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The trial judge imposed penalties of about $18 million.
Standard Life recently imposed penalties of up to 25% on early surrender of policies.
The university had imposed penalties on itself last year in hopes of pre-empting further sanctions.
If sanctions are imposed, penalties could include the cutoff of U.S. assistance and certain export restrictions.
The legislation could also have imposed penalties for failing to create the accounts.
It filed an administrative proceeding against Ernst, and an administrative law judge imposed penalties.
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Treasury-imposed penalties for the non-implementation of welfare reforms are currently running at £10m a month, and the DUP has argued that without change there will be an unsustainable funding gap estimated at around £600m by the summer.
The N.C.A.A. largely accepted Mississippi State's self-imposed penalties on its football program for recruiting violations.
It could accept Michigan's self-imposed penalties or assess more sanctions.
Miami is fighting back, with the university president, Donna E. Shalala, calling for the N.C.A.A. to end the investigation with its self-imposed penalties in place.
COLLEGES NCAA--Accepted Rutgers' self-imposed penalties of two years' probation and the loss of 20 total scholarships in 10 sports for violating eligibility and financial aid rules.
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