Regulatory penalties: establishing and quantifying a regulatory penalty
If you think a wholesaler’s conduct has rendered them liable to a fixed penalty, you should identify the contravention at the outset.
You should also consider if any conduct which is liable to a fixed penalty is as a consequence of fraud.
Consideration of fraud
The contraventions that are liable to a fixed regulatory penalty do not normally involve fraud. They should be relatively minor contraventions and the penalties are designed to encourage compliance.