Better late than never, they always say. Yesterday, the SEC announced its Enforcement results for Fiscal Year 2025, which ended back on September 30, 2025. In the past, the SEC has reliably published is Enforcement results sometime in November following the end of the fiscal year, but for some reason we did not hear about the results until now, a little over six months after the end of fiscal 2025.

The announcement commences with, not too surprisingly these days, an indictment of past practices:

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 expectations on what constitutes effective enforcement.

Call me old-fashioned, but isn’t it weird to read so many press releases from the SEC that are so critical of itself? In any event, here is what the announcement has to say about fiscal 2025 results:

During fiscal year 2025, the Commission filed 456 enforcement actions, including 303 standalone actions and 69 “follow-on” administrative proceedings seeking to bar or suspend individuals from certain functions in the securities markets based on criminal convictions, civil injunctions, or other orders, and obtaining orders for monetary relief totaling $17.9 billion. These enforcement actions addressing a broad range of misconduct demonstrate the Commission’s prioritization of cases that directly harm investors and the integrity of the U.S. securities markets, including offering frauds, market manipulation, insider trading, issuer disclosure violations, and breaches of fiduciary duty by investment advisers.

The results do not include the 1,095 matters in which potentially violative conduct was investigated and which were closed, the several matters where market participants remediated their practices, or cases that were otherwise not pursued.

FY 2025 was a unique period of transition for the enforcement division never experienced before in modern SEC history. It was characterized by an unprecedented rush to bring a significant number of cases in advance of the presidential inauguration and the aggressive pursuit of novel legal theories under the prior Commission.

This period brought about the current Commission’s resolution of prior cases that were not sufficiently grounded in the federal securities laws. The current Commission deliberately refocused the enforcement program on matters of fraud—cases that inherently require more time and resources to develop and bring, often requiring up to two or more years to manifest results.

Some of the key themes highlighted in the announcement include:

– Protecting retail investors
– Holding individual wrongdoers accountable
– Combatting securities fraud wherever it occurs
– Safeguarding markets from abusive trading
– Deploying resources judiciously as to emerging technologies

The announcement also includes an addendum that provides more detailed statistics highlighting the Division of Enforcement’s fiscal 2025 Enforcement activities.

– Dave Lynn