The present state of US financial enforcement

US financial enforcement has seen a significant decline, with SEC actions against public companies dropping to their lowest level on record in fiscal year 2026. According to InvestmentNews, the regulator initiated just 16 actions, marking a 71 percent decline from the 56 brought in the prior year. This drop represents the smallest annual tally since the Securities Enforcement Empirical Database began tracking data in fiscal year 2010. The findings come from a November 2026 report by Cornerstone Research and the NYU Pollack Center for Law & Business. Reuters reported that US SEC enforcement activity plunged two years into the Trump administration, while the Wall Street Journal noted that enforcement penalties fell to an 18-year low. Law360 described the Securities and Exchange Commission under this shift as taking a 'back to basics' approach that breaks from the past. Total monetary settlements in fiscal year 2026 reached $184 million, which is the lowest in the SEED database and more than $600 million below the prior year's total. The average settlement fell to $12 million, while the median dropped to $1 million. Furthermore, 99 percent of total monetary settlements in fiscal year 2026 consisted of civil penalties, representing the highest such share in the database. Disgorgement and prejudgment interest totaled just $1 million for the year, which is roughly $100 million below the next-lowest total recorded in fiscal year 2025. Only 63 percent of settling defendants faced a monetary settlement at all, and no defendant in a public company or subsidiary action admitted guilt. Chair Paul Atkins stated at the Conference on Financial Market Regulation on May 8, 2026, that the SEC no longer measures the success of its enforcement program by the quantity of actions brought. Half of all fiscal year 2026 actions against public companies and subsidiaries involved Issuer Reporting and Disclosure allegations. Additionally, fiscal year 2026 marked the first year in the database with no actions involving Foreign Corrupt Practices Act allegations, following a White House executive order on February 10, 2025, that paused FCPA enforcement by the Department of Justice. A larger share of actions in fiscal year 2026 named individual defendants than in any of the prior 10 years, aligning with Enforcement Division Director David Woodcock's goal of holding individual wrongdoers accountable, as outlined in September 2026 remarks.