Posts tagged ‘second circuit’
Second Circuit As To SEC Settlement Policy – “It Is Not … The Proper Function Of Federal Courts To Dictate Policy To Executive Administrative Agencies”
By Mike Koehler
Published March 16 2012, FCPA Professor
Previous posts (here, here, and here) have discussed Judge Jed Rakoff’s (S.D.N.Y.) concerns of the SEC’s neither admit nor deny settlement policy. Judge Rakoff’s concerns have not been in FCPA cases, but the SEC uses the same settlement policy in FCPA cases – both corporate and individual resolutions. Read more
