2nd Circ. Ruling Limits Collection Beyond Restitution Terms

By Rachel Maimin, Jason Gould and Jennifer Jameson ( November 9, 2026, 2:56 PM EST) -- On Sept. 21, in In re: IIG Structured Trade Finance Fund Ltd., the U.S. Court of Appeals for the Second Circuit held that where a restitution judgment includes a payment schedule and does not require immediate payment, "the government is not entitled to a turnover order to collect funds for restitution above and beyond the payment schedule." This is so even when a defendant's assets substantially appreciate....

Law360 is on it, so you are, too.

A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence. Over 200 articles are published daily across more than 60 topics, industries, practice areas and jurisdictions.


A Law360 subscription includes features such as

  • Daily newsletters
  • Expert analysis
  • Mobile app
  • Advanced search
  • Judge information
  • Real-time alerts
  • 450K+ searchable archived articles

And more!

Experience Law360 today with a free 7-day trial.

Start Free Trial

Already a subscriber? Click here to login