SEC 公布 2025 财年执法结果
来源：美国证监会 (SEC) | 时间：2026-04-07T19:48:30+00:00
美国证券交易委员会今天公布了截至 2025 年 9 月 30 日的财年的执法结果。有效执法计划的核心是确定提起哪些案件并负责任地管理委员会……
美国证券交易委员会今天公布了截至 2025 年 9 月 30 日的财年的执法结果。
有效执法计划的核心是确定提起哪些案件并负责任地管理委员会资源。遗憾的是，这些资源在前几年被滥用，以追求媒体头条新闻和增加数字，进而导致对有效执法的期望被误导。
2025 财年业绩及支持背景
2025 财年，委员会提出了 456 项执法行动，包括 303 项独立行动和 69 项“后续”行政程序，旨在根据刑事定罪、民事禁令或其他命令禁止或暂停个人在证券市场的某些职能，并获得总额 179 亿美元的货币救济令。这些针对广泛不当行为的执法行动表明，委员会优先处理直接损害投资者和美国证券市场诚信的案件，包括提供欺诈、市场操纵、内幕交易、发行人披露违规行为以及投资顾问违反信托义务。
调查结果不包括已调查并结案的 1,095 件潜在违规行为、市场参与者已整改其行为的若干事项以及未追究的案件。
2025 财年对于执法部门来说是现代 SEC 历史上从未经历过的独特过渡时期。其特点是在总统就职典礼之前前所未有地急于提起大量案件[1]，并在前一个委员会的领导下积极追求新颖的法律理论。
在此期间，现任委员会对先前未充分依据联邦证券法的案件做出了解决。现任委员会有意将执法计划重新集中在欺诈问题上，这些案件本质上需要更多的时间和资源来开发和提起，通常需要长达两年或更长的时间才能显现结果。
自 2022 财年以来，上一届委员会对违反账簿和记录（特别是未能维护和保存渠道外通信）的公司采取了 95 项行动，并处以 23 亿美元的罚款。加上七起与加密货币公司注册相关的案件和六起“交易商定义”案件，这些案件没有发现这些违规行为对投资者造成直接损害，也没有给投资者带来任何利益或保护，并证明了现任委员会认为对联邦证券法的误解、委员会资源的错误分配以及对提起的案件数量与投资者保护问题的偏见。今年的执法结果澄清了这些行动的缺陷及其各自的处罚，并重新确立了执法有效性的定义和衡量标准，以国会的初衷为基础，重点是采取真正防止投资者受到伤害的行动，而不是头条新闻和夸大的数字。
展望未来，执法重点和结果将与委员会和该司的核心任务联系起来，因此将考虑以下要素来履行其使命： 打击多种形式的欺诈行为以及参与此类不当行为的市场参与者；通过适当的补救措施解决有关各方的欺诈和操纵行为；并在投资者受到损害时偿还损失。
美国证券交易委员会主席保罗·S·阿特金斯 (Paul S. Atkins) 表示：“在过去的一年里，委员会停止了通过执法进行监管，并通过优先考虑提供有意义的投资者保护和加强市场诚信的案件，将其执法计划重新集中在委员会的核心使命上。” “我们已将资源转向造成最大伤害的不当行为类型，特别是欺诈、市场操纵和滥用信任，而不是优先考虑数量和创纪录的处罚，而不是真正的投资者保护。这一方针修正的一个关键部分是重新强调追究个人不法行为者的责任，这将促进更强有力的威慑并更好地保护投资者。我为工作人员在推进基于合理判断、明确法律权威和现实世界需求的执法计划方面所做的工作感到自豪投资大众的。”
“我完全支持不再使用执法作为政策制定工具，而是回归委员会的历史规范，”美国证券交易委员会委员马克·T·乌耶达 (Mark T. Uyeda) 表示。 “我们将继续专注于连贯和透明的政策制定，以及与市场参与者的有意义的接触，以促进合规性，并以更适当的方式行使执法权，首先以投资者保护为指导。”
支持细节
在 2025 财年的执法行动中，委员会获得了总额为 179 亿美元的货币救济令，其中 108 亿美元为没收非法所得和预判利息，以及 72 亿美元为民事罚款。委员会获得金钱救济令的一些行动包括委员会认为通过单独的非 SEC 行动中的法院命令（例如，并行刑事诉讼中的归还或没收令）全部或部分满足的返还赃款金额。排除这些“视为已满足”的金额（这些金额历来没有在委员会的年度统计数据中详细列出或排除），以及委员会针对其 80 亿美元庞氏骗局的长期诉讼中针对罗伯特·艾伦·斯坦福和其他被告的判决后，2025 财年获得的货币救济总计为 14 亿美元的没收和判决前利息以及 13 亿美元的民事罚款。
在 2025 财年，一些市场参与者自我报告了违规行为，与该部门的调查进行了有意义的合作 [3]，和/或纠正了 [4] 证券法违规行为。因此，该司建议并委员会批准了减轻民事处罚的决议[5]，或拒绝建议对一方采取执法行动。 2025 财年，委员会向受损害的投资者返还了约 2.62 亿美元，并向 48 名个人举报人奖励了约 6000 万美元。此外，SEC 在 2025 财年收到了创纪录的 53,753 条举报、投诉和转介，比上一财年增加了近 19%。
保护散户投资者
2025 财年的执法结果表明，委员会注重保护可能特别容易受到证券欺诈的散户投资者的利益，同时优先考虑识别和纠正欺诈行为。该部门在 2025 财年向这一关键领域投入了大量资源，并采取行动解决针对退伍军人、老年人和宗教团体成员的欺诈行为。
该部门提出了几项值得注意的行动，包括：
Paramount Management Group, LLC、Prestige Investment Group, LLC 及其创始人 Daryl F. Heller 参与庞氏骗局，该骗局涉嫌诈骗约 2,700 名投资者，其中许多是散户投资者，并导致投资者损失 4 亿美元；
First Liberty Building & Loan, LLC 及其所有者 Edwin Brant Frost IV 涉嫌涉嫌庞氏骗局，诈骗约 300 名投资者超过 1.4 亿美元；
Nightingale Properties, LLC 及其创始人 Elchonon “Elie” Schwartz 涉嫌通过虚假陈述从约 700 名散户投资者那里筹集了 6000 万美元，并挪用了超过 5200 万美元的投资者资金；
总部位于马萨诸塞州的生物制药公司 Allarity Therapeutics, Inc. 因披露失败向投资公众隐瞒了其不当行为
[正文过长，已截取前部进行翻译]
有效执法计划的核心是确定提起哪些案件并负责任地管理委员会资源。遗憾的是，这些资源在前几年被滥用，以追求媒体头条新闻和增加数字，进而导致对有效执法的期望被误导。
2025 财年业绩及支持背景
2025 财年，委员会提出了 456 项执法行动，包括 303 项独立行动和 69 项“后续”行政程序，旨在根据刑事定罪、民事禁令或其他命令禁止或暂停个人在证券市场的某些职能，并获得总额 179 亿美元的货币救济令。这些针对广泛不当行为的执法行动表明，委员会优先处理直接损害投资者和美国证券市场诚信的案件，包括提供欺诈、市场操纵、内幕交易、发行人披露违规行为以及投资顾问违反信托义务。
调查结果不包括已调查并结案的 1,095 件潜在违规行为、市场参与者已整改其行为的若干事项以及未追究的案件。
2025 财年对于执法部门来说是现代 SEC 历史上从未经历过的独特过渡时期。其特点是在总统就职典礼之前前所未有地急于提起大量案件[1]，并在前一个委员会的领导下积极追求新颖的法律理论。
在此期间，现任委员会对先前未充分依据联邦证券法的案件做出了解决。现任委员会有意将执法计划重新集中在欺诈问题上，这些案件本质上需要更多的时间和资源来开发和提起，通常需要长达两年或更长的时间才能显现结果。
