You said 2 things:
> if they don't win (with infractions being $10 million minimum
But all of the numbers you give are the maximum possible fines. The actual fines imposed by the regulators will always bee smaller than that.
You also said:
> The citizen who filed the complaint would enlist help from a no-win-no-fee legal firm,
That's not how the fines work. They're fines, paid to the regulator. They're not compensation paid to the victim. There's no payout for no-win-no-fee solicitors, and so they're not going to get involved.