Dorothy Heyl, of counsel at Milbank, Tweed, Hadley & McCloy, writes that with SEC penalties higher than ever - despite the public clamor for even higher penalties - a decision by the Supreme Court last term again raises the specter for the SEC that when the SEC seeks penalties in "civil" actions, defendants might deserve the constitutional protections afforded criminal defendants.
Be Careful What You Wish for - SEC Penalties Act and 'Southern Union'
New York Law Journal
October 12, 2012
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