Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherBrowse by ChannelAbout the NetworkJoin the NetworkProductsSub-MenuProducts OverviewBlog ProBlog PlusBlog PremierMicrositeSyndication PortalsAbout UsContactSubscribeSupport
Book a Demo
Search
Close

An Active Year in Enforcement, with Changes to Come

By David A. Last, Lisa Vicens, Matthew C. Solomon, Tom Bednar & Ava Bayani Kazerouni on January 22, 2025
Email this postTweet this postLike this postShare this post on LinkedIn

The following is part of our annual publication Selected Issues for Boards of Directors in 2025. Explore all topics or download the PDF.


The Securities and Exchange Commission (SEC) and Department of Justice (DOJ) both had active enforcement years in 2024. The SEC’s aggressive focus on crypto enforcement continued, resulting in the filing and continued litigation of several cases in federal courts nationwide. The DOJ announced a number of policy updates in 2024, including guidance related to voluntary disclosures and corporate enforcement, and remained active in the foreign corruption and national security spaces. Finally, both the SEC and DOJ have increased their focus on AI and new technologies, showing increasing concern about the risks associated with AI, with the DOJ issuing guidance on AI in compliance programs and the SEC bringing cases related to misleading marketing about the use of AI in investment strategies. As noted more fully below, with the incoming Trump Administration, enforcement priorities at both SEC and DOJ are expected to shift. The SEC is expected to have a renewed focus on traditional enforcement areas, such as accounting fraud, misrepresentations in securities offerings and insider trading, with significant reductions in enforcement activity related to crypto, cyber incidents and ESG issues. The DOJ is likely to continue its focus on FCPA and national security (including sanctions and export controls), while devoting increasing resources to immigration and violent crime. Additionally, the benefits of cooperation are likely to increase at both the SEC and DOJ, with the potential for reduced penalties for companies able to effectively demonstrate their cooperation and self-remediation.

In anticipation of the incoming Trump Administration, there already have been notable personnel changes at both SEC and DOJ with more to come. Specifically, SEC Chair Gary Gensler and Democratic Commissioner Jaime Lizarraga have announced that they will depart. In addition, Trump has announced the nomination of former Commissioner Paul Atkins as Chair, who will stand to replace the outgoing heads of the Divisions of Enforcement and Corporation Finance, among other positions. On the DOJ side, Attorney General-nominee Pam Bondi and Deputy Attorney General nominee Todd Blanche will work with all-new appointees at the top levels of DOJ. Most of the nominees for those positions have yet to be announced, though the incoming administration has announced the nomination of Gail Slater to head the Antitrust Division and Kash Patel to run the FBI.

Read the full post

Photo of Lisa Vicens Lisa Vicens

Elizabeth Vicens’ practice focuses on a broad spectrum of securities enforcement, investigations and compliance, as well as securities litigation, with a concentration in complex, cross-border issues.

Read more about Lisa VicensEmail
Photo of Matthew C. Solomon Matthew C. Solomon

Matthew C. Solomon has significant experience in complex and high-stakes civil and criminal matters, having served for 15 years with the U.S. Department of Justice and the U.S. Securities and Exchange Commission—including most recently as the SEC’s Chief Litigation Counsel.

Read more about Matthew C. SolomonEmail
  • Posted in:
    Corporate & Commercial, Criminal
  • Blog:
    Cleary Enforcement Watch
  • Organization:
    Cleary Gottlieb Steen & Hamilton LLP
  • Article: View Original Source

LexBlog, Inc. logo
Facebook LinkedIn Twitter RSS
Real Lawyers
99 Park Row
  • About LexBlog
  • Careers
  • Press
  • Contact LexBlog
  • Privacy Policy
  • Editorial Policy
  • Disclaimer
  • Terms of Service
  • RSS Terms of Service
  • Products
  • Blog Pro
  • Blog Plus
  • Blog Premier
  • Microsite
  • Syndication Portals
  • LexBlog Community
  • Resource Center
  • 1-800-913-0988
  • Submit a Request
  • Support Center
  • System Status
  • Resource Center
  • Blogging 101

New to the Network

  • Tennessee Insurance Litigation Blog
  • Claims & Sustains
  • New Jersey Restraining Order Lawyers
  • New Jersey Gun Lawyers
  • Blog of Reason
Copyright © 2025, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo