Employees of contractor updating NYC’s time-keeping software obtain bribes, kickbacks for steering work to subcontractor at inflated rates. The employees get caught; the contractor pays settlement to the gov’t. The contractor’s insurer pays $15 mil to the contractor pursuant to theft-by-employee policy. To recoup the payout, can the insurer get a piece of the restitution the thieving employees were ordered to pay? The Second Circuit says no. [Updated] But maybe they can get a piece of the forfeiture pie.