自 2022 财年以来，上一届委员会对违反账簿和记录（特别是未能维护和保存渠道外通信）的公司采取了 95 项行动，并处以 23 亿美元的罚款。加上七起与加密货币公司注册相关的案件和六起“交易商定义”案件，这些案件没有发现这些违规行为对投资者造成直接损害，也没有给投资者带来任何利益或保护，并证明了现任委员会认为对联邦证券法的误解、委员会资源的错误分配以及对提起的案件数量与投资者保护问题的偏见。今年的执法结果澄清了这些行动的缺陷及其各自的处罚，并重新确立了执法有效性的定义和衡量标准，以国会的初衷为基础，重点是采取真正防止投资者受到伤害的行动，而不是头条新闻和夸大的数字。
展望未来，执法重点和结果将与委员会和该司的核心任务联系起来，因此将考虑以下要素来履行其使命： 打击多种形式的欺诈行为以及参与此类不当行为的市场参与者；通过适当的补救措施解决有关各方的欺诈和操纵行为；并在投资者受到损害时偿还损失。
美国证券交易委员会主席保罗·S·阿特金斯 (Paul S. Atkins) 表示：“在过去的一年里，委员会停止了通过执法进行监管，并通过优先考虑提供有意义的投资者保护和加强市场诚信的案件，将其执法计划重新集中在委员会的核心使命上。” “我们已将资源转向造成最大伤害的不当行为类型，特别是欺诈、市场操纵和滥用信任，而不是优先考虑数量和创纪录的处罚，而不是真正的投资者保护。这一方针修正的一个关键部分是重新强调追究个人不法行为者的责任，这将促进更强有力的威慑并更好地保护投资者。我为工作人员在推进基于合理判断、明确法律权威和现实世界需求的执法计划方面所做的工作感到自豪投资大众的。”
“我完全支持不再使用执法作为政策制定工具，而是回归委员会的历史规范，”美国证券交易委员会委员马克·T·乌耶达 (Mark T. Uyeda) 表示。 “我们将继续专注于连贯和透明的政策制定，以及与市场参与者的有意义的接触，以促进合规性，并以更适当的方式行使执法权，首先以投资者保护为指导。”
支持细节
在 2025 财年的执法行动中，委员会获得了总额为 179 亿美元的货币救济令，其中 108 亿美元为没收非法所得和预判利息，以及 72 亿美元为民事罚款。委员会获得金钱救济令的一些行动包括委员会认为通过单独的非 SEC 行动中的法院命令（例如，并行刑事诉讼中的归还或没收令）全部或部分满足的返还赃款金额。排除这些“视为已满足”的金额（这些金额历来没有在委员会的年度统计数据中详细列出或排除），以及委员会针对其 80 亿美元庞氏骗局的长期诉讼中针对罗伯特·艾伦·斯坦福和其他被告的判决后，2025 财年获得的货币救济总计为 14 亿美元的没收和判决前利息以及 13 亿美元的民事罚款。
在 2025 财年，一些市场参与者自我报告了违规行为，与该部门的调查进行了有意义的合作 [3]，和/或纠正了 [4] 证券法违规行为。因此，该司建议并委员会批准了减轻民事处罚的决议[5]，或拒绝建议对一方采取执法行动。 2025 财年，委员会向受损害的投资者返还了约 2.62 亿美元，并向 48 名个人举报人奖励了约 6000 万美元。此外，SEC 在 2025 财年收到了创纪录的 53,753 条举报、投诉和转介，比上一财年增加了近 19%。
保护散户投资者
2025 财年的执法结果表明，委员会注重保护可能特别容易受到证券欺诈的散户投资者的利益，同时优先考虑识别和纠正欺诈行为。该部门在 2025 财年向这一关键领域投入了大量资源，并采取行动解决针对退伍军人、老年人和宗教团体成员的欺诈行为。
该部门提出了几项值得注意的行动，包括：
Paramount Management Group, LLC、Prestige Investment Group, LLC 及其创始人 Daryl F. Heller 参与庞氏骗局，该骗局涉嫌诈骗约 2,700 名投资者，其中许多是散户投资者，并导致投资者损失 4 亿美元；
First Liberty Building & Loan, LLC 及其所有者 Edwin Brant Frost IV 涉嫌涉嫌庞氏骗局，诈骗约 300 名投资者超过 1.4 亿美元；
Nightingale Properties, LLC 及其创始人 Elchonon “Elie” Schwartz 涉嫌通过虚假陈述从约 700 名散户投资者那里筹集了 6000 万美元，并挪用了超过 5200 万美元的投资者资金；
总部位于马萨诸塞州的生物制药公司 Allarity Therapeutics, Inc. 因披露失败向投资公众隐瞒了其不当行为
[正文过长，已截取前部进行翻译]
The Securities and Exchange Commission today announced enforcement results for the fiscal year that ended on September 30, 2025.
Central to an effective enforcement program is determining which cases to bring and responsibly stewarding Commission resources. Regrettably, such resources have been misapplied in prior years to pursue media headlines and run up numbers, and in turn, led to misguided expectations on what constitutes effective enforcement.
Fiscal Year 2025 Results & Supporting Context
During fiscal year 2025, the Commission filed 456 enforcement actions, including 303 standalone actions and 69 “follow-on” administrative proceedings seeking to bar or suspend individuals from certain functions in the securities markets based on criminal convictions, civil injunctions, or other orders, and obtaining orders for monetary relief totaling $17.9 billion. These enforcement actions addressing a broad range of misconduct demonstrate the Commission’s prioritization of cases that directly harm investors and the integrity of the U.S. securities markets, including offering frauds, market manipulation, insider trading, issuer disclosure violations, and breaches of fiduciary duty by investment advisers.
