In Liu v. SEC, the U.S. Supreme Court affirmed the SEC’s ability to seek disgorgement as an equitable remedy for violations of the securities laws, but clarified that this power is limited by certain long-standing principles. 140 S. Ct. 1936 (2020). After Congress passed the National Defense Authorization Act for Fiscal Year 2021 (NDAA) amending the Securities Exchange Act of 1934 (Exchange Act) to provide the SEC with explicit authority to seek disgorgement in federal court, H.R.6395, 116th Cong. (2020) §6501, some wondered what the effect would be on the limiting principles set out in Liu. A year later, courts are thus far consistently applying the Liu limiting principles notwithstanding the NDAA’s amendments. Therefore, practitioners should continue to look to Liu for the relevant limits on disgorgement as an equitable remedy.