Google published a blog post this morning named Repeated violations of Webmaster Guidelines explaining that if you have repeated violations of Google's Webmaster Guidelines and those violations lead to numerous manual actions, Google may take a more serious approach to penalizing your site.
Google said "repeated violations may make a successful reconsideration process more difficult to achieve." "Especially when the repeated violation is done with a clear intention to spam, further action may be taken on the site," Google added.
What does Google mean by "further action,"? I assume it can mean a multitude of things such as longer penalty time, removal from the index completely, PageRank drop, or who knows. I did ask Google for clarification on that. Gary Illyes from Google told me on Twitter that he doesn't know the answer to that, so I assume he was not involved in the details around this blog post. I did email Google to get an official response.
Here is a quote from the blog post so we have it just in case it changes over time:
However, some sites violate the Webmaster Guidelines repeatedly after successfully going through the reconsideration process. For example, 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. Such repeated violations may make a successful reconsideration process more difficult to achieve. Especially when the repeated violation is done with a clear intention to spam, further action may be taken on the site.In order to avoid such situations, we recommend that webmasters avoid violating our Webmaster Guidelines, let alone repeating it. We, the Search Quality Team, will continue to protect users by removing spam from our search results.
John Mehlem from Google's German webmaster team said on Google+ that repeated violations are "rare."
Thing is, I always assumed Google hard stricter penalties for repeated violations.
Finally, this is about manual actions NOT algorithmic actions such as penguin and panda.