The results do not include the 1,095 matters in which potentially violative conduct was investigated and which were closed, the several matters where market participants remediated their practices, or cases that were otherwise not pursued.
FY 2025 was a unique period of transition for the enforcement division never experienced before in modern SEC history. It was characterized by an unprecedented rush to bring a significant number of cases in advance of the presidential inauguration [1] and the aggressive pursuit of novel legal theories under the prior Commission.
This period brought about the current Commission’s resolution of prior cases that were not sufficiently grounded in the federal securities laws. The current Commission deliberately refocused the enforcement program on matters of fraud—cases that inherently require more time and resources to develop and bring, often requiring up to two or more years to manifest results.
Since fiscal year 2022, the prior Commission brought 95 actions and $2.3 billion in penalties against firms for book-and-record violations, specifically failing to maintain and preserve off-channel communications. Together with seven crypto firm registration-related and six ‘definition of a dealer’ cases, these cases identified no direct investor harm from those violations, produced no investor benefit or protection, and demonstrate what the current Commission views as a misinterpretation of the federal securities laws, a misallocation of Commission resources, and a bias for volume of cases brought versus matters of investor protection. This year’s enforcement results clarify the flaws of these actions and their respective penalties and re-establish the definition and measure of enforcement effectiveness, grounded in Congress’s original intent and focused on bringing actions that actually prevent investor harm instead of headlines and inflated numbers.
Going forward, enforcement priorities and results will be linked to the Commission’s and the Division’s core mandate, and will thus contemplate the following elements to fulfill its mission: Standing up to fraud in its many forms and those market participants engaged in such misconduct; addressing the fraudulent and manipulative conduct of the parties in question through appropriate remediation; and repaying investors’ losses when harmed.
“Over the past year, the Commission has put a stop to regulation by enforcement and recentered its enforcement program on the Commission’s core mission by prioritizing cases that provide meaningful investor protection and strengthen market integrity,” said SEC Chairman Paul S. Atkins. “We have redirected resources toward the types of misconduct that inflict the greatest harm—particularly fraud, market manipulation, and abuses of trust—and away from approaches that prioritized volume and record-setting penalties over true investor protection. A key part of this course correction is a renewed emphasis on holding individual wrongdoers accountable, which promotes stronger deterrence and better safeguards investors. I am proud of the staff’s work in advancing an enforcement program grounded in sound judgment, clear legal authority, and the real-world needs of the investing public.”
