In the 2025 fiscal year (ended September 30, 2025), the SEC’s enforcement activity, as measured by the number of stand-alone enforcement actions, was at its lowest level in ten years. While the decline was reflected across many categories of SEC enforcement, there were certain specific areas – such as cases involving insider trading and market manipulation – where SEC activity actually increased. And notwithstanding the overall decline in SEC enforcement activity, there are signs to suggest that foreign companies listed on U.S. exchanges should be prepared heightened SEC scrutiny and enforcement activity, as discussed below.Continue Reading SEC Enforcement Actions Decline, But Foreign Cos. Should Remain Vigilant

In my recent roundup of the top current stories in the world of D&O, I noted the increasing importance of geopolitical issues as a source of D&O claims risk. Among the factors supporting this trend is the rising relevance of cross-border enforcement initiatives, which in many instances had led to D&O claims. In the latest sign of the importance of cross-border enforcement issues, the SEC has announced the formation of a cross-border task force to “identify and combat cross-border fraud harming U.S. investors.” The SEC’s September 5, 2025, press release about the task force can be found here.  A September 10, 2025, post on TheCorporateCounsel.net blog about the new task force’s formation can be found here.Continue Reading SEC Forms Task Force to Combat Cross-Border Fraud