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Expert Analysis

Making Sense Of SEC Civil Money Penalties

Law360, New York (March 4, 2014, 2:24 PM EST) -- If you or your company has ever been involved in a long U.S. Securities and Exchange Commission enforcement investigation, you’ve probably gone through the five stages of grief — denial that you did anything wrong, anger that the enforcement lawyers are pursuing you, hope that things won’t turn out too badly, depression that it appears they will, and finally acceptance that it’s best to resolve the matter and move on even though you think the outcome is unfair.

One of the stumbling blocks in the final stage is grappling with the amount of the money penalty, i.e., the fine on top...

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