As you correctly pointed out in the question, Australia and New Zealand are both analogues we've looked at that have tribunal mechanisms. The U.K. has a tribunal mechanism that's organized slightly differently from what's being proposed under the CPPA. Again, as I pointed out earlier, different jurisdictions have different kinds of constitutional frameworks that can drive those differences.
It's also important to recognize that when we're looking at analogues around the world, a lot of the privacy rule sets or legal frameworks have very different applications and very different scope, and therefore would necessitate different kinds of oversight mechanisms. A good example that we referenced earlier today is California, which has come up in this committee a number of times over the last few weeks. California's administrative monetary penalty regime is capped at between $2,500 and $7,500 per transgression. At that level, it may not be necessary to have a body of expertise dedicated to understanding the issues and determining the right level of monetary penalty that would be applied.
In this case, under CPPA, we're talking about going up to $10 million or 3% of global revenues. That is a very significant impact. I think a degree of procedural fairness would be expected. That's why the tribunal is a core part of the government's proposal.