He himself finds the penalty payment a useful and effective instrument. But there is also criticism. Especially on circumventing a criminal trial. “Double punishment is not allowed in our legal system,” Schilder explains. “The question then is whether an order subject to a penalty is a type of criminal law, but that is not the case, the judiciary also recognizes. The order subject to a penalty is not a punishment, but an incentive to encourage someone not to commit the same offense again.” .”