Although predominantly a military spending bill, the National Defense Authorization Act (NDAA) includes consequential changes to the SEC’s power to recover disgorgement of ill-gotten gains for securities violations. Regulated entities and individuals should be aware of these changes and the questions that courts will need to answer about them in coming years. In a guest article, Palmina Fava, Cliff Thau, Marisa Antonelli and David Hoffman of Vinson & Elkins provide concrete steps companies can take in anticipation of this sea change in SEC enforcement. See “What to Expect From the Biden Administration’s New Anti-Corruption Tools” (Mar. 3, 2021).