It's quite correct that the current section 52 does not provide for a monetary penalty at all in respect of the substantive obligations that are imposed today, the obligations that obtain during one's time as a public office holder or afterwards, when one is governed by the post-employment obligations, a cooling-off period and the like. That is not in the nature of an omission.
The current provision in proposed section 52 is designed to assist the Ethics Commissioner in ensuring compliance with the various filing requirements, which can be quite burdensome. The Ethics Commissioner had raised this at one point, that he would like some administrative tools to ensure that public office holders across the board are filing and giving him the information as required. So these tailored provisions are designed to assist in that.
In respect of breaches of the substantive provisions, the act, as did the code before it, has as the major compliance mechanism the public report. We have a commissioner who has powers to compel evidence, powers to compel persons to give testimony before him. He issues a report. The report is made public. The report is filed with the Prime Minister, the complainant, and the public office holder complained against. At that point, the matter of sanction, if any, becomes a matter for the Prime Minister. In some cases the Prime Minister would have to act, of course, through the Governor in Council.
All of that is consistent with and doesn't derogate from the Prime Minister's role and accountability for the comportment of his ministry, the comportment of public office holders. That's a feature of this system and of any Westminster system.