Looking Back, Looking Ahead: SEC FY 2025 Results and New Enforcement Director Named

The SEC on April 7, 2026, released its enforcement results for fiscal year (FY) 2025, which ended on September 30, 2025. A day later, on April 8, the Commission announced the appointment of David Woodcock to serve as the Director of the Division of Enforcement.

The Commission used the announcement of FY 2025 results to highlight a philosophical shift in how the Commission under President Donald Trump's administration is approaching enforcement. The current leadership is reorienting the program away from what it characterizes as headline-driven, high-volume enforcement activity and toward actions focused on a so-called "back to basics" approach to fraud, investor protection and individual accountability. And the news of Mr. Woodcock's appointment – following an abrupt and surprising departure of his predecessor, Judge Margaret Ryan, on March 16, 2026 – echoed that sentiment.

Announcing Mr. Woodcock's appointment, SEC Chair Paul Atkins said "[t]he Division of Enforcement has undergone a significant course correction, restoring Congressional intent by prioritizing cases that provide meaningful investor protection and strengthen market integrity" and that through Mr. Woodcock's leadership, the agency will "continue to focus on the types of misconduct that inflict the greatest harm to investors."

In announcing his appointment – and return to the agency following service as Regional Director of the Enforcement Division's Fort Worth Regional Office from 2011 to 2015, Mr. Woodcock – a highly regarded and well known securities and governance attorney – noted his "commitment to lead the division with the highest level of professionalism and rigor as we execute the Chairman's vision and ensure the integrity of our financial markets."

Key Enforcement Numbers

During FY 2025, the Commission filed 456 total enforcement actions, including 303 stand-alone actions and 69 follow-on administrative proceedings (APs) seeking to bar or suspend individuals based on criminal convictions, civil injunctions or other orders. The Commission obtained orders for monetary relief totaling $17.9 billion, comprising $10.8 billion in disgorgement of ill-gotten gains and prejudgment interest and $7.2 billion in civil penalties. Compared to recent history, the contrast is striking:

Notably, the SEC also reported that it closed 1,095 matters in which potentially violative conduct was investigated, including several matters where market participants remediated their practices or cases were otherwise not pursued.

The Commission took the additional step of contextualizing those headline figures. After excluding financial remedies the Commission deemed satisfied by satisfaction of separate court orders in parallel proceedings (such as criminal restitution or forfeiture orders) and the judgments against Robert Allen Stanford and other defendants in the Commission's long-running $8 billion Ponzi scheme litigation, the adjusted monetary relief totaled $1.4 billion in disgorgement and prejudgment interest and $1.3 billion in civil penalties. The Commission noted that these "deemed satisfied" amounts have not historically been broken out or excluded from annual statistics. Notably absent from Enforcement's FY 2025 stats were eye-popping penalties for off-channel communications, crypto and other cases the likes of which have fallen out of focus under new leadership.

A Deliberate Change in Enforcement Philosophy

The current Commission (comprising three commissioners rather than a full five) was direct in its criticism of the prior administration's enforcement approach. Keeping with the clear theme of his prior statements, Chair Atkins stated that the Commission has "put a stop to regulation by enforcement" and refocused on cases that provide "meaningful investor protection and strengthen market integrity." Commissioner Mark Uyeda similarly endorsed the "move away from using enforcement as a tool for policymaking" and a "return to the Commission's historical norms."

As noted above, central to this critique is the prior administration's pursuit of so-called "off-channel communications" cases (business-related communications transmitted over unapproved or unmonitored and often personal messaging platforms). Beginning in FY 2022, the Commission filed 95 actions and imposed $2.3 billion in penalties against firms for violations related to failing to maintain and preserve off-channel communications. The current Commission views those cases, along with certain crypto-industry registration and "definition of a dealer" cases, as having identified no direct investor harm and produced no investor benefit. Clearly punctuating the point, the release concludes unequivocally that such actions "demonstrate what the current Commission views as 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."

The release acknowledged that FY 2025 was a "unique period of transition," marked by what is described as an unprecedented rush to file a significant number of cases ahead of the presidential inauguration and an aggressive pursuit of novel legal theories under the prior Commission. Indeed, some of those litigated cases are still hanging on in federal courts around the country despite about-face dismissals in select crypto, dealer-registration and other matters.

The current Commission has deliberately refocused on fraud-based matters, which it notes inherently require more time and resources to develop, often taking two or more years to fully investigate – harkening back to recent agency statements about a current Enforcement prioritization of quality over quantity when it comes to case counts and financial remedies stats.

Protecting Retail Investors

In the release, the Commission reemphasized its commitment to protecting retail investors, who are particularly vulnerable to securities fraud. Enforcement actions in FY 2025 targeted fraudsters who preyed on veterans, seniors and members of religious communities – themes also observed in the program's current FY 2026 reported cases. Notable 2025 actions included charges in connection with several large-scale Ponzi schemes, including one involving approximately 2,700 investors and an alleged $400 million in losses and another involving approximately 300 investors and more than $140 million in alleged losses.

