New Sheriff in Town: David Woodcock Returns to Lead SEC Enforcement Division

David Woodcock returned to the SEC as Director of the Enforcement Division (the “Division”) in early May of 2026.[1]He previously served as Director of the SEC’s Fort Worth Office from 2011-2015. He recently summarized his priorities for the Division in a speech at the MFA Legal & Compliance conference.[2]We have summarized certain of his remarks below:

The SEC oversees the world’s deepest and most dynamic capital markets and the Commission’s three-part mission—protecting investors; maintaining fair, orderly, and efficient markets; and facilitating capital formation—is the north star guiding every enforcement action.

Our goals are aligned with those of Chairman Atkins: to return the enforcement program back to basics. That means vigorously protecting investors and safeguarding markets, while also providing transparency.

The Division’s focus is to protect investors and safeguard markets from real harm which means identifying and stopping fraud and manipulation in all its forms: offering fraud, accounting and disclosure fraud, insider trading, market manipulation, fraud by foreign actors targeting U.S. markets and investors, and breaches of fiduciary duties by advisers misusing client assets.

Offering Frauds

The Division continues to bring cases involving offering frauds that have caused significant losses to investors. Recently, we alleged that an individual and his affiliates raised more than $770 million from approximately 2,700 investors, many of whom were retail investors, to invest in a fraudulent scheme involving ATMs that generated roughly $400 million in investor losses. In another case, we charged an alleged fraudster in connection with a Ponzi scheme in which approximately 300 investors were defrauded of at least $140 million. These have always been core matters for the Division.

Financial Reporting

We are also prioritizing financial reporting matters that ensure good corporate accounting and disclosures. In early 2026, we brought actions against an agricultural processing and commodities trading company for allegedly inflating performance. In another matter, we settled with a manufacturing company that violated internal accounting controls. In a third case, we settled with a public company and charged three of its executives with allegedly making false and misleading statements in public filings and financial statements to conceal unfavorable information.

Market Manipulation and Insider Trading

Safeguarding markets necessarily involves addressing market manipulation and insider trading. In December 2025, we filed an action against three Pakistani and U.S. nationals for allegedly carrying out two market manipulation schemes and, with three associates, an approximately $41 million insider trading scheme involving nine potential corporate acquisitions. In another matter, we charged a Russian national for his role in an alleged multi-year scheme in which hundreds of U.S. retail brokerage accounts were hacked and used to manipulate the prices and trading volume of hundreds of securities, generating approximately $31 million in gross proceeds. Last week, we charged 21 individuals for their alleged involvement in a decade-long insider trading scheme involving misappropriated information from multiple law firms resulting in millions in illicit profits. This case highlights the SEC’s unwavering commitment to uncovering sprawling schemes and holding all participants accountable.[3]

Private Funds

The private fund space warrants close attention. Private investment markets and efforts to broaden access to retail investors can be quite positive, but we must, and will, remain vigilant. We are attuned to potential risks relating to liquidity, fees, valuations, and conflicts of interest—not only at the private fund adviser level but throughout the distribution chain. Firms must ensure their representatives understand the products they sell and the investment profiles, risk tolerance, and liquidity needs of their clients.

In the investment adviser space, the Division will remain active. We will continue to pursue matters involving misappropriated client assets, inadequate safeguarding of assets; misleading strategy disclosures; undisclosed fees and expenses; fraudulent valuations and mismarking; prohibited trading practices; and undisclosed conflicts of interest.

Recent cases illustrate this focus. In one settled matter, the Commission found that a private fund advisor sold loans from its inventory to client funds at prices it represented as fair value but instead used par value less unamortized fees. During the early days of the pandemic, the firm continued this practice without assessing the market disruption’s effect on fair market value, despite observable signs of widening spreads and rising rates. In another matter, we filed two litigated complaints, alleging Ponzi-like schemes involving more than $275 million raised from more than 250 investors. A second complaint charged the portfolio manager who allegedly invested his private fund client in the scheme despite his undisclosed conflicts of interest and awareness of red flags. Those cases remain ongoing.

When looking at private credit as an asset class, we should remember that it was prior banking regulatory decisions that constricted financing for small and growing businesses, which created the opening – and need – for private credit to expand rapidly. There are stresses in some portfolios and developments playing out more broadly across this sector, and we are monitoring the situation.

Interagency Cooperation

A critical part of our overall approach is strong coordination with federal partners, state securities regulators, and foreign authorities. The Department of Justice, the Commodity Futures Trading Commission (“CFTC”), the Financial Crimes Enforcement Network (FinCEN), banking regulators, and our foreign counterparts all hold pieces of the enforcement puzzle that the SEC cannot complete on its own. When fraud crosses borders, no single agency can address it in isolation. Fraudsters do not respect jurisdictional lines, so we must work with our foreign counterparts to counteract increasingly complex schemes that cross borders.

We also are returning to a more collaborative and productive posture with our enforcement partners and formalizing information-sharing protocols. This is well underway with the CFTC. We are not looking for opportunities to pile on. A more focused Division cannot afford unnecessary duplication, and investors deserve a regulatory system that works together.

Cross Border Fraud

The important work of the SEC’s Cross-Border Task Force, established last September, will continue. The task force brings together Enforcement staff with expertise in cross-border matters to identify and stop bad actors who use international borders to frustrate U.S investor protections. Current work includes investigating potential violations of the U.S. securities laws related to foreign-based companies, including market manipulation schemes. The task force is also looking at potential violations by underwriters, auditors, and other gatekeepers who facilitate a foreign company’s access to U.S. markets for fraudulent purposes. Finally, the task force is examining potential securities law violations related to companies from foreign jurisdictions, such as China, where governmental control and other factors pose unique risks to investors.

Retail Fraud Working Group

Consistent with these efforts, we will reinstitute the Retail Fraud Working Group, which will focus on protecting retail investors and strengthening coordination with our state and federal partners.

The Conduct Matters — Before and After the Investigation Begins

When advising your clients operating in today’s enforcement environment, the message is both simple and demanding: we are not focused on prosecuting firms or individuals for honest mistakes that cause no investor harm. If your situation fits that profile, demonstrate it with evidence and facts.

The Commission recognizes the difference between error and fraud, and our remedies will be calibrated accordingly. But how the firm engages the Division during an investigation also matters. A company that self-reports, cooperates fully, and remediates will not be treated the same as one that conceals or obstructs.

The takeaway is simple: engage early, engage seriously, engage candidly. If your client operates in a gray area, take advantage of the Commission’s stated commitment to pre-enforcement dialogue. If we misunderstand your business, use that opportunity to clarify. The days when a subpoena was our primary tool of communication are behind us.

I hope my tenure will be marked by a return of the SEC’s Enforcement program to what it was intended to be: a targeted, principled, evidence-based response to conduct that harms investors. This is a necessary component to ensuring that investors continue to have confidence in participating in the world’s finest capital markets.

[1] The Director’s bio is available here. We have also added references to certain cases.

[2] His full remarks are available here.

[3] The DOJ brought a parallel criminal case against thirty individuals; See also, The insider-trading scandal that is rocking M&A law firms.