The Securities and Exchange Commission seemed to bring closure the largest corporate fraud scandal in history in July, when it announced final civil settlements with former WorldCom Chief Financial Officer Scott Sullivan and five other executives at the former telecommunications company.

At the time, Sullivan had agreed to be liable for $10 million in disgorgement and nearly $3.6 million in prejudgment interest. Observers were startled to learn, however, that as part of the deal the SEC agreed to waive the actual payment of those monies, and wouldn’t impose a civil penalty against Sullivan and two of the accountants based on their ...