SEC Acting Enforcement Director Sam Waldon declared recently that his division is moving “full steam ahead” against those who “lie, cheat, and steal” but also is focusing on quality over quantity. He rejected traditional metrics — case counts, penalty totals and aggregate dollar amounts — as effective measures of the SEC’s enforcement program.
At the 2026 SEC Speaks Conference held last month in Washington, D.C., Waldon and senior enforcement leaders emphasized the division’s commitment to transparency and procedural fairness, as embodied by recent revisions to its Enforcement Manual. The more prominent revisions are intended to foster robust two-way engagement with defense counsel during the Wells process and articulate clearer guideposts for the staff’s assessment of public company cooperation under the Seaboard factors and corporate penalties under the Commission’s 2006 Penalty Statement. Waldon also confirmed that the division will continue to bring non-fraud cases in the right circumstances — with a more thoughtful approach. He said his division aims to distinguish between an entity that makes “an honest mistake, recognizes the mistake, fixes the mistake, takes steps to remediate and improves internal controls” and one that “engages in multiple mistakes, doesn’t think it’s a mistake, covers up the mistake, [and] didn’t take steps to remediate.”
Read on to learn more about Waldon’s remarks and what companies should take away from them.