Disgorgement is an order to give up gains obtained from unlawful conduct. It is remedial rather than punitive, which is why it is tracked separately from civil penalties: adding the two together and calling the result a fine double-counts the harm.
law and enforcement · updated 2026-10-16
See also
Civil monetary penalty— A civil monetary penalty is a punitive fine imposed by a regulator or court, distinct from disgorgement of gains. Statutory tiers …
Prejudgment interest— Prejudgment interest is the time value of disgorged gains between the conduct and the judgment. It is a component of monetary reli…
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