| http://www.w3.org/ns/prov#value | - The Respondent argues that a cease and desist order is not an available sanction in this case because: 1) it would be a retroactive application of the Securities Enforcement Remedies and Penny Stock Reform Act of 1990 (Remedies Act); 2) a cease and desist order requires a finding of likelihood of future violation; and 3) a cease and desist order is a penalty and is therefore barred by the five-yea
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