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High Severity

Immediate Enforcement Before Appeal

The Division can enforce its own decisions through "such orders and directions as may be necessary" with parties facing "administrative and criminal penalties" for non-compliance (59.2-59.3). The provision appears to require immediate compliance before appeal rights are exhausted, meaning platforms could face license suspension, content removal orders, or other enforcement actions before judicial review. This creates severe operational uncertainty for digital businesses—particularly startups and smaller platforms—who must comply with potentially erroneous Division decisions immediately or face penalties, rather than having enforcement stayed pending appeal as is standard in democratic jurisdictions.