I blogged a few weeks ago about how the Enforcement Division is getting “back to basics” under SEC Chair Paul Atkins (and new Enforcement Division Director, Military Judge Meg Ryan, who was sworn in shortly before the government shutdown). A new report from Cornerstone Research and the NYU Pollack Center for Law & Business puts a finer point on the trend line. Here’s an excerpt from Cornerstone’s press release:

The U.S. Securities and Exchange Commission (SEC) brought 30% fewer enforcement actions against public companies and subsidiaries in FY 2025 than in FY 2024—a decline that coincided with the change in SEC administration.

While a decline aligns with previous years in which there was an SEC administration change, FY 2025 stood out for its composition: outgoing Chair Gary Gensler oversaw 52 actions (93%), while only four were initiated under the new SEC administration—the highest and lowest respective totals for outgoing and incoming chairs during a transition year since at least FY 2013.

Here are a few other takeaways:

– Monetary settlements are 45% lower than FY 2024: Total monetary settlements of $808 million in FY 2025 are the lowest since FY 2012 and the second lowest in SEED. This is also less than half of the FY 2016-FY 2024 average total monetary settlement of $1.9 billion.

– Chair Atkins to Focus on Issuer Reporting and Disclosure: Three of the four actions initiated against public companies and subsidiaries after Chair Gensler’s departure involved Issuer Reporting and Disclosure allegations. This is expected to continue into FY 2026. In his May 2025 remarks, Chair Atkins signaled his administration would “return” to the “core mission that Congress set” for the SEC—prioritizing “protecting investors; furthering capital formation; and safeguarding fair, orderly, and efficient markets.”

– Final Off-Channel Communications Sweep Under Chair Gensler: The SEC initiated nine actions in January 2025 as part of Chair Gensler’s off-channel communications sweep—an area that Chair Atkins indicated interest in addressing in remarks made in October 2025.

– Cooperation and Admissions of Guilt Continued Under Chair Gensler: The SEC noted cooperation by 73% of public company and subsidiary defendants that settled in FY 2025, higher than the FY 2016–FY 2024 average of 65%—reflecting the SEC’s continued emphasis on cooperation under Chair Gensler.

– Record-Low Disgorgement and Prejudgment Interest: The total amount of disgorgement and prejudgment interest ($108 million) was the lowest in any fiscal year in SEED — more than $300 million below the next-lowest total in FY 2012.

– Civil Penalties Continued in Administrative Proceedings: FY 2025 civil penalties for administrative proceedings accounted for the highest percentage of the total monetary settlement for any fiscal year in SEED.

– Liz Dunshee