Let's have a think here – If the CASA are going to 'accept' an exposition, then they only need take a new application over the counter (accept it) collect the money (lots of) and same day issue a certificate. Piece of cake – no fuss. The holder is then solely responsible for operating legally and if CASA audit at a later date and "discover" breaches, then it would be fair to prosecute, fine, shut down or whatever.
I have been advocating this for years. The Department of Infrastructure and Transport (or whatever name they go under at a particular point in time) should be the section of Govt which accepts your AOC application and, if the correct boxes are ticked and you have an OM and Compliance Statement in your hot little hand, issue a certificate. The person accepting the application should not have any input into how you intend to comply. The Compliance Statement does that.
CASA should be the organisation to oversee and "police" the operation from then on. If they find things in you organisation are not in accordance with the Regs, write out a ticket and get it fixed or allow the courts to decide.
The way it is now, the issuance of a certificate, approval, etc. by CASA is based on an individual's interpretation of whether you comply with the applicable legislation by the individual's who has the "delegation" to issue said certificate.