The problem with penals is the same thing that was wrong with launch obers- you have a VERY potent squad that only costs manpower but requires the enemy to invest manpower, muntions, better positioning and have a vet advantage in order to be competative against them and even then its a toss up.
Id like to see penals turned into an unremarkable but flexible squad that requires munitions to be effective:
Start em as a 260mp squad (because of high accuracy and FANTASTIC vet) that is armed with mosins and oorah (not unlike cons, but a clearly less support oriented and better in combat) maybe a 3rs weapon slot to incentivise not upgrading them all
They can then specialize to:
Urban combat- satchels and ppshs
Strelky- svts and a standard grenade
Or anti vehicle- ptrs and AT satchel
All upgrades would fill all weapon slots and remove oorah.
That's actually a really good idea, fits their elite inf role very good.