Act now: Understanding the rise in penalties despite fewer filings

The U.S. Securities and Exchange Commission (SEC) brought 286 enforcement actions in fiscal year 2025, the lowest number in 20 years, according to data released by the agency on April 22, 2026.

Despite the decline in filings, penalties imposed by the SEC reached record levels, driven largely by resolutions of cases initiated in prior years involving fraud, market manipulation, and securities violations tied to major financial institutions.

The enforcement total marks a continued downward trend from 347 actions in fiscal year 2024 and 403 in fiscal year 2023, reflecting a sustained reduction in new case initiations over the past three years.

SEC officials attribute the drop in new filings to a strategic shift toward resolving complex, long-running investigations rather than launching numerous smaller actions, particularly those related to disclosure failures and insider trading schemes uncovered in earlier market stress periods.

Among the matters contributing to elevated penalties were settlements with major banks and trading firms over allegations of spoofing, wash trading, and misrepresentations in structured product sales, some of which originated from investigations launched during the 2022–2023 volatility surge in equity and fixed-income markets.

The agency also noted that enforcement related to AI-driven market activities remained minimal in 2025, with only 16 actions involving artificial intelligence tools or algorithms, consistent with the second-half slowdown observed in the prior year.

SEC Chair Gary Gensler emphasized that the enforcement strategy prioritizes impact over volume, stating that “a smaller number of significant cases can deter misconduct more effectively than many minor ones,” though he did not provide specific dollar figures for penalties collected in 2025.

The decline in new filings contrasts with rising penalties in other federal enforcement domains, such as tax collections and civil fraud, where agencies reported increased recoveries despite fluctuating case volumes.

SEC enforcement data is compiled annually and released as part of the agency’s performance and accountability reporting, with fiscal year 2025 covering the period from October 1, 2024, to September 30, 2025.