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Fine should be all the revenue they made while they were breaking the law. Everyone who OK’d it should be barred from working in similar positions for life.
I’d go with prison sentences as well, especially for foreign nationals. Doesn’t need to be a long one (15-30 days) - just enough to open a international warrant.
Having an open Europol/Interpol warrant against them would hurt their job prospects far more than a ban (fully unenforceable outside the EU).
Their potential new US employer would see the conviction in their background check or the employee would have to tell any potential employer “Hey, I can’t go abroad to 80% of the world”.
So when are we getting that money?