What is disgorgement?
Disgorgement is an equitable remedy that requires a person or organization that commits fraud to give up the ill-gotten gains of that fraud. Disgorgement is an appropriate remedy because one should not be allowed to profit from illegal and reprehensible acts. The judge ruled that DOJ may pursue ill-gotten profits and will not have to demonstrate that these profits will be used to fund future misconduct. This issue is currently under appeal to the District of Columbia Court of Appeals.