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" ... In 2021, smart businesses will watch to see whether or not this "big game" approach to enforcement continues. With 2020's cases acting as precedent, expect large penalties and disgorgements to continue in 2021. However, don't be surprised if the SEC's new leadership also pursues a larger volume of EAs in 2020 due to changing priorities, as well as the possibility that enforcement teams will be able to hit the field again once a Covid-19 vaccine is broadly distributed. ... "
" ... The Libor scandals and manipulations cost banks billions in penalties and disgorgements. Regulators had enough. So in concert, they decided Libor was to fade into the sunset by 2021. ... "