• I repeat the thanks to @Velocio

    I respect you have done the hard work to keep this place going and it's your choice to make.
    But you are not alone on this, and some legal expertise might illuminate an alternative path.

    E.g. regardless of how threatening the OSB'23 might appear, OFCOM doesn't have the ability or goal to destroy, Section 392 Communications Act 2003 means they have to publish (and then follow) their penalty guidelines. These (last updated Sept.17) are clear on the objective of penalties and "Ofcom will ensure that the overall amount of the penalty is appropriate and proportionate to the contravention in respect of which it is imposed, taking into account the size and turnover of the regulated body."

  • For what it's worth they've got a consultation doc out specifying that "the actual penalty amount that we impose in a given case within the penalty maximum is calculated in line with our Penalty Guidelines and must be appropriate and proportionate" so I'm sure there's no intent to get rid of that approach.

    The list of criminal offences out also doesn't seem to be the sort of thing you might inadvertently trip, so it may be worth exploring what the risk of disproportionate civil liabilities/Ofcom penalties may be?

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