New Brattle Report Highlights Sharp Second-Half Decline in FY25 SEC Enforcement

SAN FRANCISCO, Oct. 28, 2025 /PRNewswire/ -- According to a new report by Brattle Senior Associate Adrienna Huffman and Principal Jan Jindra, the US Securities and Exchange Commission (SEC) initiated 506 enforcement actions in Fiscal Year 2025 (FY25), which runs from October 1 to September 30. This represents a 13% decline from FY24 and the lowest level in eight years. Their analysis highlights a dramatic slowdown in enforcement in the second half of the fiscal year, a decline that coincided with leadership changes and shifting priorities under new SEC Chair Paul Atkins.

SEC Enforcement Activity for Fiscal Year 2025: A Tale of Two Halves compares SEC enforcement actions in FY25 to annual activity and monthly patterns observed between fiscal years 2018 and 2024. The authors' comparison includes analysis of enforcement actions by type of allegations, respondent types (individuals versus non-individual entities), and actions with parallel criminal indictments.

"While a temporary slowdown typically follows the swearing-in of a new SEC chair in enforcement activity, the decline in FY25 was well outside the historical norms," said Dr. Jindra. "The data in our report suggests a structural shift in enforcement priorities under new leadership, with a growing emphasis on individual accountability and capital formation, and a move away from the broader regulatory actions that defined prior years."

Key findings from the report include:

• FY25 saw the lowest enforcement totals since FY18, with the 506 enforcement actions initiated – well below the average of 716 cases per fiscal year.
• Historically, the highest number of enforcement actions occurs in the second half of a year; however, the 144 cases initiated in the second half of FY25 were by far the fewest for any half-year analyzed.
• While there was a continued decline in enforcement actions against individual respondents in FY25, a noticeable increase occurred in the second half of the fiscal year – from 30.4% of respondents to 46.5%.
• The mix of allegations in SEC enforcement actions during the first half of FY25 was generally in line with prior years. However, the second half showed notable variations, with Securities Offerings cases nearly doubling, and cases involving the Foreign Corrupt Practices Act (FCPA), Issuer Reporting, and Broker-Dealer allegations declining.
• There was a record proportion (22.9% of total enforcement actions) of parallel criminal investigations in the second half of FY25.

The report also includes predictions for SEC enforcement activity in 2026, with the trajectory of activity testing whether the FY25 slowdown is the start of a "new normal" at the Commission.

The full report can be found on Brattle's website: https://www.brattle.com/insights-events/publications/sec-enforcement-activity-for-fiscal-year-2025-a-tale-of-two-halves/.

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SOURCE The Brattle Group