Convicted of fraud for trading on inside information stolen from employer MSD, defendant John Afriyie was ordered to pay $511,361.82 in restitution under the Mandatory Victims Restitution Act, covering MSD's fees to Sullivan & Cromwell to guide MSD's compliance with probes by the U.S. Attorney's Office and Securities and U.S. Exchange Commission; to help prepare four MSD witnesses to testify at Afriyie's criminal trial; and, to represent MSD in post-verdict restitution proceedings.

On issues prompted by the Supreme Court's 2018 decision in Lagos v U.S., the U.S. Court of Appeals for the Second Circuit held that attorney fees are not categorically exempt from recovery under the MVRA, and that restitution under the MVRA is appropriate only for expenses related to criminal matters.