SEC Enforcement: Past, Present And Future

By Brian Rubin and Gregory Amoroso ( December 4, 2017, 1:07 PM EST) -- In Dan Brown's latest best-seller, "Origin,"[1] he explores the questions: (1) Where do we come from (meaning, how did life get formed)? and (2) Where are we going (or, how will we evolve)? While the U.S. Securities and Exchange Commission Division of Enforcement's "Annual Report, A Look Back at 2017"[2] is no "Origin," "The Da Vinci Code" or even "Inferno," and co-directors of enforcement Steven Peikin and Stephanie Avakian are no Robert Langdon or Ambra Vidal (as far as we know), the SEC has raised "Origin"-like questions and answers, focusing on its "broad range of the significant enforcement actions, penalties and money returned to investors"[3] during fiscal year 2017 (where do we come from?) and its priorities for the coming year: "Our goal is to continue to protect investors, deter misconduct, punish wrongdoers and keep our markets the safest and strongest in the world"[4] (or, where are we going?). Without the chase scenes, conspiracy theories and symbolism of a Dan Brown book (and without a pile of murdered bodies), this article focuses on certain past priorities of the SEC and current (and possibly future) enforcement actions....

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