“I fully support the move away from using enforcement as a tool for policymaking, and the return to the Commission’s historical norms,” said SEC Commissioner Mark T. Uyeda. “We will remain focused on coherent and transparent policymaking, as well as meaningful engagement with market participants to promote compliance, and wield the authority of enforcement in a more appropriate manner, guided by investor protection above all.”
Supporting Detail
In connection with its fiscal year 2025 enforcement actions, the Commission obtained orders for monetary relief totaling $17.9 billion, of which was $10.8 billion in disgorgement of ill-gotten gains and prejudgment interest and $7.2 billion in civil penalties. And some of the actions in which the Commission obtained orders for monetary relief included disgorgement amounts that the Commission deemed satisfied, in whole or in part, by a court order in a separate non-SEC action (e.g., a restitution or forfeiture order in a parallel criminal proceeding). After excluding these “deemed satisfied” amounts, which historically had not been broken out or excluded in annual Commission statistics, and the judgments against Robert Allen Stanford and other defendants in the Commission’s long-running litigation concerning their $8 billion Ponzi scheme, the monetary relief obtained in fiscal year 2025 totaled $1.4 billion in disgorgement and prejudgment interest and $1.3 billion in civil penalties.
In fiscal year 2025, some market participants self-reported violations, co-operated meaningfully [3] with the Division’s investigations, and/or remediated [4] securities law violations. As a result, the Division recommended, and the Commission approved, resolutions imposing reduced civil penalties [5] or declined to recommend an enforcement action against a party. During fiscal year 2025, the Commission returned approximately $262 million to harmed investors and awarded approximately $60 million to 48 individual whistleblowers . In addition, the SEC received a record 53,753 tips, complaints, and referrals in fiscal year 2025, nearly 19 percent more than in the prior fiscal year.
Protecting Retail Investors
The fiscal year 2025 enforcement results demonstrate the Commission’s focus on protecting the interests of retail investors, who may be particularly vulnerable to securities fraud, while prioritizing identifying and remedying fraudulent conduct. The Division devoted significant resources to this critical area in fiscal year 2025 and brought actions to address conduct involving fraudsters who targeted veterans , seniors , and members of a religious community .
The Division filed several noteworthy actions, including:
Paramount Management Group, LLC, Prestige Investment Group, LLC, and their founder, Daryl F. Heller, in connection with a Ponzi scheme that allegedly defrauded approximately 2,700 investors, many of whom were retail investors, and resulted in $400 million in investor losses;
First Liberty Building & Loan, LLC and its owner, Edwin Brant Frost IV, in connection with an alleged Ponzi scheme that defrauded approximately 300 investors of more than $140 million;
Nightingale Properties, LLC and its founder Elchonon “Elie” Schwartz in connection with allegedly raising $60 million from approximately 700 retail investors through false representations and misappropriating more than $52 million in investor funds;
Massachusetts-based biopharmaceutical company Allarity Therapeutics, Inc. for disclosure failures that concealed from the investing public a harsh critique levied by the FDA regarding the company’s flagship cancer drug candidate; and
Vanguard Advisers, Inc. , a registered investment adviser, for failing to adequately disclose conflicts of interest when recommending to prospective and existing clients that they enroll in a fee-based advisory service that provided ongoing portfolio management of their accounts.
Holding Individual Wrongdoers Accountable
In fiscal year 2025, the Commission prioritized charging individuals for violating federal securities laws and will continue to do so. Of the standalone actions filed during this past fiscal year, approximately two-thirds involved charges against one or more individual bad actors (a 27 percent year-over-year increase), and nearly nine out of every 10 standalone actions filed under Acting Chairman Uyeda and Chairman Atkins involved individual charges . The Commission also obtained orders barring 119 individuals from serving as officers and directors of public companies.
Holding individual wrongdoers accountable benefits the investing public by seeking to provide specific and general deterrence , and, particularly where injunctive and other non-monetary remedies are imposed , protecting markets and investors from future misconduct by those same bad actors.
Combatting Securities Fraud Wherever it Occurs
The Commission continued to pursue enforcement actions involving potential market manipulation , such as account takeover and “pump-and-dump” or “ramp-and-dump” schemes involving foreign-based companies and gatekeepers. In September 2025, the Commission formed the Cross-Border Task Force to help address the serious threat that fraudsters located abroad pose to U.S. investors and markets, and several enforcement actions from fiscal year 2025 demonstrate the Commission’s commitment to pursuing transnational fraud that harms American investors.
Safeguarding Markets from Abusive Trading
Central to the Commission’s enforcement efforts are detecting and deterring market abuses, including insider trading, market manipulation, and myriad other practices that interfere with fair, orderly, and efficient markets.
In fiscal year 2025, the Commission brought a number of actions covering a wide range of abusive trading practices, including against a California resident for allegedly conducting a manipulative trading scheme known as “spoofing” through which he obtained approximately $234,000 in ill-gotten gains.
The Commission also filed insider trading charges against, among others:
a former Vice President of Drug Safety and Pharmacovigilance at a biopharmaceutical company ;
a former investor relations executive and two others ; and
a former Head of Equity Trading at an investment firm .
