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High Severity

Sanctions Stacking Enables Speech Suppression

This provision permits the Division to impose multiple simultaneous sanctions—including correction orders, content removal, access blocking, license suspension, administrative penalties, and criminal penalties—with only vague "necessary and proportionate" language providing no objective criteria. Combined with 63, which permits sanctions "even if the person does not know or has no reason to believe that the information is false," this creates liability without fault. The framework eliminates incentives for voluntary correction by permitting sanctions even after removal/retraction, and concentrates enforcement power in a non-judicial Division with a President-appointed Director who acts as both investigator and adjudicator. This creates severe chilling effect as speakers face arbitrary stacking of severe penalties for innocent mistakes or good-faith errors.