commitments on this label (including the support period) will be legally enforceable in contract and tort lawsuits and under other laws. When it comes to U.S. laws that touch technology, enforceability is a mess. Spyware, spam, fraud, misleading labels, etc. are already governed by various state and federal laws, yet enforcement efforts are whack-a-mole at best. For IoT devices, having the proposed requirements sound…
So I'm not sure "escalating penalties" is going to cut it. It's still whack-a-mole. You need a way to kill the mole, not just drive it to pop up a new hole.
You need a way to get to the principals. They're the mole.
You need to either make them personally liable financially, or you need to jail them. Nothing else is going to stop serial fraud-behind-a-shell-company.
I'm not sure I have an answer. But whatever answer there is needs to be applied not only to fraud telemarketers (please), but also to fraud IoT manufacturers/resellers.