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Kokesh impacting SEC enforcement program

Jaclyn Jaeger | November 15, 2017

The interplay between the length of time it takes to conduct a Foreign Corrupt Practices Act investigation and the statute of limitations is a principal challenge of the U.S. Securities and Exchange Commission, made even more challenging by a key U.S. Supreme Court ruling this summer.  

In June 2017, a unanimous Supreme Court ruled, in the case of Kokesh v. SEC, that disgorgement collected by the SEC is subject to the general five-year statute of limitations on monetary civil penalties. Since Kokesh, statute-of-limitations issues for the SEC have only grown, Steven Peikin, co-director of the SEC’s Enforcement Division, recently told an audience at the New York University School of Law.

“In many instances, by the time a foreign corruption matter...

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