SEC Enforcement FY2025 Results Signal Shift in Priorities in Direct Critique of Prior Administration
On April 7, 2026, the SEC Division of Enforcement published its annual enforcement results for the 2025 fiscal year (October 2024 through September 2025). The Division reported 456 total enforcement actions, the lowest number in at least 20 years, including 303 “stand-alone” actions; 69 “follow-on” administrative proceedings arising from other civil, criminal, or administrative events; and 84 actions against delinquent filers. The SEC also reported approximately $17.9 billion in monetary relief.
FinCEN Postpones Effective Date of Anti-Money-Laundering Rule for Investment Advisers and Exempt Reporting Advisers
On July 21, 2025, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule requiring anti-money-laundering (AML) programs for certain investment advisers (the IA AML Rule). The rule, previously scheduled to take effect on January 1, 2026, will now be delayed until January 1, 2028.
Ian McGinley, Former Director of Enforcement for the CFTC, Joins Sidley’s Regulatory and Enforcement Practice
Sidley is pleased to announce that Ian McGinley has joined the firm as a Securities Enforcement and Regulatory partner in the Regulatory and Enforcement practice group in New York. Mr. McGinley was most recently the Director of Enforcement for the U.S. Commodity Futures Trading Commission (CFTC). At Sidley, he will focus on regulatory enforcement and white-collar criminal defense, with a particular emphasis on commodities and securities laws. He will also advise clients in civil and criminal matters involving digital assets.
The New UK Corporate Offence of Failure to Prevent Fraud
The fraud landscape in the UK is changing, and it will become much easier to prosecute organisations for fraudulent offences.
In September 2025, the UK’s new corporate “failure to prevent fraud” offence introduced under the Economic Crime and Corporate Transparency Act 2023 (Act), will come into force. This marks a key step in the UK government’s intention to bring about a corporate-culture shift around fraud prevention, encouraging organisations to take proactive measures to prevent fraud.
