On January 12th, the D.C. Circuit found that a petitioner violated NASD rules when he engaged in securities transactions on behalf of two clients without telling his employer. The Court further upheld the fines and suspensions imposed for those rule violations. However, the Court granted the petition challenging the SEC order imposing restitution. In the instant case, sophisticated investors willingly sought to invest their money in a highly speculative venture involving a start-up company that eventually failed. The SEC failed to establish a causal connection between petitioner's violations and the investors' losses. The SEC's judgment awarding full restitution was neither adequately explained nor supported by agency precedent. Siegel v. SEC.