In administrative sanctioning procedures initiated by the OEFA, does the filing of appeals suspend the accrual of interest? Apparently, no longer

Abstract

The COAC of OEFA initiated enforcement proceedings requiring interest payments from the fine imposed in the first administrative instance, despite reconsiderations and/or appeals, raising concerns since Article 24 of the PAS Regulation suspends fines during appeals. This article analyzes the legality of this interpretation, its communication, and the reasonableness of accrued interest during the appeal process, even if authorities exceed the legal deadline to resolve.