SEC Enforcement FY2025 Results Signal Shift in Priorities in Direct Critique of Prior Administration

On April 7, 2026, the SEC Division of Enforcement published its annual enforcement results for the 2025 fiscal year (October 2024 through September 2025). The Division reported 456 total enforcement actions, the lowest number in at least 20 years, including 303 “stand-alone” actions; 69 “follow-on” administrative proceedings arising from other civil, criminal, or administrative events; and 84 actions against delinquent filers. The SEC also reported approximately $17.9 billion in monetary relief.

These results were published several months later than is typically expected. The following day, the SEC announced that David Woodcock, a law firm partner and former Director of the SEC’s Fort Worth Regional Office from 2011 to 2015, will be appointed Director of Enforcement, effective May 4, 2026. Woodcock is a well-known and widely respected attorney with experience in both government and private practice.

Enforcement Actions Filed in Fiscal Years 2021 to 2025[1]
	FY 2025	FY 2024	FY 2023	FY 2022	FY 2021
Standalone Enforcement Actions	303	431	501	463	434
Follow-On Admin. Proceedings	69	93	162	169	143
Delinquent Filings	84	59	121	129	120
Total Actions	456	583	784	761	697

“Standalone enforcement actions” is a combined count of civil actions and standalone admin proceedings.

The report is notable for its explicit, repeated criticism of the prior Commission’s enforcement approach. It states that an effective enforcement program requires “responsibly stewarding Commission resources” and asserts that “[r]egrettably, such resources have been misapplied in prior years to pursue media headlines and run up numbers[].” The report further characterizes fiscal year 2025 as a “unique period of transition” marked by an “unprecedented rush” to file enforcement actions ahead of the presidential transition and the “aggressive pursuit of novel legal theories.” In a deviation from prior years, the report referenced the number of matters closed without enforcement action — 1,095 matters in total.

In a statement included in the report, SEC Chairman Paul Atkins stated that the Commission “has put a stop to regulation by enforcement and recentered its enforcement program on the Commission’s core mission by prioritizing cases that provide meaningful investor protection and strengthen market integrity.” The report also criticizes the prior Commission’s focus on off-channel communications, “definition of a dealer,” and crypto registration cases, stating that these matters “identified no direct investor harm, produced no investor benefit or protection, and demonstrate what the current Commission views as a misinterpretation of the federal securities laws,” as well as a misallocation of resources and emphasis on case volume. Consistent with this view, the Commission highlights that beginning in February 2025, it dismissed several crypto-related enforcement actions brought by the prior Commission, describing that shift as a “necessary course correction.”

Not surprisingly, the number of actions filed during fiscal year 2025 significantly declined from prior years, a decrease of approximately 130 actions year over year, or approximately 22%.

Total Money Ordered (in millions)
	FY 2025	FY 2024	FY 2023	FY 2022	FY 2021
Penalties	$7,208	$2,102	$1,580	$4,194	$1,456
Disgorgement	$10,760	$6,092	$3,369	$2,245	$2,395
Total	$17,968	$8,194	$4,949	$6,439	$3,852

 

 

 

 

 

Although the SEC reported nearly $18 billion in monetary relief, the accompanying addendum clarifies that a significant portion of that figure ($14.9 billion) arose from a single long-running matter originally filed in 2009.² Excluding that matter, as well as certain disgorgement amounts the Commission “deemed satisfied” by separate non-SEC actions, fiscal year 2025 monetary relief totaled approximately $1.4 billion in disgorgement and $1.3 billion in civil penalties, an approximately 33% reduction year over year.

The Division emphasized that the 2025 enforcement results reflect the Commission’s stated focus on protecting retail investors, holding individual wrongdoers accountable, combating fraud and market abuses, and deploying resources “judiciously,” including in matters involving emerging technologies. The report also notes that notwithstanding this shift, the Commission remains committed to pursuing misconduct involving emerging technologies.

Enforcement Categories
	2025	2024	2023	2022	2021
Broker-Dealer	65	98	140	132	110
Delinquent Filings	84	59	121	129	120
Foreign Corrupt Practices Act	6	2	11	6	5
Insider Trading	32	35	32	43	28
Investment Adviser/Companies	99	135	139	174	159
Issuer Reporting/Audit & Accounting	47	60	107	91	70
Market Manipulation	16	19	24	35	31
Miscellaneous	9	56	23	6	7
Nationally Recognized Statistical Rating Organizations	0	6	4	1	2
Public Finance Abuse	7	14	6	20	12
Securities Offering	90	97	167	113	150
Self-Regulatory Organization /Exchange	0	1	5	1	1
Transfer Agent	1	1	5	9	2
Total	456	583	784	761	697

The report serves as both a statistical summary and a policy statement, signaling the SEC’s enforcement priorities to market participants and framing its approach going forward 

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1 Statistics for fiscal years 2021 to 2024 based on data published in the Division’s report for fiscal year 2024.
2 $14.9 billion of the reported total came from orders entered in SEC v. Stanford International Bank Ltd.
3 The SEC’s report includes each action initiated in only one category, even though many actions may fall under more than one category. Statistics based on original data in the Division’s report for each respective fiscal year.