Virtual currencies were front and center again this week. The SEC’s Divisions of Enforcement and Trading and Markets issued a rare joint statement cautioning investors about trading virtual currencies. At the same time the CFTC secured a ruling affirming its …
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Kokesh on Remand: Applying the Statute of Limitations
In Kokesh the Supreme Court rejected the SEC’s claim that disgorgement is equitable, concluding that as used in agency enforcement actions it is in fact a penalty. The Court also reserved the questions of whether the Commission is entitled to …
Kokesh on Remand: Applying the Statute of Limitations
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