SEC "Monetary Penalties Speak Very Loudly," But What Do They Say? A Critical Analysis of the SECs New Enforcement Approach

money goes raises certain questions: Does the new strategy improve the SEC’s efforts to police the securities markets and protect investors? What are

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the money goes raises certain questions: Does the new strategy improve the SEC’s efforts to police the securities markets and protect investors? What

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137. Some of this history is told in GILBERT, supra note 121, at 18-26; and USAID, USAID History, http://www.usaid.gov/about_usaid/usaidhist.html

reports identify the intended targets of the strikes, which does not necessarily reflect what was in fact hit.180 Below, we dis- cuss additional sources we