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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.
4 points
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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”.