Securities Enforcement Roundup – April 2026

In this issue of our monthly Securities Enforcement Roundup, we highlight top securities enforcement developments from April 2026.

In April 2026:

• The US Securities and Exchange Commission (SEC or Commission) announced its enforcement results for Fiscal Year (FY) 2025, which reflect a continued decline in enforcement actions filed by the Commission
• The SEC appointed David Woodcock as its new Director of Enforcement, and launched the new podcast series Material Matters hosted by Chairman Paul Atkins
• The SEC continued to focus on addressing gatekeepers, financial fraud, and individual accountability, filing settled orders against a Certified Public Accountant (CPA) and unregistered investment advisers
• The Financial Industry Regulatory Authority (FINRA) fined two broker-dealers for failure to adequately supervise registered representatives engaged in alleged fraud

SEC ANNOUNCES ENFORCEMENT RESULTS FOR FY 2025

On April 7, the SEC announced its enforcement results for the fiscal year that ended on September 30, 2025, months after the typical November or December release date. The results reflect the Commission’s prioritization of actions involving alleged fraud and investor harm and continued shift away from volume-focused case generation. [1]

The Commission reported filing 456 enforcement actions in FY 2025, a significant decline from the 583 actions brought in FY 2024 (which was already a 28% decline from FY 2023). According to the release, this reduction was driven by a “deliberat[e] refocu[s]” away from cases that do not meaningfully advance investor protection or market integrity, including actions based primarily on technical or strict-liability violations.

Specifically, the SEC cited cases involving failures to preserve off-channel communications and registration-related cases against crypto firms as emblematic of the previous administration’s “bias for volume cases,” noting that these cases involved “no direct investor harm,” “produced no investor benefit,” and reflected a “misinterpretation of the federal securities laws” and “misallocation of Commission resources.”

The SEC reiterated its commitment to redressing alleged fraud, holding individuals accountable for investor harm, and protecting the vulnerable. Consistent with this approach, the SEC noted that in FY 2025 it “prioritized charging individuals.”

Of the standalone actions filed during FY 2025, “approximately two-thirds involved charges against one or more individual bad actors,” reflecting a 27% increase over FY 2024. The SEC also underscored its continued objective to return funds to harmed investors and combat fraud wherever it occurs, citing in particular its Cross-Border Task Force (on which we previously wrote) dedicated to addressing the threat that fraudsters located abroad pose to US investors.

All told, the SEC’s FY 2025 enforcement results reflect an ongoing recalibration of the Commission’s enforcement priorities to address cases with clear investor impact and reinforce deterrence through targeted individual accountability.

SEC APPOINTS NEW DIRECTOR OF ENFORCEMENT, AND LAUNCHES PODCAST

On April 8, the SEC announced the appointment of David Woodcock as Director of the Division of Enforcement. [2] Mr. Woodcock joins the SEC from Gibson, Dunn & Crutcher LLP where he served as a partner and chair of the firm’s securities enforcement practice group. Prior to entering private practice, Mr. Woodcock served in senior roles at the Commission, including as Director of the Fort Worth Regional Office and as Chair of the SEC’s Financial Reporting and Audit Task Force.

He also previously served as in-house corporate counsel at Exxon Mobil. His appointment reinforces continuity within the Enforcement Division and is unlikely to result in a significant substantive shift in enforcement practices.

On April 16, the SEC introduced Material Matters, a podcast hosted by Chairman Atkins that is intended to provide insight into the Commission’s policy direction. [3] The inaugural episode features a discussion between Chairman Atkins and Commissioners Mark Uyeda and Hester Peirce on the agency’s regulatory philosophy.

During the episode, Chairman Atkins described Commissioner Uyeda as having “inherited an agency that had really diverted” from its “core mandate.” Commissioner Uyeda similarly noted that the “last four years were a complete outlier to anything” he had seen in “over three decades.”

