Do you spam Google repeatedly? Google may decide to serve you harsher penalties and manual actions in the future.
In a blog post, from the Google Webmaster Blog, Google’s Search Quality Team stated that if webmasters repeatedly violate the Google Webmaster Guidelines, Google may take “further action” against their sites and/or make “a successful reconsideration process more difficult to achieve.”
Google is specifically referring to the manual actions taken by Google Search Quality representatives. Google is not talking about the algorithm updates like Panda, Penguin etc.
One example from 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.” For cases like these or similar, Google may choose to make it harder for a successful reconsideration or enforce harsher penalties.
I'm not certain Google will specify what is entailed in their "further action" and I don't concern myself with knowing those answers because here at Pulse Media Solutions we don't put ourselves or any of our clients in those predicaments.
You may be able to learn more about that intent at the Google Webmaster Blog.