Almost anyone who reads the newspaper or watches the news has observed the arrest and subsequent criminal sentencing of Bernard L. Madoff, a top Wall Street broker, for fraud. After a lengthy investigation, the Securities and Exchange Commission ("SEC") ultimately filed a civil complaint against Madoff, alleging a $50 billion swindling scheme that led to utter financial devastation for many former Madoff clients. The Federal Bureau of Investigation lodged a criminal complaint against Madoff, as well, which resulted in his arrest. The Madoff case is representative of the increasingly common, high-profile instances of major corporate and investment fraud that have caused billions of dollars in losses to everyday, unwitting investors. As a result of such cases, the SEC, as well as similar state securities regulation agencies, have increasingly cracked down on instances of securities fraud, and have embarked upon very public campaigns to prevent securities fraud through education and stricter regulations on the issuance, sales, and purchases of securities.