Aggregation combines individual records into a summary figure. Aggregating enforcement penalties requires care about what is being added: penalty, disgorgement and interest are different things, and adding them without saying so overstates the fine.
data and analysis · updated 2026-09-08
See also
Disgorgement— Disgorgement is an order to give up gains obtained from unlawful conduct. It is remedial rather than punitive, which is why it is …
Civil monetary penalty— A civil monetary penalty is a punitive fine imposed by a regulator or court, distinct from disgorgement of gains. Statutory tiers …