Sky Blog
Central to an effective enforcement program is determining which cases to bring and responsibly stewarding Commission resources. Regrettably, such resources have been misapplied in prior years to pursue media headlines and run up numbers, and in turn, led to misguided …
Fiscal year 2025 was a year of extremes in terms of the number of enforcement actions brought by the Securities and Exchange Commission (SEC). During the first quarter of fiscal year 2025 (October through December 2024), the SEC reported a …
The New York State Attorney General filed civil actions against a former executive for insider trading and against his company for approving the trading plan that the executive used. These actions highlight the risk of state regulators filing claims that …
Under the leadership of Chairman Paul Atkins with a Republican majority on the commission, the Securities and Exchange Commission (SEC) is expected to continue on its trajectory toward regulatory reform that marks a pivot from the prior administration.
Regulators, investors, and academics generally agree on the main goal of strong SEC oversight: to improve financial reporting, which helps markets allocate capital and promotes market efficiency. But this goal prompts a question that matters for corporate governance and long-run …
This month, we examine the following most important SEC enforcement developments:
The Securities and Exchange Commission today [August 21] announced that Judge Margaret “Meg” Ryan has been named Director of the Division of Enforcement, effective Sept. 2, 2025. Acting Director of Enforcement Sam Waldon will return to his previous role as …
In a new essay, I compare a judicial revolution that is happening with one that is not. Both the change and the status quo are being managed by the current Supreme Court. , When it comes to administrative law, the …
In an earlier post, I discussed my paper arguing that significant changes to the corporate-disclosure regime should trigger review of aspects of the securities-fraud regime. This is because the disclosure regime and the securities-fraud regime go hand-in-hand. So if …
Since July 2023, the Commission has brought three cases against special purpose acquisition companies (SPACs) and/or SPAC sponsors, charging them with fraud because they made false and misleading statements regarding the details of their communications with potential target companies. I …
The proposed Department of Government Efficiency (“DOGE”) in incoming President Donald J. Trump’s administration promises an ambitious agenda of “regulatory rescission, administrative reductions and cost savings” with the goal of “mass head-count reductions across the federal bureaucracy” by July 4, …
The Securities and Exchange Commission announced on November 22 that it filed 583 total enforcement actions in fiscal year 2024 while obtaining orders for $8.2 billion in financial remedies, the highest amount in SEC history.
The 583 enforcement actions represent
I’d like to take the opportunity today to reflect on some of the goals and intentions that then-Director Gurbir Grewal and I, as his deputy, discussed when we assumed leadership of this remarkable Division three-plus years ago, and what I …
On Wednesday, November 6, 2024, major media outlets announced Donald J. Trump as the winner of the 2024 U.S. presidential election. This alert discusses the potential impact of Mr. Trump’s election on the U.S. Securities and Exchange Commission (the “SEC”) …
Last week’s election results signal a definitive end to the enforcement-only philosophy that for the last four years has characterized the SEC’s posture towards the crypto industry. It’s not realistic to think Congress and regulators will now simply adopt a …
Good afternoon. Thank you to Bruce Carton for the invitation to speak today and for the kind introduction. I appreciate the opportunity to be able to talk to you about the work of the SEC’s Division of Enforcement.
As is …
Each month, we publish a roundup of the most important SEC enforcement developments. This month included the SEC’s fiscal year end and a large number of enforcement actions of note, and we examine:
The Securities and Exchange Commission plays a crucial role as the watchdog of Wall Street by detecting financial misconduct and enforcing securities laws, but much of its investigative process has remained opaque to researchers and the public. In a new …
The U.S. Securities and Exchange Commission (“SEC”) has disbanded its Climate and ESG Task Force in the Division of Enforcement. The Task Force was established in March 2021 with the purpose of identifying ESG-related misconduct, including material gaps or misstatements …
With the Labor Day holiday now behind us, it is a good time to review the SEC’s active enforcement docket and to look ahead to likely areas of continuing enforcement attention as we head into the fall. The record over …