Tag: penalty

Insider trading has long been a key component of the Commission’s enforcement program. Yet over the years the exact theory being employed has varied. Nevertheless, the core theory has remained constant – using inside information for personal benefit in connection …

When Small Insider Trading Profits Yield a Max Penalty

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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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