Sidley Publishes Securities Enforcement and Regulatory Update

In a recent article, Sidley published a 2025 fiscal year end report of Securities and Exchange Commission (SEC) enforcement actions. The fiscal year, ending on September 30, saw 90+ enforcement actions targeting rule enforcement, conflicts of interest, misrepresentations and inadequate disclosures, artificial intelligence, miscellaneous compliance failures, and other related areas. According to Sidley, “These numbers were substantially down from the prior fiscal year, where the SEC brought over 130 actions against investment advisers and their representatives.” The decrease in enforcement cases is likely due to a combination of factors including a change in the administration and the loss of approximately 15% of Enforcement staff due to buy-outs and staff attrition. The new administration, under the leadership of Chairman Paul Atkins, plans to focus on “cases of genuine harm and bad acts” rather than cases involving books and records (ex. off-channel communications cases) that “consumed excessive Commission resources not commensurate with any measure of investor harm.” The article highlights several enforcement cases including those involving the marketing rule, custody rule, and inadequate disclosures. Most of the cases involved investment advisers, private funds, and chief compliance officers of both private and registered funds.

Click here to read the 2025 Fiscal Year in Review SEC Enforcement update.