Commissioner Peirce emphasized the importance of interagency coordination, noting with respect to the Commodity Futures Trading Commission that “we want to make sure that we’re not spending resources to address the same problem.” The episode underscored themes and priorities that the SEC has recently expressed, including a renewed focus on market integrity and aligning regulatory efforts, while also distinguishing current priorities from those of the prior administration.

SEC CONTINUES FOCUS ON GATEKEEPERS, FRAUD, INDIVIDUAL ACCOUNTABILITY

As discussed in our Current Developments in SEC Enforcement for Public Companies: 2025-2026 report and March 2026 Securities Enforcement Roundup, the SEC remains focused on protecting investors through enforcement actions involving gatekeepers and financial fraud.

On April 8, the SEC settled charges against a CPA stemming from his firm’s failure to appropriately audit what was then one of the world’s largest crypto trading platforms, FTX. [4] The SEC found that the firm’s audits were not conducted in accordance with applicable accounting standards because the CPA lacked sufficient understanding of FTX and the crypto asset markets and, in particular, did not sufficiently understand FTX’s relationship with Alameda Research LLC, the trading firm controlled by FTX’s founder and owner Sam Bankman-Fried.

The SEC alleged that the CPA had failed to grasp the “pivotal role” Alameda played in FTX’s business despite the fact that the FTX-Alameda relationship was “at the heart of the misappropriation of billions of dollars of FTX customer assets that led to the collapse of FTX in November 2022.”

According to the SEC, the CPA and his team never evaluated Alameda’s ability to “borrow virtually unlimited amounts from FTX” and failed to consider how such borrowing might affect the accuracy of FTX’s financial statements. The SEC found that the CPA failed to comply with applicable accounting standards and engaged in negligent professional conduct and, as a result, barred him from appearing before the SEC for two years.

Also on April 8, the SEC settled charges against three unregistered investment advisers and their founder concerning offers and sales of interests in dozens of unregistered investment companies. [5] The advisory entities that the founder operated managed venture capital funds. The SEC alleged that the founder assured investors that investments in the funds were “low risk, high return” by touting investments by institutional investors in the same funds—yet such investments had not actually occurred.

The SEC further alleged that the respondents overstated the funds’ investment performance, omitted poor performance from company statements, failed to disclose conflicts of interest, and failed to file registration statements for their securities offerings.

The SEC found that the respondents violated Section 10(b) of the Exchange Act, Section 17(a)(2) of the Securities Act of 1933, and Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (Advisers Act), ordered the respondents to pay more than $1.7 million in disgorgement, censured them, and separately assessed a $600,000 fine against the founder and imposed an associational bar under the Advisers Act. [6]

These actions illustrate the Commission’s continued focus on holding gatekeepers and perpetrators of financial fraud accountable. We expect this trend to continue in future enforcement proceedings.

FINRA FINES FIRMS FOR FAILURE TO SUPERVISE REGISTERED REPRESENTATIVES

Recently resolved enforcement actions reflect FINRA’s continued focus on alleged fraud and redressing direct harm to investors.

In April, FINRA issued two letters of acceptance, waiver, and consent (AWC) in which it alleged that firms had failed to supervise their registered representatives and maintain and enforce an adequate supervisory system.

In one instance, FINRA alleged that a registered representative recommended to senior customers, and customers with moderate risk tolerances and no prior experience with leverage, a complex investment strategy that involved purchasing on margin concentrated positions in high-yield securities. FINRA further alleged that the firm failed to reasonably respond to numerous red flags concerning the suitability of the strategy.

In a second AWC, FINRA alleged that a registered representative sent numerous emails to retail customers about private placements that contained misleading, exaggerated, or promissory statements, including false claims that the representative was an investment banker.

According to FINRA, the firm’s email review system flagged only a portion of those emails, and the firm took no action to address the representative’s conduct until prompted by a regulatory request. FINRA found that both firms violated FINRA Rules 3110(a) and 2010, imposing monetary fines.

These resolutions serve as a reminder that firms should carefully review supervisory alerts and consider whether their supervisory systems are adequately tailored to their business.