Olivia A. Rauh is an Associate in the Washington, D.C., office of Buckley LLP, where she represents corporate and individual clients in a wide range of government enforcement, litigation, regulatory, and compliance matters.
Ms. Rauh received her J.D. from the University of Pennsylvania in 2018, and her B.A. (magna cum laude) from Colgate University in 2015.
A recent Supreme Court decision allows the Securities and Exchange Commission to continue pursuing disgorgement in its enforcement actions, but with significant limitations that will curb disgorgement’s scope and could complicate the SEC’s future efforts to seek it.
Whether the SEC has...Buckley Commentary & Analysis
"Supreme Court will likely decide whether courts can order disgorgement in SEC enforcement proceedings" by Olivia A. Rauh
The Supreme Court will hear arguments on March 3 in a case that will likely determine whether the SEC has statutory authority to seek disgorgement in enforcement actions, and whether the courts have authority to order it.
The SEC’s authority to seek disgorgement was virtually...Buckley Commentary & Analysis