Deploying Resources Judiciously as to Emerging Technologies
In fiscal year 2025, the Commission made a necessary course correction in its approach to enforcing the federal securities laws in the context of crypto assets. [6] The Division remains committed to detecting, deterring, and bringing actions against those seeking to take advantage of investors by misusing new technologies. In February 2025, the Commission announced the launch of the Cyber and Emerging Technologies Unit to complement the work of the Crypto Task Force and to protect investors by combatting misconduct as it relates to securities transactions involving blockchain technology, AI, account takeovers, cybersecurity, and other areas.
During fiscal year 2025, the Division charged:
New York City-based Unicoin, Inc. and four of its current or former top executives for alleged false and misleading statements in an offering of certificates that purportedly conveyed rights to receive crypto assets called Unicoin tokens and in an offering of Unicoin, Inc.’s common stock;
PGI Global founder Ramil Palafox for allegedly orchestrating a $198 million crypto asset and foreign exchange fraud scheme that involved the offer and sale of “membership” packages, which he claimed guaranteed investors high returns from supposed crypto asset and foreign exchange trading, and for misappropriating more than $57 million; and
The founder and former CEO of artificial intelligence company Nate, Inc. with fraudulently soliciting investments and raising more than $42 million through the sale of company stock by allegedly making false and misleading statements about the company’s use of artificial intelligence.
Litigation Highlights
The Division prevailed in several cases at trial and on summary judgment in fiscal year 2025, including:
Trial Victories
SEC v. Gallagher (S.D.N.Y.) – In 2021, the Commission charged defendant Steven M. Gallagher with allegedly committing securities fraud through a scheme to manipulate stocks using Twitter. In September 2025, after a nine-day trial, the jury found Gallagher liable for securities fraud and manipulative trading . As demonstrated at trial, between December 2019 and October 2021, Gallagher used his Twitter account to encourage his numerous followers, including many retail investors, to buy stocks in which Gallagher had already amassed holdings. Gallagher then sold those stocks while he continued to recommend others buy them, never disclosing that he was selling the stocks. Gallagher repeated this pattern with more than 30 microcap stocks, making illicit trading profits in excess of $2.6 million. For two of these stocks, Gallagher was also found to have engaged in manipulative trading by “marking the close” – a strategy involving placing end-of-day orders to buy stock at above-market prices to artificially increase the stock’s price.
SEC v. Minuskin, et al. (S.D. Cal.) – In 2022, the Commission charged defendant Thomas F. Casey and other co-defendants for their alleged roles in a fraudulent securities offering that targeted retirees’ retirement accounts. In June 2025, after a five-day trial and less than two hours of deliberation, the jury found Casey liable for inducing more than 200 people to invest in excess of $10 million into Golden Genesis, a venture to supposedly create blood banks for selling human plasma from young donors for anti-aging treatments, based on false claims including that the investments would generate guaranteed high returns and be secured by the company’s assets. As demonstrated at trial, the funds were not secured, and Casey used investor funds to compensate himself and to prop up the scheme by paying back other investors, causing approximately $8 million in losses to the victims.
SEC v. Cutter Financial Group, et al. (D. Mass.) – In 2023, the Commission charged Massachusetts-based investment adviser Jeffrey Cutter and his advisory firm, Cutter Financial Group, LLC, for allegedly recommending that their advisory clients invest in insurance products that paid a substantial up-front commission without adequately disclosing the defendants’ financial incentive to sell the products. In April 2025, after a seven-day trial, the jury found Cutter and his firm liable for violating Section 206(2) of the Investment Advisers Act of 1940. The jury found for the defendants on claims the Commission alleged under Sections 206(1) and (4) of the Act.
Summary Judgment Victories
SEC v. Brown, et al. (N.D. Tex.) – In 2024, the Commission charged defendants Matthew Brown and his company for allegedly engaging in a fraudulent scheme to submit and publicly tout a bogus offer to invest $200 million in Virgin Orbit Holdings, Inc., which was on the verge of bankruptcy. Among other things, to convince Virgin Orbit that the offer was legitimate, the Commission’s complaint alleged that Brown sent Virgin Orbit a fabricated screenshot of his company’s bank account purporting to show a balance of more than $182 million, when the bank account had less than $1. In August 2025, the court granted the Commission’s motion for summary judgment and found that Brown and his company violated Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder.
SEC v. Melton, et al. (M.D.N.C.) – In 2023, the Commission charged recidivist Marshall Melton and a business he controlled with allegedly conducting an offering fraud that largely targeted older investors. In April 2025, the court granted the Commission’s motion for summary judgment and found that Melton and his business violated the antifraud provisions of the federal securities laws by raising funds purportedly for a real estate development project without disclosing to investors that he actually was using the funds for personal and unrelated expenses. The court also found that the defendants had an affirmative duty to disclose Melton’s securities disciplinary history.
[1] Press Release , SEC Announces Record Enforcement Actions Brought in First Quarter of Fiscal Year 2025 (Jan. 17, 2025 ): (“the most actions filed in their respective periods since at least 2000.”)
