(151) The legal systems of Denmark and Estonia do not provide for administrative fines as defined in this regulation. The provisions on administrative fines can be applied so that in Denmark the competent national court will impose a fine as a criminal sanction, and in Estonia the supervisory authority will impose a fine as part of an infraction proceeding, provided that such application of the provisions in those Member States will have an effect equivalent to an administrative fine imposed by the supervisory authority. Therefore, the competent national court should take into account the recommendation of the supervisory authority that advocates the imposition of a fine. The fines imposed must in any case be effective, proportionate and dissuasive.