SEC Issues Statement Concerning Financial Penalties Against Corporations

On January 18, 2006, the Washington office authored an Alert Memorandum entitled “SEC Issues Statement Concerning Financial Penalties Against Corporations.” In the January 4, 2006 statement, the Securities and Exchange Commission set out principles that will guide the imposition of civil penalties against corporations in future actions. The alert memorandum summarizes the Commission’s statement and discusses how it reflects an evolution in the Commission’s thinking about corporate penalties and whether it portends a change in the Commission’s sanctions practices.