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Supreme Court Upholds SEC Disgorgement Without Proof of Investor Loss

The unanimous June 4 ruling limits disgorgement to a wrongdoer’s net profits and resolves a split over whether the SEC must show investors suffered pecuniary harm.

FILE - The seal of the U.S. Securities and Exchange Commission is seen on the building in Washington, Dec. 3, 2024. (AP Photo/Jose Luis Magana, File)
The Supreme Court is seen in Washington, Monday, May 18, 2026. (AP Photo/J. Scott Applewhite)
The Supreme Court is seen in Washington, Monday, May 18, 2026. (AP Photo/J. Scott Applewhite)
United States Securities and Exchange Commission logo and U.S. flag are seen in this illustration taken April 23, 2025. REUTERS/Dado Ruvic/Illustration/File Photo

Overview

  • The Supreme Court on Thursday issued a unanimous opinion by Justice Neil Gorsuch holding that the SEC need not prove investors suffered financial loss before obtaining disgorgement.
  • The Court reaffirmed that disgorgement must be tied to a defendant’s net profits rather than gross receipts and grounded the rule in traditional equitable restitution principles.
  • The case arose from Ongkaruck Sripetch’s penny‑stock pump‑and‑dump schemes; Sripetch consented to civil judgment and received a related 21‑month criminal sentence.
  • The decision immediately strengthens the SEC’s leverage in enforcement and settlements, a change analysts say is especially consequential in markets like crypto where tracing individual investor losses is difficult.
  • The Court left open major issues for future cases, including whether disgorged funds must be returned to victims or may go to the Treasury and whether statutory disgorgement triggers a Seventh Amendment jury right—a point Justice Clarence Thomas pressed in concurrence.