Former SEC Officials Discuss Aggressive Enforcement Climate

The SEC Division of Enforcement brought 760 enforcement proceedings in FY2022, consistent with pre-pandemic activity. The SEC also ordered respondents and defendants to pay a record $6.44 billion in penalties and disgorgement. An aggressive enforcement approach is expected to continue, and the SEC appears to be stretching the boundaries of what constitutes securities fraud. This article distills remarks made at a Securities Docket program by Linklaters partner Doug Davison, WilmerHale partner William R. McLucas, and Ankura Consulting Group directors Jason Flemmons and Martin Wilczynski. See “Discussing 2022 Enforcement Results, SEC Enforcement Director Stresses Trust-Building Measures” (Jan. 18, 2023). 

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