The Securities and Exchange Commission issued a press release on April 7, 2026, announcing the agency’s enforcement results for transitional period under the new presidential administration.[1]

Describing FY 2025 as “a unique period of transition,” the statement pointed to a pulse of enforcement actions initiated between October and December 2024 [2] under outgoing SEC Chair Gary Gensler, critiquing the activity as “unprecedented rush” and the focus as an “aggressive pursuit of novel legal theories.”[3]. Current SEC Chair Paul S. Atkins described the shift as having “redirected resources toward the types of misconduct that inflict the greatest harm—particularly fraud, market manipulation, and abuses of trust.”[4]

During FY 2025, the SEC brought 303 standalone enforcement actions, a combination of civil suits and administrative procedures that excludes follow-on actions.[5] This represented a 29.7 percent decrease from the prior year and the fewest actions since at least 2013 when the agency’s current announcement format began:

According to the SEC, this decline was due to its shift in priorities:

The current Commission deliberately refocused the enforcement program on matters of fraud—cases that inherently require more time and resources to develop and bring, often requiring up to two or more years to manifest results.[6]

The agency described this realignment as an intent to bring enforcement efforts to bear on what the new leadership views as better guided by “investor protection above all,” articulating a set of goals:

• Protecting retail investors: The SEC views retail investors as “particularly vulnerable to securities fraud” and has “brought actions to address conduct involving fraudsters who targeted veterans, seniors, and members of [an Ismaili] community” [7] in Texas.
• Holding individual wrongdoers accountable: The SEC reported a 27 percent increase in the number of actions brought against one or more individuals.
• Combatting securities fraud wherever it occurs: The SEC includes actions against market manipulation and the formation of its Cross-Border Task Force as part of this initiative.
• Safeguarding markets from abusive trading: The SEC views this to encompass conduct such as insider trading, market manipulation, and “spoofing” (submitting securities transaction orders designed to influence prices but not be executed).

The SEC further elaborated on its shift away from certain types of enforcement:

Since fiscal year 2022, the prior Commission brought 95 actions and $2.3 billion in penalties against firms for book-and-record violations, specifically failing to maintain and preserve off-channel communications.[8]

The agency characterized these, plus seven digital asset (i.e., cryptocurrency)-related cases and six “definition of a dealer” cases, as having:

no direct investor harm[,] no investor benefit or protection, and demonstrate what the current Commission views as a misinterpretation of the federal securities laws, a misallocation of Commission resources, and a bias for volume of cases brought versus matters of investor protection.[9]

In light of the two-plus-year time frame for results of the new case types that the SEC projects it will be concentrating on, investors may not see the volume of enforcement actions return to prior levels for some time to come. 

Takeaways

Although the absolute number of enforcement actions has declined during the past fiscal year, registrants should remain cognizant that these results do not speak to the number of ongoing investigations. The SEC continues to conduct compliance examinations and launch investigations, and, as SEC leadership has noted, many investigations take years to complete. 

Consequently, while the overall number of enforcement actions brought by the SEC has declined since the beginning of FY 2025, registrants should not lose focus on maintaining robust compliance programs and ensuring compliance with applicable SEC rules. Most SEC enforcement actions are subject to a five-year statute of limitations or longer, and it is possible that changes in SEC leadership or priorities will return to a more aggressive approach to enforcement at the agency in the future.

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[1] SEC, SEC Announces Enforcement Results for Fiscal Year 2025, Apr. 7, 2026, available at https://www.sec.gov/newsroom/press-releases/2026-34.

[2] SEC, SEC Announces Record Enforcement Actions Brought in First Quarter of Fiscal Year 2025, Jan. 17, 2025, available at https://www.sec.gov/newsroom/press-releases/2025-26.

[3] SEC, Apr. 7, supra.

[4] Id.

[5] SEC, Addendum to Division of Enforcement Press Release, Apr. 7, 2026, available at https://www.law360.com/articles/2462727/attachments/0.

[6] SEC, Apr. 7, supra.

[7] Secs. & Exch. Comm’n v. Rawjani, No. 3:25-civ-02404-L (N.D. Tex. filed Sept. 5, 2025).

[8] SEC, Apr. 7, supra.

[9] Id.