dard employed for a criminal convic- tion. In some contexts, the term "viola- tion" has been held not to imply a criminal conviction. Sedinta S.P.ft.L. v. Imrex Co., Inc., 473 U.S. 479, 489, 105 S.Ct. 3275, 87 L.Ed.2d 346 (1985) (" 'violation' refers only to a failure to adhere to legal require- ments."). In S