Category: SEC enforcement
SEC Announces FY2025 Enforcement Results, Emphasizing Focus on Fraud
On April 7, 2026, the US Securities and Exchange Commission (SEC) announced its enforcement results for fiscal year 2025, which ran from October 2024 to September 2025. In FY2025, the SEC filed 456 enforcement actions, including 303 “standalone” actions, representing a decrease of 22% and 30%, respectively, from FY2024. In […]
Featured in Law360: 3 Cases Highlight SEC Distinction Between Exec, Co. Liability
Law360 recently published an article authored by Cooley attorneys Tejal Shah and Bingxin Wu examining three recent Securities and Exchange Commission (SEC) enforcement actions involving public companies that provide insight on the circumstances in which the SEC holds companies versus executives accountable for disclosure violations. As the article explains, the […]
Updated SEC Enforcement Manual Emphasizes Engagement and Transparency
On February 24, 2026, the US Securities and Exchange Commission (SEC) announced major updates to its Enforcement Manual (Manual), a guidance document the SEC staff uses when conducting investigations of potential securities law violations. This is the first time the SEC has updated the Manual since 2017, but the announcement […]
SEC in the Courts: SCOTUS to Review Disgorgement Powers (Again), District Court Upholds Follow-On Administrative Proceedings
2026 is off to a rousing start for the US Securities and Exchange Commission (SEC), with two notable developments related to the agency’s civil enforcement authority. On January 8, the SEC won a constitutional challenge to its ability to seek industry bans through a follow-on administrative proceeding.[1] This is the […]
Featured in Law360: 2025’s Defining AI Securities Litigation
Law360 recently published an article authored by Cooley securities litigation attorneys analyzing three defining cases from 2025 that will shape how courts assess artificial intelligence (AI)-related disclosures moving forward. As the article explains, the “stakes are rising,” given that “AI-related securities filings doubled from seven in 2023 to 15 in […]
SEC Public Companies Enforcement: FY 2025 Review and What to Expect in 2026
When Paul Atkins became the new chairman of the Securities and Exchange Commission (SEC) in April 2025, the market expected enforcement actions against public companies to decrease. Chairman Atkins has criticized the prior SEC administration’s pursuit of large corporate fines, believing that they unfairly penalized shareholders. He also criticized the […]
SEC’s ‘Project Crypto’ – Chairman Atkins Outlines Regulatory Vision
On November 12, 2025, at the Federal Reserve Bank of Philadelphia, Securities and Exchange Commission (SEC) Chairman Paul Atkins delivered a keynote address unveiling the next phase of “Project Crypto,” the SEC’s initiative to provide clarity and consistency in applying US securities laws to digital assets. Atkins emphasized the SEC’s […]
SEC Changes Course, Concludes Mandatory Arbitration Provisions Do Not Conflict With Federal Securities Laws
The US Securities and Exchange Commission (SEC) recently changed its longstanding position disfavoring the inclusion of certain mandatory arbitration provisions in corporate certificates of incorporation or bylaws. As Chair Paul Atkins explained, the SEC’s September 17, 2025, policy statement “provides the Commission’s views on whether mandatory arbitration provisions are inconsistent […]
SEC Intensifies Oversight of Foreign Companies that Participate in U.S. Capital Markets
According to NERA, a leading consulting and expert firm, the share of foreign-based companies listed on U.S. stock exchanges has risen steadily in the last decade, from 17.4% in 2016 to 26.9% in 2025. As noted in our September 18 blog post, the U.S. Securities and Exchange Commission (SEC) recently […]
SEC Creates Cross-Border Task Force to Combat Fraud
On September 5, 2025, the U.S. Securities and Exchange Commission (SEC) announced the formation of a Cross-Border Task Force that will “strengthen and enhance the Division of Enforcement’s efforts to identify and combat cross-border fraud harming U.S. investors.” According to the SEC, the task force will “focus initially on investigating […]