Enforcement Without Judicial Safeguards
The Division can enforce its own decisions immediately through "such orders and directions as may be necessary" (59.3), with parties facing "administrative and criminal penalties" for non-compliance (59.2) before appeal rights are exhausted. This creates severe business uncertainty as license suspensions, content restrictions, or financial penalties could be enforced immediately, causing irreversible operational and reputational harm even if later overturned on appeal. The provision concentrates investigative, adjudicatory, and enforcement powers in the same body without explicit protection for businesses during the appeal period.