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The SEC’s enforcement agenda continues to evolve under shifting leadership priorities and a dynamic regulatory landscape. In this edition, we examine the Commission’s enforcement priorities for 2026 and offer key takeaways from recent Department of Justice (DOJ) activity to help you navigate regulatory risk and prepare for what’s ahead.
Key 2026 enforcement priorities
On February 11, 2026, SEC Enforcement Judge Margaret Ryan delivered her first major public address at the Los Angeles County Bar Association’s 56th Annual Securities Regulation Seminar. Judge Ryan outlined her guiding principles as integrity, honor, fidelity to the law, and an unwavering commitment to the fair and judicious use of the formidable power and resources the federal government has entrusted her with.
Process: Commitment to the Wells process
Judge Ryan emphasized the commitment of the Division of Enforcement (the Division) to provide transparent and appropriate process to individuals and companies under investigation. Key process commitments include:
- Four-week Wells submission window: Proposed defendants or respondents now have four weeks to make submissions explaining why the Commission should not authorize an enforcement action.
- Senior leadership attendance: A member of the enforcement senior leadership team will attend every Wells meeting, and all Wells submissions will be read and carefully considered.]
- Commission review: The Commission also receives submissions and is expected to read them.
Priorities: Focus on fraud and market integrity
Judge Ryan dispelled the idea that the SEC has limited its enforcement activity. She emphasized three principal enforcement priorities
First, the Division remains focused on returning to basics with fairness and timely resolution of cases. She stated directly that “reports that enforcement work at the SEC has been tossed to the wayside are not only greatly exaggerated but flat out wrong,” and she emphasized being “far more concerned with the quality and impact of the enforcement actions that we bring than with chasing numbers.”
Second, a principal focus is protecting investors from fraud schemes, which SEC Chairman Paul Atkins refers to as pursuing “the liars, cheats, and thieves.” This includes uncovering fraud that wipes out retirement savings and making full use of remedies to return money to harmed investors. The Division will continue to charge violations for misconduct that undermines market integrity, including accounting fraud, insider trading, wash trading, and market manipulation schemes.
Third, Judge Ryan addressed compliance with provisions beyond fraud, such as reporting requirements, books and records obligations, and broker–dealer or investment advisor fiduciary duties. She acknowledged that violations of these provisions are “not necessarily on par with fraud” and that many “should not – and do not – result in enforcement cases.” However, she identified “a middle ground: where fraud is absent, but compliance has failed in a way that poses risks to investors, risks to the integrity of the market, or yields a benefit to the participant.” Such cases “may warrant enforcement action but may also present opportunity” for “thoughtful resolutions that recognize wrongdoing while rectifying the violation or charting a firmer path toward compliance.”
Judge Ryan’s initial priorities do not come as a surprise, but her comments related to when and how enforcement will engage with technical violations of the securities laws signal a shift in the agency’s approach. Her full speech is available online.
Alignment with the DOJ
The DOJ continues to prosecute fraud that overlaps with core securities fraud issues, i.e., schemes involving deceptive conduct harming investors and entities. For example, the 2025 report of the DOJ’s Fraud Section Year in Review highlighted extensive white-collar prosecutions and indictments tied to fraud against markets and consumers.
Furthermore, the DOJ’s emphasis on charging individuals for white-collar criminal conduct parallels the SEC’s strategy of targeting individual bad actors responsible for substantive misconduct over public corporations.
Finally, 2025 saw core alignment between both agencies with the SEC civilly targeting securities fraud and the DOJ pursuing parallel criminal charges for overlapping conduct. For example, both the DOJ and SEC successfully brought charges against Ryan Squillante, who had received material non-public information (MNPI) about various publicly traded companies while in his role as the head of equity trading at an investment firm. Squillante, while in possession of that MNPI, traded in his personal brokerage accounts on at least 11 different occasions. Squillante profited more than $216,000 from his illegal trading.
On June 6, 2025, Squillante pleaded guilty to securities fraud and was sentenced to two months in prison, 18 months of supervised release, and a $331,368 fine. On January 29, 2026, the SEC secured a final judgment by consent against Squillante, permanently enjoining him from violating section 10(b) of the Securities and Exchange Act of 1934 and Rule 10b-5 thereunder and finding him liable for disgorgement in the amount of $216,965 and prejudgment interest in the amount of $33,800, which was deemed satisfied based on the criminal fine imposed against him.