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Top 10 SEC Settlements
In recent years the SEC has imposed unprecedented penalties in its
enforcement actions. Prior to the passage of SOX, the largest penalty imposed in an SEC enforcement
action against a publicly traded company for financial fraud was the $10 million penalty against
Xerox in April 2002. NERA's research has shown that since SOX, the SEC has imposed penalties of
$10 million or more against 115 parties, including 14 that were penalized at least $100 million. In
February 2006, the SEC reached an $800 million settlement with American International Group, the
largest penalty since SOX.
Lists of the most recent and largest settlements identified in our study are listed below.

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