How do you seal cards if the deck is empty?

Specifically, does this incur a reshuffle penalty? Even with the updated FAQ that mentions "drawing" rather than "the draw step", this is not clear because the manual says. that to seal a card you "reveal" it from the top of the deck. It specifically does not say that you "draw" it from the top of your deck. So in order to seal the card, do you first 'draw' it (and hence suffer reshuffle penalty)?