Second Circuit Clarifies Criminal Forfeiture Law By Solomon L. Wisenberg on October 14, 2013 Email this postTweet this postLike this postShare this post on LinkedIn On Friday, the Second Circuit held that 18 U.S.C. Section 982(a)(2) requires forfeiture of the gross receipts of a criminal violation, rather than the mere profits. The case is United States v. Peters. (wisenberg)