Canada: fines are the most common sanction here. However, in some instances failure to comply may constitute an offense subject to prosecution. This could lead to imprisonment for up to 5 years and a fine of up to CAD $5 million. EEA Countries: the implementation of the Amended Transparency Directive (TDA) had a significant impact on the proposed sanctions across EEA countries. One of the most notable sanctions under this directive was either a fine of up to EUR ‎€10 million, or 5% of annual turnover, or up to twice profits gained or losses avoided for legal entities; and the higher of up to EUR €2 million or up to twice profits gained for individuals. France: in comparison to the TDA, France’s regulator, the AMF, has stipulated administrative sanctions that might be as high as EUR ‎€100 million, or for legal entities 15% of the total annual turnover, and if relevant, up to 10 times the amount of profits gained or losses avoided. Additionally, the AMF also proposes criminal and civil sanctions. South Korea: under the 5% regime, failure to submit a report can lead to criminal sanctions that include imprisonment of up to three years, or a fine of up to KRW 100 million. Furthermore, submission of false information or omission of material facts can lead to harsher criminal sanctions such as imprisonment of up to five years or a fine not exceeding KRW 200 million. This offense can also lead to the suspension of voting rights, or a disposal order of the infringing securities for up to 6 months.