On March 20, 2012, Judge Denise L. Cote of the United States District Court for the Southern District of New York ordered Joseph F. ‘‘Chip’’ Skowron III (‘‘Skowron’’) to pay $10 million in restitution to Morgan Stanley as a corporate victim of Skowron’s insider trading and obstruction of justice schemes. Judge Cote’s decision in United States v. Skowron, No. 11 Cr. 699 (DLC), 2012 BL 652827 (S.D.N.Y. Mar. 20, 2012) provides a useful roadmap for evaluating potential avenues
for restitution to corporations that fall victim to insider trading schemes by their employees.

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