2025 SEC enforcement actions key highlights

On Nov. 19, 2025, Cornerstone Research issued a press release regarding the Securities and Exchange Commission (SEC) Enforcement Actions for Fiscal Year 2025. The press release is based on available data per the SEC as of Nov. 14, 2025. Included in the press release is a link to the “SEC Enforcement Activity: Public Companies and Subsidiaries, Fiscal Year 2025 Update” Report issued by Cornerstone Research. The SEC typically issues an annual Enforcement Results Article each November. However, it has not yet been released by the SEC.

Throughout 2025, the SEC initiated 56 actions against public companies and subsidiaries. This is a decrease from the 80 actions initiated in 2024. Of the 56 actions, 30 are against subsidiaries, and 26 are against public companies.

The 2025 actions resulted in $808 million in total monetary settlements, the lowest amount in SEC history during a year in which there was a change in the SEC administration. These include $108 million in disgorgement and the remaining $700 million in civil penalties. The majority of the civil penalties were for administrative proceedings at approximately 84% of total monetary settlements, the highest percentage in history.

2025 saw the lowest total monetary settlements since 2012 as well as the second lowest average monetary settlement of $15 million. The $108 million in disgorgement was the lowest in history. The second lowest amount of disgorgement in a year is over $300 million more than the 2025 amount. It was noted that it is possible that the significant reduction in disgorgement settlements is due to the lack of clarity in whether the SEC can collect disgorgement settlements without evidence that investors suffered losses due to the alleged actions of the respective defendants.

In 2025, 41% of allegations related to issuer reporting and disclosures, 27% related to investment advisor/investment companies, 23% related to broker-dealers, 7% related to the Foreign Corrupt Practices Act and 2% related to other areas. Actions were heavily focused on issuer reporting and disclosures, investment advisor/investment companies and broker-dealers.