In general, a lot of government fees and penalties are not just about that penalty, it's about the fact that if you do it again, the next one will be much, much bigger. Read the $150K as a warning shot across the bow.

There are some places where this doesn't seem to operate very well, particularly in the financial world, but in general, this is often the idea behind these penalties. Especially for the first time a law is getting enforced; it isn't really very just to ignore a law for years/decades and then one day out of the blue slam someone with multi-million dollar judgments. There are even some Common Law doctrines that the targets could use to argue against such penalties holding up in court, though, as always, trying to counter a written law with common law general doctrines is tricky. But I'd say there's at least a good chance you could get a sudden, huge initial penalty argued way down in a lawsuit.