Section 6501 of the NDAA was intended to clarify the scope of the SEC’s disgorgement authority in civil litigation but ambiguities remain. One major question raised by Section 6501 is whether the accounting provisions of the Securities Exchange Act ushered in by the FCPA are scienter-based, such that the NDAA’s ten-year statute of limitations (SOL) period would apply. In this second part of a three article series, Steptoe attorneys Lucinda Low, Christopher Conte and Daniel Podair analyze what SOL will attach to the FCPA’s accounting provisions. The first article addressed the application of the NDAA’s expanded statute of limitations period to the FCPA’s anti-bribery provisions. The final segment will address how the NDAA’s provisions affect disgorgement and consider the NDAA’s implications for FCPA investigations. See “The SEC’s New Disgorgement Powers: Questions and Consequences” (Mar. 17, 2021).