Today’s Focus: Financial Regulation & Compliance
TODAY’S TOP STORY
SEC Posts Lowest Enforcement Year in Two Decades, Signals New Direction
The SEC Division of Enforcement published its fiscal year 2025 results on April 7, revealing just 456 total enforcement actions — the lowest count in at least 20 years. Of those, only 303 were stand-alone actions. While the headline monetary figure was $17.9 billion, nearly $14.9 billion stemmed from a single legacy case filed in 2009, meaning actual new recoveries were far more modest.
Chairman Paul Atkins declared the agency has ended “regulation by enforcement,” and new Enforcement Director David Woodcock takes the helm May 4. For compliance teams, the shift means less enforcement risk in gray areas but no reprieve on core investor protection — fraud, insider trading, and market manipulation remain firmly in scope.
ALSO TODAY
Basel III Endgame Re-Proposal: Comment Period Open Through June 18 — The Fed, OCC, and FDIC jointly re-proposed US bank capital rules that would reduce CET1 requirements by 4.8% for the largest banks and up to 7.8% for community banks — a 20-percentage-point swing from the 2023 proposal. Model your capital impact now and prepare comment letters.
Treasury Issues GENIUS Act AML Proposed Rule — FinCEN and OFAC published a joint proposed rule implementing the GENIUS Act’s anti-money laundering and sanctions compliance requirements for payment stablecoin issuers. Treasury is targeting final rules by July 2026. Review whether your stablecoin operations fall within scope.
FinCEN’s Record $80M Broker-Dealer AML Penalty — Canaccord Genuity was hit with the largest BSA enforcement action ever against a broker-dealer: $80M for willful AML program failures spanning 2018-2024. FinCEN cited insufficient staffing and unreviewed surveillance reports. Audit your SAR filing timeliness now.
DEADLINE ALERT
June 18, 2026 — Comment deadline for all three Basel III Endgame NPRMs (capital rules, large bank output floor, and stress testing adjustments). If your institution hasn’t started drafting comments, begin now.
ONE THING TO DO TODAY
Review your SEC enforcement exposure map. With the agency shifting away from “regulation by enforcement,” now is the time to reassess which compliance gray areas your firm has been treating as high-risk solely because of enforcement threat. Reallocate resources toward the controls that matter most under the new regime.
Next week: Cybersecurity, Data Security & Cloud Security
CyberEyeQ is a daily regulatory intelligence briefing. Not legal advice. Forward to a colleague who needs this.