There are certainly a variety; as to how low they go and how high they go, I don't know. The Competition Act certainly has an administrative monetary penalty regime. The only point I would make is that usually the amount prescribed in an administrative monetary penalty scheme takes into account the nature of the potential regulatory offences that one is talking about, as well as all the facts and context.
For example, in the Competition Act you may be dealing with millions and millions of dollars, so the administrative monetary penalty scheme may reflect the amounts you are actually dealing with. So it may be a larger amount than you might see in another administrative monetary penalty scheme where you're dealing with things like a failure to file a report and you're talking about people who make $100,000 a year.
It's going to vary. There's a point where, once you get to...and what that point is is difficult to say, because it's contextual and the courts will determine on a fact-by-fact basis. There's a point where, if you're trying to create an administrative monetary penalty scheme, if you set the threshold of your monetary penalty too high, it then transforms. In a sense, it can be viewed as more akin to a fine and bring with it a whole host of procedural fairness, natural justice safeguards. If they are not in the act, the court will strike down your regime as being not sufficient under the charter. So there are issues.
The one point I would make is that the amendment as has been proposed does not simply raise the $500 threshold under proposed section 52 of the Conflict of Interest Act; it is setting out that there would be a $50,000 administrative monetary penalty for violations that are not set out in proposed section 52. So it's actually hitting on violations that are not the ones we have prescribed in clause 52, which are the ones around filing of reports and so on; it would actually be violations of the substantive parts of the code.