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Thursday, April 30, 2026

2022 Year-End Securities Enforcement Update - Gibson Dunn

I. Introduction: Themes and Notable Developments

A. Themes: Aggressive Enforcement Continues

The principal theme of Securities Enforcement this year is consistent with the message this Administration has promoted since it began: this Commission and its Enforcement Division are seeking to heighten the level of enforcement by employing existing remedies and increasing the price of resolving an enforcement investigation. The Commission’s Enforcement agenda has played out in numerous ways, most notably in the increase in civil monetary penalties, but in the demand for other remedies as well.

1. Notable Metrics: Increased Actions, But Particularly Penalties

The enforcement statistics for fiscal 2022 reflect a 6.5% year-over-year increase in stand-alone actions, from 434 in 2021 to 462 in 2022.[1] However, this number is still well below the five-year high of 526 actions in fiscal 2019. The distribution of actions across subject matter was generally consistent with prior years, with the majority of cases involving broker-dealers and investment advisers, public company financial reporting, and securities offerings. There were modest increases year-over-year in the percentage of stand-alone actions for issuer reporting, audit and accounting (16% of actions in 2022, compared to 12% in 2021) and insider trading (9% of actions in 2022, compared to 6% in 2021). There was a modest decrease in percentage of stand-alone actions for securities offerings (23% of actions in 2022, compared...



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