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What is New After Liu: Unsettled Questions Surrounding SEC Disgorgement

On June 22, 2020, in Liu v. SEC, the Supreme Court held in an 8-1 decision that the SEC is authorized under 15 U.S.C. § 78u(d)(5) (2015) to seek disgorgement as “equitable relief” in district court actions, as long as the...more

The Lasting Impact of Kokesh: Footnote 3 and Beyond

In June 2017, the Supreme Court held in Kokesh v. SEC that SEC disgorgement is a penalty, rather than an equitable remedy, and thus subject to the five-year statute of limitations codified in 28 U.S.C. § 2462. More than two...more

The Catch with Kokesh: Insurers Refusing to Cover Disgorgement to SEC

In the wake of the Supreme Court’s unanimous decision in Kokesh v. SEC, which defined disgorgement as a penalty subject to the five-year statute of limitations, we observed that the decision was likely to have far-reaching...more

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