In a blog post this morning, written anonymously at the Google Webmaster Blog, Google’s Search Quality Team said that if webmasters repeatedly violate the Google Webmaster Guidelines and get caught, Google may take “further action” against their sites and/or make “a successful reconsideration process more difficult to achieve.”
Google is talking specifically about manual actions, the penalties you see in the Google Search Console, issued manually by Google Search Quality representatives. This is not talking about the algorithmic actions that happen automatically through algorithms such as Panda, Penguin and the other search quality algorithms.
The example given by Google was “a webmaster who received a Manual Action notification based on an unnatural link to another site may nofollow the link, submit a reconsideration request, then, after successfully being reconsidered, delete the nofollow for the link.” In these cases, the webmaster may see that it is harder to receive a successful reconsideration request, or he may see stiffer penalties on his site.
I asked Google to comment about what specifically they mean by further action, and I am waiting for a reply. But I suspect this may mean that the site may have a longer time period to wait to get out of the penalty, or the action man be as extreme as deindexing the whole site from Google.
You may be able to learn more about that intent at the Google Webmaster Blog.