SEC enforcement outcomes

Fiscal year 2025 and 2024 compared

The SEC fiscal year ends on 30 September ¹. The figures below are as published in the SEC's annual results releases ^1,2.

Why the 2025 money figures need care

The SEC said some disgorgement ordered in fiscal year 2025 was deemed satisfied by orders in separate non-SEC cases, such as parallel criminal restitution or forfeiture orders ¹. It removed those amounts and the judgments in one Ponzi scheme litigation. On that basis it reported US$1.4 billion in disgorgement and prejudgment interest and US$1.3 billion in civil penalties ¹.

The addendum to the release says the judgments in that litigation included penalties of US$5.9 billion and disgorgement of US$9 billion ⁴. It defines standalone enforcement actions as a combined count of civil actions and standalone administrative proceedings ⁴.

What the SEC said about its approach

The fiscal year 2025 release says the current Commission has refocused enforcement on fraud and has put a stop to what it called regulation by enforcement ¹. It says the prior Commission brought 95 actions and obtained US$2.3 billion in penalties since fiscal year 2022 for failures to preserve off-channel communications, and that these cases identified no direct investor harm ¹.

The release reports that about two-thirds of standalone actions charged individuals ¹. It lists seven crypto-related actions brought by the prior Commission that were dismissed from February 2025 ¹.

How an SEC case moves

• Matter under inquiry: a preliminary stage that typically involves incomplete information ³.
• Investigation: opened from an inquiry or independently. Investigative proceedings are nonpublic, except where the Commission orders otherwise ³.
• Wells notice: staff tell a person they have made a preliminary determination to recommend an action. The person may make a written submission, which should be limited to 40 pages, not including exhibits ³. US regulations allow persons involved in investigations to submit a written statement setting out their position ⁵.
• Commission vote: the filing of any enforcement action must be authorized by the Commission ³.
• Closing: when staff decide not to recommend action, the Division notifies the person by termination letter ³.

Reading the totals

The total count of 456 actions includes 69 follow-on administrative proceedings that seek to bar or suspend individuals based on criminal convictions, civil injunctions or other orders ¹. The SEC says its fiscal year 2025 results do not include 1,095 matters that were investigated and closed ¹. Money ordered is not the same as money collected. The releases report amounts ordered and, separately, amounts returned to harmed investors ^1,2.