Stock Markets June 4, 2026 10:12 AM

Supreme Court Unanimously Upholds SEC’s Broad Use of Disgorgement

Justices affirm lower-court rulings allowing the agency to recover ill-gotten gains without proving investor pecuniary loss

By Maya Rios

The U.S. Supreme Court on June 4 issued a unanimous decision siding with the Securities and Exchange Commission in a dispute over the scope of its disgorgement authority. The ruling affirms lower-court findings that the SEC may seek repayment of illegal profits even where the agency does not prove victims suffered monetary loss, and it follows litigation involving defendant Ongkaruck Sripetch and a California court order to return more than $3 million plus interest.

Supreme Court Unanimously Upholds SEC’s Broad Use of Disgorgement

Key Points

  • The Supreme Court unanimously upheld a lower-court interpretation allowing the SEC to seek disgorgement of illegal profits without proving investor pecuniary harm.
  • Defendant Ongkaruck Sripetch was ordered to repay more than $3 million plus interest after admitting securities-law violations tied to an alleged pump-and-dump scheme and receiving a 21-month prison sentence in a related criminal case.
  • Disgorgement remains a significant enforcement mechanism for the SEC, which reported about $1.4 billion in disgorgement recoveries for fiscal 2025 (excluding certain sums) and $6.1 billion in the prior fiscal year.

WASHINGTON, June 4 - The U.S. Supreme Court handed the Securities and Exchange Commission a clear victory on Thursday, ruling 9-0 in favor of the agency in litigation over the extent of its power to recoup unlawful profits through disgorgement. The decision upholds a lower court judgment that supported a broad application of the SEC’s authority to obtain monetary remedies representing ill-gotten gains.

The case was brought by a defendant identified as Ongkaruck Sripetch, who had been ordered by a federal court in California to repay in excess of $3 million plus interest after the SEC alleged he profited from financial fraud. At the heart of Sripetch’s challenge was a contention that the agency must demonstrate victims experienced economic harm before it can compel surrender of those profits.

The Supreme Court’s unanimous opinion affirmed the lower courts’ approach. The SEC’s general authority to pursue disgorgement was not contested in the litigation; that power has long been recognized by courts and is grounded in federal law. What the case tested was whether the agency must establish that its enforcement actions caused pecuniary harm to investors before seeking repayment of illicit proceeds.

According to charges brought by the SEC, Sripetch used a so-called pump-and-dump strategy, artificially boosting the price of penny stocks and then selling his shares at the inflated levels. Sripetch admitted to violating securities statutes and, in a related criminal proceeding, received a 21-month prison sentence. He challenged the civil disgorgement order on the basis that the SEC failed to prove his conduct led to share-price declines or direct financial losses to investors.

During arguments before the justices in April, attorneys representing the Justice Department contended that the SEC is not required to prove fraud produced pecuniary harm before seeking repayment remedies in court. A federal judge in California had previously sided with the SEC’s broader reading of disgorgement power, and that ruling was sustained last year by the San Francisco-based 9th U.S. Circuit Court of Appeals.

The court’s decision arrives as the SEC continues to rely on disgorgement as a major enforcement tool. The agency reported obtaining roughly $1.4 billion through disgorgement in fiscal 2025, a figure that omits certain amounts recovered by other federal agencies and excludes an $8 billion payment recorded in January 2025 from long-standing litigation tied to a Ponzi scheme. In fiscal 2024, under the previous administration, the SEC’s disgorgement recoveries totaled about $6.1 billion, representing nearly three-fourths of the agency’s total financial penalties that year.

In addition to disgorgement, the SEC retains the ability to seek fines, sanctions and other penalties through its enforcement actions. The ruling follows a distinct 2024 Supreme Court decision that constrained another aspect of the SEC’s enforcement practice, finding that administrative adjudications before the agency itself could violate the Seventh Amendment’s jury trial guarantee when seeking penalties for securities fraud.

With the high court’s unanimous endorsement of the lower courts’ view, the SEC’s capacity to pursue repayment of illegal gains without proving direct investor pecuniary loss is affirmed, though the agency continues to face other constitutional and procedural limits in its enforcement toolkit.

Risks

  • Ongoing legal and procedural constraints - While disgorgement authority is affirmed in this case, other limits on SEC enforcement remain, such as the 2024 Supreme Court ruling restricting in-house administrative adjudications, which could affect the agency’s broader enforcement strategy.
  • Enforcement variability - The SEC’s heavy reliance on disgorgement for financial recoveries creates exposure to shifts in judicial interpretation or policy that could change the agency’s penalty mix, with implications for financial firms and market participants.
  • Operational uncertainty for market intermediaries - Firms and individuals in the securities sector may face continuing uncertainty about potential civil remedies and the conditions under which disgorgement will be sought, particularly in cases involving manipulation of low-priced stocks.

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