(a) the seriousness of the contravention, in relation to the requirement(s) concerned;

(b) the duration and/or frequency of the contravention, and the extent to which it reflects more widespread weaknesses in controls and/or management; the extent to which the contravention was deliberate or reckless;

(c) the licensee's past compliance record and conduct following the contravention; and

(d) the scope of any other action taken by the CBB or other regulators against the licensee, in response to the compliance failures in question.