[2] E.g., In the Matter of MUFG Securities EMEA plc, Exch. Act Release No. 103646, Admin. Proceeding File No. 3-22504 (Aug. 6, 2025). (Aug. 6, 2025)
[3] E.g., In the Matter of Sourcerock Group, LLC, Exch. Act Release No. 103629, Admin. Proceeding File No. 3-22502 (Aug. 4, 2025). (Aug. 4, 2025)
[4] E.g., In the Matter of Empower Advisory Group, LLC and Empower Financial Services, Inc., Exch. Act Release No. 103809, Admin. Proceeding File No. 3-22517 (Aug. 29, 2025). (Aug. 29, 2025)
[5] E.g., Press Release , SEC Charges Three Broker-Dealers with Filing Deficient Suspicious Activity Reports (Nov. 22, 2024).
[6] Beginning in February 2025, the Commission dismissed seven enforcement actions brought by the prior Commission involving crypto assets: SEC v. Coinbase, Inc., et al. (Feb. 27, 2025); SEC v. v. Cumberland DRW LLC (Mar. 27, 2025); SEC v. Consensys Software Inc. (Mar. 27, 2025); SEC v. Payward, Inc., et al. (Mar. 27, 2025); SEC v. Dragonchain, Inc. (Apr. 30, 2025); SEC v. Balina (May 2, 2025); and SEC v. Binance Holdings Limited, et al. (May 29, 2025).
Central to an effective enforcement program is determining which cases to bring and responsibly stewarding Commission resources. Regrettably, such resources have been misapplied in prior years to pursue media headlines and run up numbers, and in turn, led to misguided expectations on what constitutes effective enforcement.
Fiscal Year 2025 Results & Supporting Context
During fiscal year 2025, the Commission filed 456 enforcement actions, including 303 standalone actions and 69 “follow-on” administrative proceedings seeking to bar or suspend individuals from certain functions in the securities markets based on criminal convictions, civil injunctions, or other orders, and obtaining orders for monetary relief totaling $17.9 billion. These enforcement actions addressing a broad range of misconduct demonstrate the Commission’s prioritization of cases that directly harm investors and the integrity of the U.S. securities markets, including offering frauds, market manipulation, insider trading, issuer disclosure violations, and breaches of fiduciary duty by investment advisers.
The results do not include the 1,095 matters in which potentially violative conduct was investigated and which were closed, the several matters where market participants remediated their practices, or cases that were otherwise not pursued.
FY 2025 was a unique period of transition for the enforcement division never experienced before in modern SEC history. It was characterized by an unprecedented rush to bring a significant number of cases in advance of the presidential inauguration [1] and the aggressive pursuit of novel legal theories under the prior Commission.
This period brought about the current Commission’s resolution of prior cases that were not sufficiently grounded in the federal securities laws. The current Commission deliberately refocused the enforcement program on matters of fraud—cases that inherently require more time and resources to develop and bring, often requiring up to two or more years to manifest results.
Since fiscal year 2022, the prior Commission brought 95 actions and $2.3 billion in penalties against firms for book-and-record violations, specifically failing to maintain and preserve off-channel communications. Together with seven crypto firm registration-related and six ‘definition of a dealer’ cases, these cases identified no direct investor harm from those violations, produced no investor benefit or protection, and demonstrate what the current Commission views as a misinterpretation of the federal securities laws, a misallocation of Commission resources, and a bias for volume of cases brought versus matters of investor protection. This year’s enforcement results clarify the flaws of these actions and their respective penalties and re-establish the definition and measure of enforcement effectiveness, grounded in Congress’s original intent and focused on bringing actions that actually prevent investor harm instead of headlines and inflated numbers.
Going forward, enforcement priorities and results will be linked to the Commission’s and the Division’s core mandate, and will thus contemplate the following elements to fulfill its mission: Standing up to fraud in its many forms and those market participants engaged in such misconduct; addressing the fraudulent and manipulative conduct of the parties in question through appropriate remediation; and repaying investors’ losses when harmed.
“Over the past year, the Commission has put a stop to regulation by enforcement and recentered its enforcement program on the Commission’s core mission by prioritizing cases that provide meaningful investor protection and strengthen market integrity,” said SEC Chairman Paul S. Atkins. “We have redirected resources toward the types of misconduct that inflict the greatest harm—particularly fraud, market manipulation, and abuses of trust—and away from approaches that prioritized volume and record-setting penalties over true investor protection. A key part of this course correction is a renewed emphasis on holding individual wrongdoers accountable, which promotes stronger deterrence and better safeguards investors. I am proud of the staff’s work in advancing an enforcement program grounded in sound judgment, clear legal authority, and the real-world needs of the investing public.”
“I fully support the move away from using enforcement as a tool for policymaking, and the return to the Commission’s historical norms,” said SEC Commissioner Mark T. Uyeda. “We will remain focused on coherent and transparent policymaking, as well as meaningful engagement with market participants to promote compliance, and wield the authority of enforcement in a more appropriate manner, guided by investor protection above all.”
Supporting Detail
In connection with its fiscal year 2025 enforcement actions, the Commission obtained orders for monetary relief totaling $17.9 billion, of which was $10.8 billion in disgorgement of ill-gotten gains and prejudgment interest and $7.2 billion in civil penalties. And some of the actions in which the Commission obtained orders for monetary relief included disgorgement amounts that the Commission deemed satisfied, in whole or in part, by a court order in a separate non-SEC action (e.g., a restitution or forfeiture order in a parallel criminal proceeding). After excluding these “deemed satisfied” amounts, which historically had not been broken out or excluded in annual Commission statistics, and the judgments against Robert Allen Stanford and other defendants in the Commission’s long-running litigation concerning their $8 billion Ponzi scheme, the monetary relief obtained in fiscal year 2025 totaled $1.4 billion in disgorgement and prejudgment interest and $1.3 billion in civil penalties.
