Forwarding to Legal. I'm aware of the general problem of undisclosed COI editing, and agree that there should be some enforcement of this, particularly given that WMF wants to use Wikipedia's NPOV and RS policies as part of WMF's marketing. I also wonder if WMF might be able to recover the costs of enforcement expenses somehow, perhaps by including a statement in the TOS that says that people and their employers who engage in certain types of undisclosed COI editing must (1) reimburse WMF for attorney fees, court fees, and other related costs of investigations and enforcement, and (2) forfeit all revenue from their related activities to WMF. My guess is that significant financial penalties would be a bigger deterrent than name-and-shame and cease-and-desist letters.
Pine