A global shift in the regulatory approach to penalties is leading to greater fines across more geographies and the use of a wider variety of recourse against a bigger cross-section of targets, notably individuals and executives. Not even annual bonuses, stock shares and promotions are safe under the broadening definitions of clawbacks being sought. “We’re recalibrating and looking at how we can have penalties that don’t just punish the misconduct that occurred but also deter future misconduct,” said Stacy Bogert, Associate Director of the SEC’s Division of Enforcement, at a session in the Global Enforcement & Compliance series presented by the Women’s White Collar Defense Association in Washington, D.C. The discussion, “The Penalty Phase: Developments in Sentencing, Forfeiture, and Clawbacks on the Global Stage,” featured Deborah Connor, partner at Morrison & Foerster; Claire Murray, Vice Chair of the U.S. Sentencing Commission; Steven Fitzpatrick, Senior Attorney in the Proceeds of Crime and International Assistance Division of the U.K.’s Serious Fraud Office; and Evelyn Sheehan, partner at Kobre & Kim. See our two-part series “Why, When and How Fund Managers Should Self-Report Violations to the SEC”: Part One (Jan. 10, 2019); and Part Two (Jan. 17, 2019).