SEC FY2025 Enforcement Drops 20%, $17.9B Recovery, New Director

April 15, 2026

SEC Announces Enforcement Results for Fiscal Year 2025 and Appoints New Enforcement Director

Brooke Conner, Rachel Copenhaver, Eric Hyla Vedder + Follow Contact LinkedIn Facebook X Send Embed

On April 7, 2026, the Securities and Exchange Commission (the “SEC” or “Commission”) announced its enforcement results for the fiscal year (“FY”) 2025. [1] The SEC’s enforcement results discussed several areas of focus, including a reprioritization of its enforcement efforts, a greater emphasis on individual accountability, a focus on protecting vulnerable retail investors, the redeployment of personnel to focus on cyber, artificial intelligence (“AI”) and international matters, and the SEC’s litigation victories. Additionally, the SEC obtained monetary relief totaling $17.9 billion. Of the $17.9 billion, $14.9 billion resulted from a single action commenced in 2009 regarding an alleged $8 billion Ponzi Scheme for which final judgment was entered in January 2025. The remaining $3 billion resulted from disgorgement ($1.4 billion), civil penalties ($1.3 billion), and certain other disgorgement amounts ($0.3 billion) the Commission deemed were satisfied by penalties in non-SEC actions.

The next day, on April 8, 2026, the Commission announced attorney David Woodcock’s appointment as the next Director of the Division of Enforcement, effective May 4, 2026. [2] Mr. Woodcock will succeed former Enforcement Division Director Judge Margaret A. Ryan, who resigned from her position effective March 16, 2026. Current Acting Enforcement Director Sam Waldon will continue in his role until May 4. Mr. Woodcock previously served as the Director of the Commission’s Fort Worth Regional Office from 2011 to 2015. Mr. Woodcock stated that he was committed to “lead[ing] the division with the highest level of professionalism and rigor as we execute [SEC Chairman Paul S. Atkins’] vision and ensure the integrity of our financial markets.” [3]

Composition of Actions

During FY 2025, the SEC filed 456 enforcement actions, including 303 standalone actions and 69 “follow-on” actions. In each category, the SEC’s actions declined by approximately 20-30% compared to FY 2024, in which the SEC pursued 583 actions total, including 431 standalone actions and 93 “follow-on” actions.

Reprioritization

In announcing its enforcement results, the SEC stated that, in FY 2025, it resolved prior cases the current Commission does not consider to be sufficiently grounded in federal securities laws. The Commission further stated that its previous actions seeking penalties for books-and-records violations (in particular its off-channel communications sweep), crypto firm registration-related cases, and “definition of a dealer cases” identified “no direct investor harm,” “produced no investor benefit or protection” and demonstrated 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.” [4]

Going forward, the current Commission stated that it is “deliberately refocused” on matters concerning fraud, noting that such cases inherently require additional time and Commission resources to pursue. [5] Accordingly, the SEC expects that future enforcement priorities and results will be linked to the Commission’s and Enforcement Division’s “core mandate” of standing up to fraud in many forms, ensuring appropriate remediation, and repaying investor losses when harmed. [6]

SEC Chairman Paul S. Atkins claimed the Commission “put a stop to regulation by enforcement” and would instead “prioritiz[e] cases that provide meaningful investor protection and strengthen market integrity” including “fraud, market manipulation, and abuses of trust[.]” [7] Fellow SEC Commissioner Mark T. Uyeda echoed this sentiment, noting that he “fully support[s] the move away from using enforcement as a tool for policymaking” and welcomed what he described as “the return to the Commission’s historical norms.” [8]

Individual Accountability

Chairman Atkins emphasized that the SEC would prioritize pursuit of individual accountability. In FY 2025, approximately two-thirds of the Commission’s standalone actions included charges against one or more individuals, which the SEC noted was a 27 percent year-over-year increase compared to FY 2024. Moreover, the SEC “obtained orders barring 119 individuals from serving as officers and directors of public companies.” [9] The SEC noted that individual accountability was essential for both specific and general deterrence in order to benefit the investing public.

