SEC Announces Enforcement Results for 2025

On April 7, the Securities and Exchange Commission (the SEC) announced enforcement results for its fiscal year that ended September 30, 2025. The release highlights that the SEC 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. Actions led to orders for monetary relief totaling $17.9 billion as well as criminal convictions and civil injunctions. In addition, there were 1,095 matters in which potentially violative conduct was investigated and which were closed, several matters where market participants remediated their practices, or cases that were otherwise not pursued. The release also reiterates the current SEC’s priorities: “Standing up to fraud in its many forms and those market participants engaged in such misconduct; addressing the fraudulent and manipulative conduct of the parties in question through appropriate remediation; and repaying investors’ losses when harmed.” The SEC also released an addendum with additional statistics and a list of enforcement cases organized by program area.

On April 8, the SEC announced the appointment of David Woodcock to serve as Director of the Division of Enforcement, effective May 4, 2026. Mr. Woodcock is currently in private practice, but he previously served as Director of the SEC’s Fort Worth Regional Office from 2011 to 2015. The release announcing his appointment highlights that, during his prior SEC tenure, Mr. Woodcock led investigations in nearly every major area of the SEC’s enforcement program, served as a member of the Enforcement Advisory Committee, and created and served as Chair of the SEC’s cross-office and cross-division Financial Reporting and Audit Task Force, which was designed to enhance the SEC’s detection and prosecution of violations involving accounting and false financial statements.

On March 27, the U.S. Government Accountability Office (GAO) released a report to Congress on recent workforce reductions at the SEC as well as other personnel changes. The Dodd-Frank Wall Street Reform and Consumer Protection Act contains a provision requiring the GAO to report triennially on the quality of SEC’s personnel management. The GAO provided the following overview of the report:

Since January 2025, the [SEC] has implemented significant personnel management changes in response to executive orders and other direction from the administration. Key changes include offering voluntary departure incentives, requiring employees to work in the office full time, and removing references to diversity, equity, and inclusion from SEC policies and procedures. About 18 percent of employees left the SEC during the fiscal year ending September 30, 2025. Most employees who departed took a voluntary departure incentive, and according to SEC, it did not conduct any involuntary terminations in response to executive actions in 2025. SEC also paused its leadership development program in 2025, in part due to uncertainty about the availability and timing of future advancement opportunities.

Concerns raised by SEC staff with whom GAO spoke included the effect of workforce reductions on the loss of experience and subject-matter expertise on the agency and increased workload and its impact on meeting agency goals. The report discusses efforts undertaken by the SEC to manage the effects of the changes, highlighting that the agency held meetings with division and major office heads to identify skill and resource gaps, adjusted the targeted ratio of employees per senior officer, and submitted a staffing plan that identified positions for potential hiring for each division and office.

At the Welcome to the BOOM BELT: A Return to First Principles in Public Markets Event sponsored by the Texas Stock Exchange on April 7, SEC Chairman Paul Atkins delivered remarks that elaborated on the three pillars of his plan to make IPOs great again.

• First: modernizing, rationalizing, and streamlining disclosure reports so that they are meaningful, understandable, and not a repellant to investors — shifting to a framework that focuses on what a reasonable investor would consider important as opposed to what a regulator might find interesting.
• Second: focusing on ensuring that states, and not the SEC, regulate matters of corporate governance.
• Third: allowing public companies to have litigation alternatives while maintaining an avenue for shareholders to continue to bring forth meritorious claims.

Chairman Atkins went on to say that “the most consequential reforms are not those that add to the compliance burden, but those that have the courage to lift it.”

On March 26, Mona DeFrawi, CEO & Founder of Radivision, Inc., submitted to the SEC a petition for rulemaking to harmonize the agency’s pre-IPO communication rules to enable greater participation by retail investors. Radivision is a streaming and social media platform focused on information about private and IPO investment opportunities. In Ms. DeFrawi’s view, “[I]ncorporating retail participation pre- and at the IPO allocation [stage] will encourage a smoother transition from private to public ownership and encourage more companies to execute earlier, smaller IPOs.” To that end, she requests that the SEC take the following actions:

• Amend Securities Act of 1933 (Securities Act) Rule 163B to expand the class of permitted testing the waters communications recipients beyond qualified institutional buyers and institutional accredited investors to include retail accredited investors in connection with IPOs and other registered offerings.
• Amend Securities Act Rule 169 to broaden the safe harbor for factual business communications during registered offerings to include, among other things, applicability to digital and social media communications.
• Issue interpretive guidance confirming that its existing policy judgments permitting retail solicitation in Regulation Crowdfunding, Regulation A+, and Rule 506(c) offerings apply with equal force to IPOs.

It will be interesting to see if the SEC will take up consideration of any of these suggestions.

On March 31, the Public Company Accounting Oversight Board (PCAOB) issued a request for public comment as part of its development of a five-year strategic plan that will “articulate the organization’s goals and objectives in support of its statutory mission to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports.” Seven areas of particular interest on which the PCAOB seeks feedback:

1. What should the PCAOB focus on as its strategic priorities in registration, inspections, and enforcement over the next two to five years to further its statutory mission?
2. What changes should the PCAOB make to its inspections program including, but not limited to, changes in light of its new quality control standard (QC 1000)?
3. What inspection information would be most useful to stakeholders, and how could inspection reporting be enhanced under a quality control-focused inspection program?
4. What standard-setting projects should the PCAOB pursue?
5. How can the PCAOB achieve greater alignment of its auditing standards with international auditing standards?
6. In what ways should the PCAOB consider deploying technology, including AI, to help further its investor-protection mission?
7. How can the PCAOB enhance transparency with its stakeholders?

Comments are requested by May 15, 2026.