The results are in: The SEC’s FY2025 enforcement results reflect decrease in actions – but a focus on fraud

The announcement comes at a moment of transition for the Commission's enforcement division. In March 2026, the Honorable Margaret “Meg” Ryan departed the Commission after just seven months as Director of the Division of Enforcement. On April 9, 2026, the Commission named a former SEC senior officer David Woodcock as her replacement. The selection of Woodcock – who once helmed the Commission's Fort Worth Regional Office and has extensive experience pursuing fraud-related enforcement – suggests that, even as overall enforcement numbers dip, the SEC is taking seriously its commitment to protect investors and maintain the integrity of U.S. markets.

While the SEC has dramatically curtailed its enforcement efforts, state attorneys general have signaled their interest in pursuing securities fraud cases and have stepped in to charge conduct that the SEC declined to pursue. Earlier this year, the New York Attorney General brought a civil complaint against a former CEO under New York’s Martin Act for insider trading. Unlike federal securities fraud laws, the Martin Act does not require proof of intent to defraud – broadening the scope of potential liability. The case has been removed to federal court and has set up a legal contest over whether state laws can be used to enforce federal insider trading laws. States, including New York and Oregon, have also used blue sky laws to pursue enforcement against cryptocurrency platforms. Given these ongoing risks, companies should continue to stay the course and review their disclosures, policies, and compliance programs with the same rigor used in the past.

SEC FY2025 enforcement by the numbers

Between October 1, 2024, and September 30, 2025, the SEC filed 456 enforcement actions (303 standalone actions, plus 69 debarment actions).  This total represents a 22 percent decrease as compared to FY2024 and an even steeper drop from Biden-era tallies, which peaked at 784 new actions in FY2023.

The SEC also obtained orders for monetary relief totaling $17.9 billion. As the Commission notes, however, this number is somewhat misleading. Adjusted downward to exclude amounts that were “deemed satisfied” by payments in related non-SEC matters, including disgorgement and penalties ordered against parties in the long-running Stanford Ponzi scheme, the total is approximately $2.7 billion – a 33 percent reduction from FY2024.

Although new enforcement is down, FY2025 saw record numbers of whistleblower complaints. The Commission received 53,753 tips, complaints, and referrals – up 19 percent from FY2024. Whistleblower payouts, however, were down from $255 million in FY2024 to $60 million in FY2025.

The SEC framed the decrease in overall enforcement activity as a victory – and seemed to suggest that we should expect even lower numbers in years to come. The totals, the Commission said, reflect an “unprecedented rush to bring a significant number of cases” prior to President Trump's second inauguration in January 2025. The prior administration's practice of “regulation by enforcement” led to “misguided expectations on what constitutes effective enforcement” that the Commission continues to level-set.

Matter highlights

The specific matters that the SEC highlighted for FY2025 add context to the numbers and paint a picture of where enforcement may be headed over the coming years. The SEC focused its enforcement efforts on cases involving demonstrable harm to retail investors. The FY2025 announcement highlighted a number of new cases filed related to Ponzi schemes, misrepresentations to the market, and inadequate disclosures that resulted in investor losses.

The Division of Enforcement has also prioritized accountability for individual bad actors. Nearly 90 percent of standalone enforcement actions filed since January 2025 included charges against at least one individual – a marked increase from prior years. Individual actions included charges for insider trading and other forms of market manipulation – another priority area for the current Commission.

Just as notable as the cases the SEC pursued in FY2025 are the cases it dropped. According to the announcement, in FY2025, the enforcement division “resolv[ed]…prior cases that were not sufficiently grounded in the federal securities laws” and “deliberately refocused on matters of fraud.” Dismissed cases include seven matters related to crypto firm registration. This retreat from crypto-related enforcement is no surprise: SEC Chairman Paul Atkins has long championed the industry and critiqued the “regulation by enforcement” of the last administration.

The SEC also stepped away from enforcement actions related to off-channel communications and other books-and-records violations. This is line with an overall pivot away from enforcement of technical violations, which Chairman Atkins has described as a drain on both corporate and Commission resources. “We must go after cases of genuine harm and bad acts,” Atkins said in an October 2025 speech, “but we must view cases of benign or innocent actions differently.”

What these results mean for SEC-regulated entities

On the whole, the SEC's FY2025 enforcement results suggest a retreat from the “broken windows policing” of the recent past and a refocusing of enforcement efforts on fraud. But just because the SEC has stepped away from enforcement of record-keeping and other technical violations does not mean that SEC-regulated entities can or should neglect their compliance programs. With the appointment of a new and experienced Director in David Woodcock, companies should prepare for a reinvigorated Division of Enforcement, laser-focused on fraud and market manipulation, in the second half of FY2026. Companies may also face increased enforcement risk under state blue sky laws as states step in where the SEC has stepped away. And in the long term, the statutes of limitations for many violations of the federal securities laws mean a new administration with a different approach could choose to pursue enforcement actions where this Administration did not. 

In light of these risks, companies must remain vigilant to ensure that their policies are adequate to prevent, detect, and remediate potential violations of the securities laws – particularly those related to fraud. And with the Commission's focus on harm to retail investors, issuers and financial services providers should review disclosures to ensure they are fulsome and accurate.

The team at Hogan Lovells stands ready to assist companies as they navigate their duties and responsibilities to the investing public.

Authored by Ann Kim, Stephanie Yonekura, and Matthew Sullivan.