1st) How do you know the buyer 'cloaked' their request. Maybe it was like the OPs link buyer (they requested no JS links so their intention was to get PR) Maybe the main goal was not PR passing but they reviewed previous or current external links on VVVs site and saw an added benefit in VVVs site because he didn't nofollow his links.
2nd) Whether or not it was their intention from the beginning... when it comes renewal time the decision will partly be made on what they 'think' or see that they are getting now.
3rd) If Google sees the cloaking they will likely take a closer look at the site being looked at.
I have no problem with nofollows. I plan sell advertising on my site next year and the agreement will specify that any advertising on my site is nofollow.
I have no intention of deceiving the people that pay me
I sell books & DVDs now. When I sell something I describe what I am selling, warts and all. I don't sell knockoff China DVD imports and then tell the buyer that they didn't specify originals when they complain.