A Manhattan federal judge has injected new doubts into a string of cases challenging an increasingly common tactic by the Securities and Exchange Commission: pursuing fraud and insider trading claims in agency enforcement proceedings, rather than in federal court.

U.S. District Judge Lewis Kaplan on Thursday rejected a bid by money manager Wing Chau, whom the SEC accused of defrauding investors in a $1.5 billion collateralized debt obligation, to block an SEC administrative judge from ruling in his case. A trial in the SEC proceeding has already taken place, and an administrative law judge is expected to rule in January.

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