In fiscal year 2025, some market participants self-reported violations, co-operated meaningfully [3] with the Division’s investigations, and/or remediated [4] securities law violations. As a result, the Division recommended, and the Commission approved, resolutions imposing reduced civil penalties [5] or declined to recommend an enforcement action against a party. During fiscal year 2025, the Commission returned approximately $262 million to harmed investors and awarded approximately $60 million to 48 individual whistleblowers . In addition, the SEC received a record 53,753 tips, complaints, and referrals in fiscal year 2025, nearly 19 percent more than in the prior fiscal year.
Protecting Retail Investors
The fiscal year 2025 enforcement results demonstrate the Commission’s focus on protecting the interests of retail investors, who may be particularly vulnerable to securities fraud, while prioritizing identifying and remedying fraudulent conduct. The Division devoted significant resources to this critical area in fiscal year 2025 and brought actions to address conduct involving fraudsters who targeted veterans , seniors , and members of a religious community .
The Division filed several noteworthy actions, including:
Paramount Management Group, LLC, Prestige Investment Group, LLC, and their founder, Daryl F. Heller, in connection with a Ponzi scheme that allegedly defrauded approximately 2,700 investors, many of whom were retail investors, and resulted in $400 million in investor losses;
First Liberty Building & Loan, LLC and its owner, Edwin Brant Frost IV, in connection with an alleged Ponzi scheme that defrauded approximately 300 investors of more than $140 million;
Nightingale Properties, LLC and its founder Elchonon “Elie” Schwartz in connection with allegedly raising $60 million from approximately 700 retail investors through false representations and misappropriating more than $52 million in investor funds;
Massachusetts-based biopharmaceutical company Allarity Therapeutics, Inc. for disclosure failures that concealed from the investing public a harsh critique levied by the FDA regarding the company’s flagship cancer drug candidate; and
Vanguard Advisers, Inc. , a registered investment adviser, for failing to adequately disclose conflicts of interest when recommending to prospective and existing clients that they enroll in a fee-based advisory service that provided ongoing portfolio management of their accounts.
Holding Individual Wrongdoers Accountable
In fiscal year 2025, the Commission prioritized charging individuals for violating federal securities laws and will continue to do so. Of the standalone actions filed during this past fiscal year, approximately two-thirds involved charges against one or more individual bad actors (a 27 percent year-over-year increase), and nearly nine out of every 10 standalone actions filed under Acting Chairman Uyeda and Chairman Atkins involved individual charges . The Commission also obtained orders barring 119 individuals from serving as officers and directors of public companies.
Holding individual wrongdoers accountable benefits the investing public by seeking to provide specific and general deterrence , and, particularly where injunctive and other non-monetary remedies are imposed , protecting markets and investors from future misconduct by those same bad actors.
Combatting Securities Fraud Wherever it Occurs
The Commission continued to pursue enforcement actions involving potential market manipulation , such as account takeover and “pump-and-dump” or “ramp-and-dump” schemes involving foreign-based companies and gatekeepers. In September 2025, the Commission formed the Cross-Border Task Force to help address the serious threat that fraudsters located abroad pose to U.S. investors and markets, and several enforcement actions from fiscal year 2025 demonstrate the Commission’s commitment to pursuing transnational fraud that harms American investors.
Safeguarding Markets from Abusive Trading
Central to the Commission’s enforcement efforts are detecting and deterring market abuses, including insider trading, market manipulation, and myriad other practices that interfere with fair, orderly, and efficient markets.
In fiscal year 2025, the Commission brought a number of actions covering a wide range of abusive trading practices, including against a California resident for allegedly conducting a manipulative trading scheme known as “spoofing” through which he obtained approximately $234,000 in ill-gotten gains.
The Commission also filed insider trading charges against, among others:
a former Vice President of Drug Safety and Pharmacovigilance at a biopharmaceutical company ;
a former investor relations executive and two others ; and
a former Head of Equity Trading at an investment firm .
Deploying Resources Judiciously as to Emerging Technologies
In fiscal year 2025, the Commission made a necessary course correction in its approach to enforcing the federal securities laws in the context of crypto assets. [6] The Division remains committed to detecting, deterring, and bringing actions against those seeking to take advantage of investors by misusing new technologies. In February 2025, the Commission announced the launch of the Cyber and Emerging Technologies Unit to complement the work of the Crypto Task Force and to protect investors by combatting misconduct as it relates to securities transactions involving blockchain technology, AI, account takeovers, cybersecurity, and other areas.
During fiscal year 2025, the Division charged:
New York City-based Unicoin, Inc. and four of its current or former top executives for alleged false and misleading statements in an offering of certificates that purportedly conveyed rights to receive crypto assets called Unicoin tokens and in an offering of Unicoin, Inc.’s common stock;
PGI Global founder Ramil Palafox for allegedly orchestrating a $198 million crypto asset and foreign exchange fraud scheme that involved the offer and sale of “membership” packages, which he claimed guaranteed investors high returns from supposed crypto asset and foreign exchange trading, and for misappropriating more than $57 million; and
The founder and former CEO of artificial intelligence company Nate, Inc. with fraudulently soliciting investments and raising more than $42 million through the sale of company stock by allegedly making false and misleading statements about the company’s use of artificial intelligence.
