The fines aren't big enough to change their business, but they are quite possibly big enough to change their _proceedures_. I can easily imagine there becomes m

The fines aren't big enough to change their business, but they are quite possibly big enough to change their _proceedures_. I can easily imagine there becomes more stringent internal rules and processes on disclosures, even if they keep doing business the same way in general. If we are talking about fines that could cause the firm to go out of business, we need evidence of actual abuse of position. I'm not sure failure to disclose, by itself, is a sufficient transgression. On the other hand, it seems that it might be fair to penalize firm their fee on the contract, or a meaningful portion of it, on the basis of breach of contract. I'm not sure if that would be higher or lower than the current penalty.