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Minimum fine is $20 million, isn’t it?


No. It's part of the calculation for the maximum fine.

The maximum fine is defined as €20,000,000 or 4% of your global anual turnover, whichever is largest.


Yep

> Up to €20 million, or 4% of the worldwide annual revenue of the prior financial year, whichever is higher

https://www.gdpreu.org/compliance/fines-and-penalties/




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