SEC reports 348 FY2026 enforcement actions and $1.095bn in monetary relief

The Securities and Exchange Commission published its enforcement results for the fiscal year ended 30 Sep on 10 Nov (press release 2026-113). The Commission filed 348 enforcement actions, comprising 235 standalone actions and 113 follow-on administrative proceedings seeking to bar or suspend individuals. Two-thirds of the standalone actions included charges against at least one individual.

Monetary relief ordered totalled $1.095 billion, made up of $752 million in disgorgement and prejudgment interest and $343 million in civil penalties. Of the disgorgement, $235 million was “deemed satisfied by a court in a separate non-SEC action”. The SEC “returned approximately $731 million to more than 250,000 harmed investors”.

SEC Chairman Paul S. Atkins said on 10 Nov: “Enforcement actions and financial remedies are important measures of activity, but they are not the only or most telling measures. Our responsibility is to apply the law fairly and consistently and ensure that our enforcement efforts advance the Commission’s mission.” In remarks in New York the same day, David Woodcock, director of the Division of Enforcement, said “activity and effectiveness are not the same”. He added: “Case counts declined this past year. Some of that is attributable to the lengthy government shutdown, some of it to a transition in personnel, priorities, and the allocation of investigative resources.” The results release itself does not give a year-earlier comparison.

Market integrity and market infrastructure

The release groups a set of actions under “Strengthening Market Integrity”, covering spoofing, deceptive trading and insider trading. In separate actions, the Commission charged individuals “for allegedly orchestrating fraudulent “spoofing” schemes to manipulate stock prices and generate ill-gotten gains”. It also charged 21 individuals for their alleged involvement in “a decade-long insider trading scheme involving information misappropriated from multiple global law firms”.

The Commission “instituted 13 trading suspensions in response to suspected manipulation involving the securities of Asia-based issuers”. Those suspensions, the release says, “involved potential manipulation designed to artificially inflate the price and trading volume of the securities, mostly using social media”.

On market infrastructure, the Commission instituted a settled order against the New York Stock Exchange LLC, “finding that it violated Rule 1001(a)(2)(vii) of Regulation Systems Compliance and Integrity (Regulation SCI) and Exchange Act Section 19(g)(1) in connection with an event in which NYSE failed to conduct opening auctions for more than 2,800 securities”. It also instituted a settled order against Wedbush Securities Inc., finding that the broker-dealer “failed to provide complete and accurate securities trading information, known as blue sheet data, to the SEC”. Separate settled orders found that Merrill Lynch, Pierce, Fenner & Smith Incorporated and Canaccord Genuity LLC failed to file Suspicious Activity Reports.

The Commission also entered into a memorandum of understanding with the Commodity Futures Trading Commission that, the release says, “deepens collaboration on enforcement matters involving market integrity and complex financial products”.

How the Division says it will work

The Division updated its Enforcement Manual “for the first time since 2017”. The release says the updates “standardize the Wells process”, “allow simultaneous Commission consideration of settlement recommendations and related waiver requests”, and “explain the Division’s framework for evaluating cooperation, including the impact of cooperation on civil penalties”.

The Commission also rescinded Rule 202.5(e) of its informal rules of procedure, which had provided that it would not settle an action in which a sanction is imposed unless the defendant or respondent also agreed “not to publicly deny the allegations in the complaint or administrative order”. The release says rescinding the rule “aligned the Commission with the overwhelming majority of federal agencies that do not have a similar rule” and “provided the SEC more flexibility in settling enforcement actions”.

The Division formed a Retail Fraud Working Group, a Financial Reporting and Accounting Unit, and an Office of Super Intelligence and Analytics, and reorganised its Trial Unit. The whistleblower programme received approximately 26,000 tips in the fiscal year and awarded more than $158 million to 65 individual whistleblowers.

Why it matters

Analysis. Annual enforcement tallies are a poor proxy for how a trading firm should adjust its controls, and the SEC itself is at pains to say so. What matters for market participants is where the Division spent its time and how it now expects to settle.

The market-integrity docket is conventional: spoofing, insider trading and trading suspensions remain in scope, including 13 suspensions of Asia-based names that the SEC ties to suspected social-media manipulation. The infrastructure cases are more specific. A Regulation SCI finding against NYSE over failed opening auctions, and a blue-sheet case against a reporting broker-dealer, are reminders that auction processes and blue-sheet reporting remain examination and enforcement targets. The new CFTC memorandum of understanding is also worth a note for firms that straddle cash equities and derivatives, including event contracts.

On process, two changes will show up in counsel’s inbox. The Enforcement Manual now sets a standardised Wells process and a published cooperation framework, and it allows settlement recommendations and related waiver requests to be considered together. The rescission of Rule 202.5(e) removes the Commission’s former insistence that settling respondents not deny the allegations. Firms heading into a Wells or settlement discussion will want to read both changes against their own disclosure and waiver planning.

What we are watching

• How the updated Wells and cooperation framework is applied in trading and market-infrastructure cases.
• Whether the 13 Asia-issuer trading suspensions are followed by litigated manipulation actions.
• Use of the CFTC memorandum of understanding on matters that sit across the securities and derivatives perimeter.

Sources

• Press release 2026-113, SEC Announces Enforcement Annual Results for Fiscal Year 2026, U.S. Securities and Exchange Commission, 10 Nov 2026
• Remarks at the 26th Annual A.A. Sommer Lecture, David Woodcock, 10 Nov 2026