Heightened Focus on Individual Accountability

One of the most notable trends from FY 2025 is the Commission's increased emphasis on charging individuals. Approximately two-thirds of stand-alone actions involved charges against one or more individuals, representing a 27 percent year-over-year increase. A noteworthy almost nine out of every 10 stand-alone actions filed under Acting Chair Uyeda and Chair Atkins involved individual charges. The Commission also obtained orders barring 119 individuals from serving as officers and directors of public companies. The Commission views individual accountability as a more effective deterrent than entity-level penalties alone, and this trend is likely to continue.

Crypto and Emerging Technologies: A Course Correction

The Commission made what it described as a "necessary course correction" in its approach to crypto assets. Beginning in February 2025, the Commission dismissed seven enforcement actions brought by the prior Commission involving crypto assets. In place of what it describes as a prior registration-based enforcement approach, the Commission rebranded Enforcement's existing Crypto Assets and Cyber Unit to the Cyber and Emerging Technologies Unit, envisioned to complement the agency's broader Crypto Task Force and focusing on alleged fraud and misconduct involving blockchain technology, artificial intelligence, account takeovers and cybersecurity. The Commission noted that it continues to pursue crypto-related fraud cases, underscoring that the shift is away from registration-based theories rather than away from enforcement in the digital asset space entirely.

Self-Reporting, Cooperation and Whistleblowers

The release once again highlighted the benefits of self-reporting and cooperation. During FY 2025, the Commission claimed, market participants that self-reported violations, cooperated meaningfully with investigations or remediated securities law violations received favorable treatment, including reduced civil penalties or outright declinations. Notably, the SEC received a record 53,753 tips, complaints and referrals in FY 2025, nearly 19 percent more than in the prior fiscal year, indicating that the whistleblower program remains robust – at least in terms of inbound reports. However, in FY 2025 the agency paid out at historically low levels, awarding a modest $60 million to 48 whistleblowers, compared with awards totaling $255 million paid to 47 whistleblowers in FY 2024.

Litigation Successes

In the release, the Commission also highlighted several litigation victories at trial and on summary judgment, including jury verdicts in cases involving stock manipulation through social media, fraudulent offerings targeting retirees and undisclosed conflicts of interest by an investment adviser. These results were highlighted to demonstrate the Enforcement Division's continued willingness and ability to take cases to trial when necessary, though this sentiment should be considered in balance with the Commission's decision to drop or settle numerous litigated matters filed during the prior administration, as well as the fact that staff attrition and resource strain may make it more challenging for Enforcement to cover the waterfront in an environment, where would-be defendants are willing to take their chances in litigation where they may feel they have a better chance before judge and jury.

Looking Ahead

The FY 2025 enforcement results make clear that the current Commission intends to prioritize the policing of alleged fraud, market manipulation, insider trading and breaches of fiduciary duty while moving away from cases that it views as regulation by enforcement or as lacking a direct nexus to investor harm. And investor harm no doubt will remain in sharp focus through FY 2026, as the U.S. Supreme Court will decide SEC v. Sripetch on whether the SEC has the ability to seek disgorgement as a penalty without showing investors suffered financial harm. The case is slated for oral argument on April 20, 2026.⁴

Market participants should take note of several key themes: the heightened focus on individual accountability means that executives and other individuals face increased personal exposure, the emphasis on cooperation and self-reporting suggests that firms that identify and remediate issues proactively may receive more favorable treatment, and the course correction on crypto enforcement signals a more targeted, fraud-focused approach and one in which prompt remediation of actual concerns may be a useful counterpoint for avoiding or mitigating the impact of an enforcement action.

No doubt the Commission and Enforcement staff in particular continue to undergo transition and face very real challenges posed by considerable staff attrition, strained resources and staff morale, as well as a marked shift in priority and tone. As the newly minted Enforcement Director, Mr. Woodcock will need to find ways to navigate these challenges in order to balance the equally important tasks of promoting and encouraging a staff of more than 1,000 professionals while also holding them accountable to standards of efficiency, accuracy and justice.

As Commission leadership continues to signal a "quality over quantity" and "back to basics" approach, our dear readers may want to seek further lasting change by engaging meaningfully in the revised Wells process and in light of Enforcement Manual changes to help ensure that the cases the Commission elects to bring are at a minimum grounded in admissible evidence, sound legal theories and articulable investor harm. As the Commission's Enforcement program continues to evolve under its current leadership, these priorities will shape (and reshape) the regulatory landscape for the foreseeable future.

The SECond Opinions Blog will continue to monitor this case and related cases and provide updates. If you need additional information on this topic, or any topic related to securities enforcement or investigations, please contact the authors or other members of Holland & Knight's Securities Enforcement Defense Team.

Notes

¹ Excluding "deemed satisfied" amounts, as described above.

² Same.

³ Same.

⁴ "CERTainly Getting Interesting: Supreme Court Again to Address SEC's Power to Obtain Disgorgement," Holland & Knight SECond Opinions Blog (Jan. 14, 2026).