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Enforcement Policies

FINRA Enforcement Announces its First Round of FINRA Forward Program Enhancements

March 9, 2026 Topic(s): Broker Dealers; Enforcement Policies; Securities Regulation

On March 2, 2026, Bill St. Louis, FINRA’s executive vice president of Enforcement, published a statement outlining changes that FINRA has implemented as part of the broader FINRA Forward initiative to increase transparency, improve efficiency and provide member firms with greater opportunities to be heard. Of particular note, FINRA’s recently implemented pilot program, which is intended to give firms the opportunity to self-report, investigate and remediate compliance issues without simultaneously having to respond to an investigation or examination of the matter.

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SEC Enforcement Director’s First Public Remarks Highlight Process, Fraud, and Compliance Failures

February 13, 2026 Topic(s): Enforcement Policies; SEC Operations

The SEC’s Enforcement Division Director recently delivered her first public remarks and provided helpful insight into the Division’s direction under her leadership. In her Remarks to the Los Angeles County Bar Association, SEC Enforcement Director Judge Margaret Ryan outlined her guiding principles, approach to enforcement process, and substantive priorities. A brief Q&A with insightful commentary from Judge Ryan followed her remarks. In our experience, after a long transition, changes within the Division of Enforcement are taking shape.

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GDC on the SEC: An Insider View of the Agency’s Enforcement Program

January 26, 2026 Topic(s): Enforcement Policies; SEC Operations

A year into the new Administration, SEC Enforcement leadership is now in place, and the Commission and internal structure of the Enforcement Division look very different. Based on our decades of experience leading and defending enforcement matters from coast to coast and across different administrations, here are our thoughts on what’s ahead.

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Chairman Atkins Discusses SEC Enforcement: An Exercise of Government Power “Tempered by Fair Process, Good Judgement, Integrity and Rectitude”

October 31, 2025 Topic(s): Enforcement Policies; SEC Operations

U.S. Securities and Exchange Commission (“SEC” or “Commission”) Chairman Paul S. Atkins outlined some foundational themes for SEC enforcement in a recent keynote address at Fordham Law’s 25th Annual A.A. Sommer, Jr. Lecture on Corporate, Securities, and Financial Law.[1] This was the Chairman’s second important enforcement-related speech in his career. The first one came 18 years ago at the same A.A. Sommer, Jr. Lecture, when then-Commissioner Atkins discussed the Wells process and potential reforms to the SEC’s enforcement program. This time, as Chairman, he used the speech to begin shaping enforcement the way he has long discussed.  

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New SEC Cross-Border Task Force to Combat Fraud

September 22, 2025 Topic(s): Cross-Border; Enforcement Policies

In an early sign of the priorities of the new administration, the SEC recently announced a new Cross-Border Task Force within the Division of Enforcement.  According to its press release, the initiative is designed to sharpen the agency’s focus on foreign-based companies and market participants whose activities may harm U.S. investors, particularly through market manipulation schemes on US exchanges or otherwise.

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SEC Speaks 2025: A New Day at the SEC

May 21, 2025 Topic(s): Crypto / Digital Assets; Enforcement Policies; Financial Reporting and Disclosures; Insider Trading; Offering Frauds; SEC Operations

On May 19 and 20, 2025, U.S. Securities and Exchange Commission (“SEC” or “Commission”) Chairman Paul S. Atkins and other senior SEC officials convened in Washington, D.C. for the annual SEC Speaks conference.  The Commission looked back at the last four years and outlined its strategic priorities going forward under President Trump’s second administration.  The post below focuses on the SEC’s changing approach to enforcement.

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