If any clear theme emerges from a review of the Australian Competition and Consumer Commission’s (ACCC) enforcement activity in 2018, it would have to be ‘penalties’. In 2018, the ACCC had a laser-like focus on pushing the boundaries on penalties and in 2018 we saw another record set for the highest ever penalty for breaches of the Australian Consumer Law (ACL). The ACCC’s efforts in the Courts to increase penalties were also complemented by it securing legislative reform to increase penalties for future ACL breaches. The ACCC had commented for some time that ACL penalties needed to be higher and not be seen as merely the ‘cost of doing business’.