The enforcement results for the first six months of the new administration show that while the Securities and Exchange Commission (“SEC”) has instituted substantially fewer new enforcement actions as compared to the same period during the first and final years of the prior administration, the mix of cases that have been brought shows a clear focus on traditional fraud schemes affecting retail investors. As we discuss in this note, there are many factors that could be contributing to these trends, including that the results reflect new Chairman Paul Atkins’ stated priority of focusing enforcement resources on those who “lie, cheat, and steal.” While it is premature to conclude that these first six months will foreshadow what’s to come for the next three and a half years under Chairman Atkins, the data so far reflects an emphasis on cases involving retail customer or investor harm.
Analysis
To conduct our analysis, we looked at all new civil actions and standalone administrative proceedings during the period of February 1, 2025 – July 31, 2025, and compared the data to the same six-month periods in 2021 and 2024. We excluded follow-on administrative proceedings (those based on convictions and previously obtained injunctions) and those related to delinquent filings, and used the same categories as found in the SEC’s annual enforcement reports.1 The following table summarizes the results of our review:

67 new actions were filed between February 1 and July 31, 2025, a 47% drop compared to the 127 cases brought during the same period in 2024 and a 66% drop compared to the 198 new cases brought during the same period in 2021.
Multiple factors likely contributed to the lower numbers for 2025. First, the results almost certainly reflect an emphasis on pursuing clearcut frauds and away from more “creative” theories pursued by the SEC during the last administration. 2
Second, as the SEC itself acknowledged, there were considerable efforts taken to file enforcement actions during the final months of the last administration. From October to December 2024, the SEC filed 118 standalone enforcement actions. 3 And, based on our analysis, the SEC filed 55 new standalone enforcement actions during the period of January 1 through January 19, 2025, before Inauguration Day on January 20, 2025.4 The apparent effort to pull these cases forward almost certainly accelerated the timing of actions that otherwise would have been filed during the first six months of the new administration or, in some cases, perhaps not at all.5
Third, the number of actions filed during the first six months of this administration may well have been impacted by the large number of SEC staff who chose to depart the agency through buyouts or early retirements offered by the current Administration at the beginning of its term. Many of these individuals were experienced professionals in senior roles who had been with the SEC for a significant number of years. As noted in Chairman Paul Atkins’ remarks during a May 6, 2025, SEC Town Hall meeting, the agency’s headcount at the time was approximately 4,200 employees and 1,700 contractors, representing a decline of approximately 15% from the highs of 2024, when the agency had approximately 5,000 employees and 2,000 contractors.6 Even though most SEC investigations are ongoing for at least one to two years prior to an enforcement action being initiated, the potential distraction and uncertainty created by this turnover likely has also contributed to the slowdown in actions filed.
Fourth, it is natural that changes in senior leadership at the SEC, as well as changes in the priorities of that new leadership team, would impact not only the number but also the mix of enforcement actions. Based on the data from the first six months of this administration, there are some themes that can be observed from the mix of cases that were filed.
Most notably, the cases brought during the first six months of this administration suggest a focus on clearcut frauds affecting retail investors, which aligns with Chairman Atkins’ stated priority of holding accountable “those who lie, cheat and steal.”7 Almost 50% of the cases filed, that is, 32 of the 67 cases, involved securities offerings and almost 25%, covering 16 of the 67 cases filed, have been brought against investment advisers – often for alleged demonstrably fraudulent conduct such as misappropriating client funds.
Another observable trend is that the number of broker-dealer actions is considerably down, with only two new cases filed during the first six months, compared to 18 filed during the same period in 2024 and 16 during the first six months of the previous administration. One major factor contributing to this decline is the absence of actions related to the use of off-channel communications, which was a key (and controversial) priority for the SEC during the last administration, and led to increases in the number of cases filed and the size of aggregate sanctions imposed during prior periods.
A final observation is the reduced number of cases—on an aggregate as well as percentage basis—involving issuer reporting and insider trading, compared to the same periods during 2021 and 2024. These areas tend to be perennial priorities for the Enforcement Division regardless of which party is in power. It will therefore be interesting to monitor whether this becomes a trend or whether it is a temporary aberration potentially caused by cases being “pulled forward” and filed between October 1, 2024 – January 19, 2025.
Conclusion
In summary, after adjusting for follow-on administrative and delinquent filing proceedings, the first six months of this administration have seen substantially fewer enforcement actions filed, and those actions have reflected a focus on frauds affecting retail investors.8 Given the many factors that likely have contributed to the slowdown, it will be interesting to see whether these six months foreshadow the direction of SEC enforcement for the next three and a half years, or whether the pace will increase and the mix of cases will evolve.9
It is important to remember that these data points only reflect filed enforcement actions, where the SEC has determined that charges are warranted following a nonpublic investigation. It is impossible to know with any certainty what kinds of investigations are being opened since the start of February or where the Division is choosing to direct its limited resources. Certain types of cases – for example, those involving allegations of accounting fraud, insider trading, or market manipulation – typically require years to investigate. As a result, it will take time before we can more confidently assess whether the past six months reflect a long-term shift or just the Enforcement Division’s historical pipeline of matters.
1See www.sec.gov/files/fy24-enforcement-statistics.pdf (listing and categorizing actions brought during FY 2024).
2See Reuters, SEC to focus on traditional cases under new leadership, acting director says, March 24, 2025, available at https://www.reuters.com/world/us/sec-focus-traditional-cases-under-new-leadership-acting-director-says-2025-03-24/ (describing interim SEC Enforcement Director Sam Waldon’s remarks at a securities industry event in which he noted that “creativity is probably not where we want to be”).
3SEC Press Release, SEC Announces Record Enforcement Actions Brought in First Quarter of Fiscal Year 2025, https://www.sec.gov/newsroom/press-releases/2025-26.
4By our count, the SEC filed an additional 9 enforcement actions between January 20 and January 31, 2025.
5For reference, on January 17, 2025, just before President Trump’s inauguration on January 20, 2025, there were 23 new actions filed.
6Paul. S. Atkins, Chairman, Opening Remarks at the SEC Town Hall, May 6, 2025, https://www.sec.gov/newsroom/speeches-statements/atkins-townhall-05062025
7Id.
8Even with the record number of cases that were brought during the final four months of the last administration, the SEC would need to bring about 150 more actions between the beginning of August and the end of September to match last year’s total, which seems unlikely.
9The authors wish to thank Catherine Kirby, King & Spalding summer associate, who assisted with the preparation of this alert.