For the first time, the Securities and Exchange Commission is seeking to enforce a provision of the 2002 Sarbanes-Oxley Act, enacted in the wake of the Enron and WorldCom scandals, which provides that any CEO or CFO shall pay back any bonuses or incentive-based compensation whenever the company is required to prepare an accounting restatement necessitated by misconduct ? but not necessarily the CEO’s or CFO’s own misconduct.