The U.S. Supreme Court’s recent decision in Liu v. SEC limits the SEC’s ability to collect disgorgement from defendants in SEC enforcement actions. The limitations the Court imposed did not curb the SEC’s general authority to seek disgorgement of the proceeds of defendants’ fraudulent schemes, but they may require a greater effort on the part of the SEC to evaluate the connection between the money it seeks in disgorgement and the sources of that money, David Slovick, partner at Barnes & Thornburg and former senior official in the SEC’s Enforcement Division, explains in a guest article. He reviews the Kokesh decision that preceded the Liu case, the lower courts’ decisions in Liu, the Supreme Court’s recent ruling, as well as Liu’s implications. See “How the SEC May Circumvent the Five-Year Statute of Limitations on Disgorgement Under Kokesh v. SEC” (Aug. 16, 2017).