Focus on Vulnerable Retail Investors and Market Abuse

The SEC highlighted five actions it brought in FY 2025 concerning alleged fraudsters targeting what it described as particularly vulnerable investors, such as veterans, seniors, and members of a religious community, including two Ponzi schemes, one case premised on affirmative false misrepresentations and the misappropriation of investor funds, and two cases based on failures to disclose material information regarding the securities at issue. The SEC noted that the Enforcement Division devoted significant resources to these types of cases in FY 2025.

The Commission also flagged a number of actions in FY 2025 aimed at a wide range of abusive trading practices, including “spoofing” and insider trading.

New Initiatives

The Commission highlighted its commitment to combatting securities fraud “wherever it occurs” and deploying additional resources to areas of emerging technology. [10] To that end, the SEC launched the Cyber and Emerging Technologies Unit in February 2025 to focus on misconduct related to blockchain technologies, AI, cybersecurity, and other areas.

Through the new Cyber and Emerging Technologies Unit, the Commission brought three enforcement actions concerning misstatements regarding the right to receive crypto tokens, a foreign exchange fraud scheme involving crypto assets, and misleading statements regarding the use of AI in FY 2025.

In September 2025, the Commission created a Cross-Border Task Force to pursue enforcement actions involving foreign-based companies and gatekeepers who engage in market manipulation. The Commission stated the task force demonstrates its commitment to pursuing transnational fraud that harms American investors, as reflected in several enforcement actions from FY 2025.

Litigation Highlights

The SEC’s FY 2025 results also highlighted five of its wins in court, including three trial victories and two summary judgment rulings establishing liability over the charged entities and individuals. Consistent with the SEC’s refocused priorities, the cases each concerned the alleged use of fraud to solicit investors into purchasing a security or to manipulate a market to reap profits at the expense of investors.

1. SEC Announces Enforcement Results for Fiscal Year 2025, SECURITIES AND EXCHANGE COMMISSION (Apr. 7, 2026), https://www.sec.gov/newsroom/press-releases/2026-34.

2. SEC Appoints David Woodcock as Director of the Division of Enforcement, SECURITIES AND EXCHANGE COMMISSION (Apr. 8, 2026), https://www.sec.gov/newsroom/press-releases/2026-35-sec-appoints-david-woodcock-director-division-enforcement.

3. Id.

4. SEC Announces Enforcement Results for Fiscal Year 2025, SECURITIES AND EXCHANGE COMMISSION (Apr. 7, 2026), https://www.sec.gov/newsroom/press-releases/2026-34.

5. Id.

6. Id.

7. Id.

8. Id.

9. Id.

10. Id.

Download PDF

[View source.]

Send Print Report

Related Posts

• SEC Approves Intraday Trading and Settlement for Tokenized Money Market Fund
• SEC Staff Issues Additional Names Rule FAQs
• SEC’s Division of Enforcement Announces Updates to Enforcement Manual

Latest Posts

• SEC Announces Enforcement Results for Fiscal Year 2025 and Appoints New Enforcement Director
• New York District Court Holds that Pre- and Post-Shift Screenings Are Not Compensable Under New York Law See more »

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
Attorney Advertising.

©
Vedder

Written by:

Vedder Contact + Follow Brooke Conner + Follow Rachel Copenhaver + Follow Eric Hyla + Follow more less

PUBLISH YOUR CONTENT ON JD SUPRA

• ✔ Increased readership
• ✔ Actionable analytics
• ✔ Ongoing writing guidance Join more than 70,000 authors publishing their insights on JD Supra

Start Publishing »

Published In:

Artificial Intelligence + Follow Cross-Border Transactions + Follow Cryptoassets + Follow Cybersecurity + Follow Digital Assets + Follow Disgorgement + Follow Enforcement Actions + Follow Enforcement Priorities + Follow Financial Markets + Follow Fraud + Follow Individual Accountability + Follow Investor Protection + Follow Market Manipulation + Follow Ponzi Scheme + Follow Regulatory Oversight + Follow Retail Investors + Follow Securities and Exchange Commission (SEC) + Follow Securities Fraud + Follow Securities Litigation + Follow Securities Regulation + Follow General Business + Follow Finance & Banking + Follow Science, Computers & Technology + Follow Securities + Follow more less

Vedder on:

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Sign Up Log in ** By using the service, you signify your acceptance of JD Supra's Privacy Policy.* - hide - hide