In a significant recent decision, Securities and Exchange Commission v. Govil, the Second Circuit substantially narrowed the scope of the Securities and Exchange Commission’s (SEC) disgorgement powers to cases in which the...more
On Nov. 23, the New York Court of Appeals held in a 6-1 ruling that an investment firm’s $140 million disgorgement payment to the Securities and Exchange Commission (SEC) was not a “penalt[y] imposed by law” under the firm’s...more