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High Severity

Undefined Penalties Create Business Uncertainty

Section 47 establishes criminal offenses for violating "regulations, rules, orders or directives" but leaves penalties completely unspecified (marked as "...................................................."), violating fundamental legal certainty principles. Businesses operating under the mandatory licensing regime cannot assess enforcement risks or compliance costs. Section 48 compounds this by imposing strict personal criminal liability on all directors and officers for company violations—they are "deemed to have committed" offenses regardless of personal involvement, though a due diligence defense exists. Combined with the Authority's broad inspection powers in 40, this creates arbitrary enforcement potential and significant personal risk for business leadership.