Tag: penalty

One of the guiding principles of the current SEC Enforcement program is to “Impose Sanctions That Most Effectively Further Enforcement Goals.” SEC Division of Enforcement Annual Report 2017. Yet just months prior to the issuance of that Report, the Supreme …

SEC Disgorgement: A Path For Reform? Read More »

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In Gabelli v. SEC, 133 S.Ct. 1216 (2013) the Court cautioned against leaving “defendants exposed to Government enforcement action . . . for an additional uncertain period into the future” beyond the five year limitation period of §2462 of Title …

SEC Request For Declaratory Relief, Injunction Time Barred Read More »

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