Oh well I tend to like to make the punishment fit the crime. If she has cum without permission, then no touching can be fitting, or ruining orgasm after orgasm until she cries.
But pain tends to work best. Menthol cream like deep heat or icy hot, rubbed into her soft, tender parts. Once applied, unable to do anything about it. Just having to suffer and scream into a pillow and drip, oh yes, drip, drip, drip. Her body trying to put out the fire, although sometimes it ignites something even deeper.