April 10, 2026
Who may be interested: Registered Investment Companies; Directors of Registered Investment Companies; Investment Advisers; Hedge Funds
Quick Take: On April 7, 2026, the SEC released its annual summary of enforcement results for fiscal year 2025. The release highlights a shift away from regulation by enforcement and toward cases involving direct investor harm, offering frauds, market manipulation, insider trading, issuer disclosure violations, and breaches of fiduciary duty by investment advisers.
SEC Chairman Paul S. Atkins stated that the SEC has refocused its enforcement program on its core mission of investor protection and market integrity. According to Chairman Atkins, the Division of Enforcement’s efforts during the fiscal year were focused on “protecting investors and pursuing wrongdoers whose misconduct undermines the integrity of our markets.” The SEC will focus on combating fraud, holding wrongdoers accountable, remediating misconduct, and compensating harmed investors.
During the fiscal year ended September 30, 2025, the SEC brought 456 enforcement actions, including 303 standalone enforcement actions and 69 follow-on administrative proceedings seeking bars or suspensions based on criminal convictions, civil injunctions, or other orders.
Enforcement actions addressed fraudulent and Ponzi-like schemes, insider trading, market manipulation, breaches of fiduciary duty, and misconduct by investment advisers and broker-dealers. The SEC also noted that some market participants self-reported violations, cooperated with investigations, and implemented remediation, resulting in reduced civil penalties or, in certain cases, no enforcement recommendations.
The SEC obtained $17.9 billion in monetary remedies, consisting of $10.8 billion in disgorgement and prejudgment interest and $7.2 billion in civil penalties. The release notes that, after excluding certain “deemed satisfied” amounts and judgments associated with the Commission’s long-running Stanford Ponzi scheme litigation, total monetary relief for fiscal year 2025 was $2.7 billion ($1.4 billion in disgorgement and prejudgment interest and $1.3 billion in civil penalties). Approximately $262 million was returned to harmed investors during the fiscal year.
The full SEC press release is available here.
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The opinions expressed are those of the author(s) and do not necessarily reflect the views of the firm or its clients, or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.
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