Penals AT package upgrade should start with AT satchel on cooldown.
One thing that it is very anoying in this game is the unit upgrades while fighting, but the penal upgrade is on other level of annoyment.
The situation: while you are persuing unupgraded penals with your vehicles, they get the upgrade, and boom, they snare your tank with their semi-nuclear satchel bomb coming out of nowhere.
Maybe this can be addressed on the next patch?
you can argue the exact same thing about conscripts, riflemen and volks.
"They got access to their snare just as I pushed them with my vehicle"
This is just a non-issue