News

Key Highlights in a 12-minute video and summary chart

The SEC’s fiscal 2024 Enforcement results are out, and show a considerable drop in the number of filed Enforcement Actions.  In its final year under the leadership of Chair Gary Gensler and Enforcement Director Gurbir Grewal, the SEC brought 583 actions, a 26% decrease from FY 2023, according to the SEC’s November 22, 2024 press release.  We attribute some of that decline to certain programmatic litigation setbacks, the flat budget over the last two years, and fewer securities offering and issuer reporting/audit and accounting cases (a ~43% drop from FY 2023).  In addition, the number of FCPA cases declined from 11 to 2, an 82% drop. The SEC’s 2024 enforcement priorities included crypto, off-channel communications, and the investment adviser Marketing Rule.

In this WMHW alert, presented in chart format (see attached PDF) and video link, we highlight important takeaways from SEC Enforcement in 2024, and how Enforcement might change in a Trump Administration SEC in 2025, especially now that President-elect Trump has named former SEC Commissioner Paul Atkins as his choice for the SEC’s next Chair.  We expect a more traditional enforcement focus on matters involving fraud, including offering frauds, investment adviser issues, retail investors, and tangible investor or market harm.  Our chart summarizes our 2024 SEC Enforcement observations and our corresponding predictions for 2025.

The alert features Barry Rashkover, Paul W. Ryan, Amanda Senske, and Mary Diaz.

Disclaimer:

These materials contain attorney advertising.  Prior results do not guarantee a similar outcome and results depend upon a variety of factors unique to each circumstance.  WMHW provides this information as a service to clients and other friends for educational purposes only.  It should not be construed or relied on as legal advice, or to create a lawyer-client relationship.  Readers should not act upon this information without seeking advice from professional advisers.