Tag: disgorgement

SEC Disgorgement: A Path For Reform?

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

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High Court Rejects SEC Effort to Avoid Limitation Period Again

p>Section 2462 of Title 28 imposes a five year statute of limitations in “an action, suit or proceeding for the enforcement of any civil fine, penalty, or forfeiture . . .” Twice the SEC has told the Supreme Court that

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