I disagree. A financial penalty in a year of 'overspending' isnt really a penalty for someone who likes to spend more than he earns. Why not simply overspend every year and budget the fines into your overspending?
By imposing a fine which is fairly small relative to the size of the business - something like 60m euro over 3 years - and counting that against FFP they are not making it 'almost impossible for them not to overspend in the following year'. Each club controls its own expenses and UEFA is simply encouraging them to 'cut' theirs. In effect they are saying that if you overspend by FFP rules in one year, a degree of the overspend must be made up by underspending relative to FFP limits in future years.
It's a reasonable point, but it only really works if you then assume that there is a fixed penalty which would be the same year on year.
UEFA has indicated that this is not the case, and that repeat offenders will be more heavily punished. In fact the main reason for not simply suspending clubs from the off is that UEFA reserves the option for this as a harsher sanction in future. As there are degrees of overspending, there should be degrees of punishment, ranging from fines to an outright ban.
You are asking the club to cut its expenses (or raise revenues) already in order to comply. There is no provision for long-term non-compliance, clubs taking the piss like that will simply be booted out.
Given that the largest expense is in wages, and that clubs cannot simply stop paying players, you can't just shift the goalposts by as much as £20m a year and expect a club to absorb that loss without breaching the contracts of employment of the playing staff. That's very clearly not the aim here.
I'm not saying fines are a perfect solution, they aren't, but the sort of double-jeopardy punishment you support would never survive a legal challenge, as the penalty itself would make the rules significantly harder to comply with and thus be counter-productive.