The idea that punishments kick in the first time that the books are looked at imo is grossly unfair. Surely the first few years need to be a case of cementing the laws as things are encountered. A bit of common sense and fairness would be to examine the books, disagree with certain parts and review the accounts for 2 years together next year, i.e. not let any club off but be definitive about what is allowed before prematurely punishing anyone.
It's like being told that you need to dress well before being let into a nightclub and at the door being told that a shirt and tie isn't appropriate so being kicked in the balls.