moneyIn October, the annual “SEC Speaks” event took place, where the SEC Chair, Commissioners, senior leaders and other staff provided public remarks and updates on the initiatives and priorities of the agency.  One of the speeches was given by Gurbir Grewal, the new SEC Director of the Division of Enforcement.  Director Grewal’s speech focused on

courthouseThree years ago, the Supreme Court issued its decision in Kokesh v. U.S. Securities and Exchange Commission, 581 U.S. ___ (2017), holding that the remedy of disgorgement in SEC civil enforcement proceedings constitutes a penalty for statute of limitations purposes. Kokesh was issued alongside the decision in Honeycutt v. United States, 581 U.S.