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The principle for assessing the proportionality of punitive sanctions, such as those under the Foreign Nationals Employment Act (Wav), has remained the same for decades: the fine must be proportionate to the offender's degree of culpability and the severity of the violation. The Minister's Wav fine policy lagged behind for a long time. With the new policy rule on fine imposition, the Minister appears to finally be changing course and assessing proportionality based on these two principles. Read the article.