Expect Dramatic Enforcement Changes in 2025: SEC Roundup
By Nicolas Morgan
By Tom Zaccaro
Welcome to SEC Roundup, a bimonthly video series by former Securities and Exchange Commission senior trial counsels Nick Morgan and Tom Zaccaro, founders of the nonprofit advocacy group Investor Choice Advocates Network.
A group of experts examining the SEC Enforcement Division's Annual Report see IAs as dominating the agency's agenda.
From off-channel communication retention, crypto currency custody, handling of material nonpublic information, the expanding "dealer" registration requirements, cyber breaches and short selling, nearly every aspect of the SEC's Enforcement Division agenda affected or involved IAs.
The SEC filed only 583 total enforcement actions in fiscal 2024 — 26% fewer than the prior year. And while the Commission obtained a record-setting $8.2 billion in civil penalties and disgorgement, over half that figure was in a single matter.
With the change in administration, 2025 promises some dramatic changes.
Each of the experts expressed views on how 2025 might shape up, including Rodrigo Seira of Cooley on crypto and digital assets; independent public company director (and former senior SEC enforcement accountant) Lisa Troe on accounting and financial reporting; Quinn Emanuel partner and former senior SEC enforcement attorney Sarah Heaton Concannon on cyber breach disclosure; Paul Hastings partner Art Zwickel on Asset Management Unit issues; and former SEC trial counsel Tom Zaccaro on insider trading and material nonpublic information.
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