SEC Announces Fiscal Year 2026 Enforcement Results, Emphasizing Individual Accountability and Division Modernization

Key Points

• On November 10, 2026, the SEC reported that it filed 348 enforcement actions in fiscal year 2026, including 235 standalone actions and 113 follow-on administrative proceedings, and obtained orders for $1.095 billion in monetary relief.
• Standalone SEC enforcement actions fell roughly 22% between fiscal year 2025 and fiscal year 2026, from 303 to 235, while follow-on administrative proceedings rose from 69 to 113.
• Charges against at least one individual, including founders and CEOs, senior executives, and gatekeepers such as accountants and auditors, appeared in two-thirds of the standalone enforcement actions the SEC filed in fiscal year 2026.
• As part of its modernization efforts, the SEC’s Division of Enforcement formed a Retail Fraud Working Group and a Financial Reporting and Accounting Unit, among other organizational changes.
• The SEC rescinded Rule 202.5(e), under which the Commission had declined to settle enforcement actions imposing a sanction unless the defendant or respondent agreed not to publicly deny the allegations.

On November 10, the Securities and Exchange Commission (SEC or Commission) released its enforcement results for the fiscal year ended September 30. The SEC’s Division of Enforcement (the Division) described a year focused on its core responsibilities of protecting investors, holding wrongdoers accountable, and safeguarding the integrity of the U.S. capital markets, while continuing to modernize its organization, processes, and technology. Here are the big themes.

The Numbers

In fiscal year 2026, the Commission filed 348 enforcement actions, including 235 standalone actions and 113 “follow-on” administrative proceedings that sought to bar or suspend individuals from certain securities market activities. It also instituted 13 trading suspensions in response to suspected manipulation involving the securities of Asia-based issuers.

The Commission obtained orders for monetary relief totaling $1.095 billion, composed of $752 million in disgorgement and prejudgment interest and $343 million in civil penalties. A court deemed $235 million of the disgorgement satisfied in a separate non-SEC action. The SEC also returned approximately $731 million to more than 250,000 harmed investors.

Year-Over-Year Comparison

Compared with fiscal year 2025, standalone actions fell roughly 22% (from 303 to 235), while follow-on proceedings rose from 69 to 113. The $17.9 billion in monetary relief the SEC reported for fiscal year 2025 included Ponzi scheme judgments and amounts deemed satisfied in other proceedings; excluding those, the SEC reported about $2.7 billion ($1.4 billion in disgorgement and prejudgment interest and $1.3 billion in civil penalties), versus about $860 million this year on the same basis. Meanwhile, amounts returned to harmed investors rose from approximately $262 million to approximately $731 million, and whistleblower awards rose from approximately $60 million to more than $158 million.

Individual Accountability

Holding individuals accountable remains one of the Commission’s most effective deterrents. Two-thirds of the standalone enforcement actions filed this year included charges against at least one individual, including founders and CEOs, senior executives, and gatekeepers such as accountants, auditors, and investment adviser personnel. SEC Chairman Paul S. Atkins noted that “[e]nforcement actions and financial remedies are important measures of activity, but they are not the only or most telling measures,” emphasizing that the agency’s responsibility is to apply the law fairly and consistently.

Enforcement Priorities

The Division said its actions focused on serious and consequential violations of the federal securities laws, including fraud, market manipulation, insider trading, gatekeeper failures, and violations that compromise the integrity of disclosures and financial reporting. Several priority areas stood out:

• Cross-border fraud. Building on the September 2025 launch of the Cross-Border Task Force, the Division took action to disrupt foreign bad actors targeting U.S. markets and investors.
• Pre-IPO secondary market. The Division intensified its investor-protection efforts in this area. As investors obtain greater access to private markets, the risk of harm from fraudsters and other bad actors grows as well.
• Investor-protection guardrails. The Commission brought actions involving the Custody Rule, Regulation Best Interest, privacy and identity-protection breaches, Suspicious Activity Report and Bank Secrecy Act obligations, and blue sheet compliance.
• Market integrity. Consistent with its “return to basics,” the Division continued to pursue market manipulation and insider trading, including spoofing, deceptive trading, and misuse of material nonpublic information.
• Investment advisers and private funds. The Division remained focused on misappropriated client assets, inadequate safeguarding of assets, misleading or inadequate disclosures, undisclosed fees and expenses, fraudulent valuations and mismarking, and undisclosed conflicts of interest.

Modernizing the Division

The Division worked to increase its investigative and litigation capacity, address evolving market risks, and deliver more timely outcomes. Key organizational changes included:

• New specialized groups. The Division formed a Retail Fraud Working Group to identify and address schemes that pose risks to everyday investors, and a Financial Reporting and Accounting Unit that combines attorneys and accountants with deep expertise in accounting standards, issuer disclosures, internal accounting controls, and auditor responsibilities.
• Advanced analytics. A new Office of Super Intelligence and Analytics brings advanced analytical capability into investigative workflows, including anomaly detection, accelerated document and transcript review, and improved blockchain and financial-flow analysis.
• Litigation. The Division reorganized its Trial Unit to enhance consistency across its litigation docket and expand litigation capacity.
• Leadership and talent. The Division launched a formal leadership training program for new and experienced supervisors, hired attorneys, accountants, technologists, and data specialists, and instituted bimonthly meetings between senior officers and senior leadership to review investigation timelines, milestones, and staffing levels.

Process, Policy, and Coordination

• Updated Enforcement Manual. The Division made significant updates to the Manual for the first time since 2017. The updates standardize the Wells process, allow simultaneous Commission consideration of settlement recommendations and related waiver requests, and explain the framework for evaluating cooperation, including its impact on civil penalties. The Division will review the Manual annually going forward.
• Rescission of Rule 202.5(e). The Commission rescinded its policy of not settling enforcement actions unless the defendant or respondent agreed not to publicly deny the allegations. The SEC said the change aligns it with the overwhelming majority of federal agencies and gives it more flexibility in settling actions.
• Cooperation and remediation. The Commission continued to emphasize that prompt self-reporting, swift and thorough remediation, and early, proactive engagement with staff can accelerate investigations and influence charging and penalty decisions.
• Interagency coordination. The Commission entered into memoranda of understanding with the Commodity Futures Trading Commission and the Food and Drug Administration, continued close coordination with the Public Company Accounting Oversight Board, and worked with criminal authorities and overseas regulators in parallel and multijurisdictional matters.

Whistleblower Program

The SEC called its whistleblower program an integral part of the Division’s work to detect and prosecute wrongdoing. Since the program’s inception, high-quality tips have led to more than $11 billion in financial remedies ordered by the Commission. In fiscal year 2026, the SEC received approximately 26,000 whistleblower tips and awarded more than $158 million to 65 individual whistleblowers, the highest number of individual whistleblowers since fiscal year 2023.

Takeaways

The SEC’s fiscal year 2026 results describe a more focused enforcement program that prioritizes consequential misconduct, individual accountability, and meaningful outcomes for investors, while the Division invests in the people, technology, and processes it expects to carry the program forward.