Litigation Highlights
The Division prevailed in several cases at trial and on summary judgment in fiscal year 2025, including:
Trial Victories
SEC v. Gallagher (S.D.N.Y.) – In 2021, the Commission charged defendant Steven M. Gallagher with allegedly committing securities fraud through a scheme to manipulate stocks using Twitter. In September 2025, after a nine-day trial, the jury found Gallagher liable for securities fraud and manipulative trading . As demonstrated at trial, between December 2019 and October 2021, Gallagher used his Twitter account to encourage his numerous followers, including many retail investors, to buy stocks in which Gallagher had already amassed holdings. Gallagher then sold those stocks while he continued to recommend others buy them, never disclosing that he was selling the stocks. Gallagher repeated this pattern with more than 30 microcap stocks, making illicit trading profits in excess of $2.6 million. For two of these stocks, Gallagher was also found to have engaged in manipulative trading by “marking the close” – a strategy involving placing end-of-day orders to buy stock at above-market prices to artificially increase the stock’s price.
SEC v. Minuskin, et al. (S.D. Cal.) – In 2022, the Commission charged defendant Thomas F. Casey and other co-defendants for their alleged roles in a fraudulent securities offering that targeted retirees’ retirement accounts. In June 2025, after a five-day trial and less than two hours of deliberation, the jury found Casey liable for inducing more than 200 people to invest in excess of $10 million into Golden Genesis, a venture to supposedly create blood banks for selling human plasma from young donors for anti-aging treatments, based on false claims including that the investments would generate guaranteed high returns and be secured by the company’s assets. As demonstrated at trial, the funds were not secured, and Casey used investor funds to compensate himself and to prop up the scheme by paying back other investors, causing approximately $8 million in losses to the victims.
SEC v. Cutter Financial Group, et al. (D. Mass.) – In 2023, the Commission charged Massachusetts-based investment adviser Jeffrey Cutter and his advisory firm, Cutter Financial Group, LLC, for allegedly recommending that their advisory clients invest in insurance products that paid a substantial up-front commission without adequately disclosing the defendants’ financial incentive to sell the products. In April 2025, after a seven-day trial, the jury found Cutter and his firm liable for violating Section 206(2) of the Investment Advisers Act of 1940. The jury found for the defendants on claims the Commission alleged under Sections 206(1) and (4) of the Act.
Summary Judgment Victories
SEC v. Brown, et al. (N.D. Tex.) – In 2024, the Commission charged defendants Matthew Brown and his company for allegedly engaging in a fraudulent scheme to submit and publicly tout a bogus offer to invest $200 million in Virgin Orbit Holdings, Inc., which was on the verge of bankruptcy. Among other things, to convince Virgin Orbit that the offer was legitimate, the Commission’s complaint alleged that Brown sent Virgin Orbit a fabricated screenshot of his company’s bank account purporting to show a balance of more than $182 million, when the bank account had less than $1. In August 2025, the court granted the Commission’s motion for summary judgment and found that Brown and his company violated Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder.
SEC v. Melton, et al. (M.D.N.C.) – In 2023, the Commission charged recidivist Marshall Melton and a business he controlled with allegedly conducting an offering fraud that largely targeted older investors. In April 2025, the court granted the Commission’s motion for summary judgment and found that Melton and his business violated the antifraud provisions of the federal securities laws by raising funds purportedly for a real estate development project without disclosing to investors that he actually was using the funds for personal and unrelated expenses. The court also found that the defendants had an affirmative duty to disclose Melton’s securities disciplinary history.
[1] Press Release , SEC Announces Record Enforcement Actions Brought in First Quarter of Fiscal Year 2025 (Jan. 17, 2025 ): (“the most actions filed in their respective periods since at least 2000.”)
[2] E.g., In the Matter of MUFG Securities EMEA plc, Exch. Act Release No. 103646, Admin. Proceeding File No. 3-22504 (Aug. 6, 2025). (Aug. 6, 2025)
[3] E.g., In the Matter of Sourcerock Group, LLC, Exch. Act Release No. 103629, Admin. Proceeding File No. 3-22502 (Aug. 4, 2025). (Aug. 4, 2025)
[4] E.g., In the Matter of Empower Advisory Group, LLC and Empower Financial Services, Inc., Exch. Act Release No. 103809, Admin. Proceeding File No. 3-22517 (Aug. 29, 2025). (Aug. 29, 2025)
[5] E.g., Press Release , SEC Charges Three Broker-Dealers with Filing Deficient Suspicious Activity Reports (Nov. 22, 2024).
[6] Beginning in February 2025, the Commission dismissed seven enforcement actions brought by the prior Commission involving crypto assets: SEC v. Coinbase, Inc., et al. (Feb. 27, 2025); SEC v. v. Cumberland DRW LLC (Mar. 27, 2025); SEC v. Consensys Software Inc. (Mar. 27, 2025); SEC v. Payward, Inc., et al. (Mar. 27, 2025); SEC v. Dragonchain, Inc. (Apr. 30, 2025); SEC v. Balina (May 2, 2025); and SEC v. Binance Holdings Limited, et al. (May 29, 2025).