Key Takeaways from SEC FY 2025 Enforcement Results: 456 Actions, $17.6B Relief

April 14, 2026

Key Takeaways from the SEC’s FY 2025 Enforcement Results

Dan Baskerville, Michael Birnbaum, Kimberly Hamm, Haimavathi Marlier, Nicole Serfoss Morrison & Foerster LLP + Follow Contact LinkedIn Facebook X Send Embed

On April 7, 2026, the SEC’s Division of Enforcement announced enforcement results for FY 2025, providing the first aggregate glimpse into enforcement activity under SEC Chair Atkins, sworn into office on April 21, 2025. In FY 2025 (October 2024 through September 2025), the agency filed a total of 456 enforcement actions (including 69 “follow on” administrative proceedings and 84 actions for delinquent filings) and secured orders for monetary relief totaling approximately $17.6 billion ($10.8 billion in disgorgement and prejudgment interest and $7.2 billion in civil penalties, less $363 million in certain offsets and penalties). However, more than half of the total enforcement actions for FY 2025 were filed between October 2024 and inauguration day (January 19, 2025) under then-Chair Gensler’s leadership. [1] The Division stressed that these results did not include 1,095 investigations that were closed or otherwise not pursued and criticized “an unprecedented rush to bring a significant number of cases in advance of the presidential inauguration.”

Based on an addendum issued with its press release, the SEC brought the most enforcement actions in the investment advisor/investment company, securities offering, delinquent filings, and broker-dealer spaces, with these actions constituting almost 75% of all actions brought in FY 2025. In FY 2024, under Chair Gensler, the SEC brought 583 enforcement actions, representing a 26% decline as compared to FY 2023, yielding around $8.2 billion in penalties and disgorgement. In comparing FY 2024 and FY 2025, notably absent from the FY 2025 results were actions involving off-channel communications, whistleblower rule violations, non-fraud crypto offerings, and cybersecurity disclosure and controls.

The Division of Enforcement, which will be under new leadership by David Woodcock effective May 4, 2026, highlighted several of its FY 2025 enforcement actions and trial victories in the press release. For example, the SEC charged an individual and his companies with allegedly operating a large-scale Ponzi scheme that raised over $770 million from approximately 2,700 investors, obtained a trial victory against an individual for securities fraud by using Twitter to promote stocks to retail investors while secretly selling his own holdings to obtain $2.6 million in illicit profits, and charged a pharmaceutical executive for allegedly making misleading statements regarding clinical trial results for a potential treatment for anemia associated with chronic kidney disease.

The agency also noted the January 2025 launch of the Crypto Task Force and the February 2025 formation of the Cyber and Emerging Technologies Unit, reaffirming its commitment to addressing misconduct relating to AI washing, cybersecurity, and blockchain technology and signaling a shift in its enforcement approach to crypto assets. As described in the press release, in April 2025, the SEC charged the founder and former CEO of an artificial intelligence company for allegedly raising over $42 million through misleading statements about the company’s use of artificial intelligence and charged a New York City-based company and four of its current and former executives in May 2025 for alleged misstatements in crypto-related offerings.

According to the press release, several market participants in FY 2025 received reduced penalties or avoided enforcement actions altogether for self-reporting, cooperating with investigations, and remediating violations of the securities laws. During FY 2025, the SEC also returned approximately $262 million to investors and awarded approximately $60 million to 48 whistleblowers.

Taken together, the SEC’s FY 2025 enforcement results underscore a post-inauguration shift toward pursuing cases centered on traditional “bread and butter” securities law violations, including Ponzi schemes and other offering frauds, market manipulation, insider trading, and breaches of fiduciary duty. Consistent with SEC Chairman Paul Atkins’ stated priority of reallocating resources toward core securities law violations, the SEC’s future enforcement efforts and outcomes will likely continue to align with the agency’s traditional mandate of protecting investors and the integrity of the market, rather than the pursuit of novel liability theories.

[1] On January 17, 2025, the Gensler-led SEC noted that the number of enforcement actions filed in the first quarter of FY 2025 was the highest since 2000.

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