When SEC director of the Division of Enforcement Margaret Ryan addressed the Los Angeles County Bar Association last week, her remarks gave a clear indication of how the SEC’s enforcement arm intends to operate under her leadership and under the broader direction of chairman Paul Atkins.
Ryan, who assumed the role in September 2025, confirmed that enforcement priorities remain rooted in the enforcement of federal securities laws, but revealed a renewed focus on resource constraints and a change in philosophical approach at the SEC. In her own words, ‘reports that enforcement work at the SEC has been tossed to the wayside are not only greatly exaggerated but flat out wrong.’
At the same time, she made it clear that she weighs the quality and impact of enforcement actions more than sheer volume, emphasizing that finite resources must be used ‘judiciously’ where they will ‘most effectively and fairly be used to protect investors and our capital markets’.
‘Judge Ryan’s remarks should be taken at face value; she is precise in her language and intent and reading her comments through the lens of any preferred narrative risks distorting their meaning,’ Freshfields partner and former SEC official Melissa Hodgman told Governance Intelligence. ‘She expressed deep respect for the enforcement staff and highlighted process enhancements likely to be formalized in an updated enforcement manual, reflecting the discipline and fairness that have defined her service as a judge, a military officer and a public servant.’
Under Ryan’s leadership, the enforcement division is prioritizing three main areas. First, it remains committed to identifying and prosecuting classic fraud schemes that cause real investor harm.
Specifically, Ryan echoed Atkins’ own rhetoric about going after the ‘liars, cheats and thieves’, focusing on scams that target US retail investors. The division will also continue to pursue cases involving accounting fraud, insider trading, wash trading and market manipulation, ensuring that improper conduct does not distort market prices or undermine integrity.
Second, Ryan highlighted that enforcement of compliance with other federal securities requirements remains important. This includes public companies’ obligations to maintain accurate records and adequate internal controls, as well as broker-dealers’ and investment advisers’ duties to adhere to fiduciary standards and financial responsibility rules. Though she acknowledged that not all violations of these provisions rise to the level of enforcement actions, she signaled a willingness to bring cases where such failures threaten investors or market integrity.
Ryan also spent considerable time on process, underscoring a commitment to transparency and fair opportunity for respondents in enforcement investigations. She detailed enhancements to the Wells process – the mechanism by which potential defendants are notified of contemplated charges – noting that recipients now have a four-week window to explain why an action should not be authorized and are often granted meetings with division leadership.
‘Far from signaling any pullback, enforcement activity appears to be strengthening as staff gains clearer alignment on priorities and direction. Her message reinforces the Commission’s tripartite mission – protecting investors, maintaining fair and orderly markets and facilitating capital formation – with investor protection unequivocally at the forefront. The themes she articulated are entirely consistent with her longstanding commitment to principled, rigorous and law‑focused public service,’ said Hodgman.
These enforcement priorities sit within a wider switch under Atkins’ chairmanship towards what many have called a ‘back-to-basics’ approach. He has publicly signaled a move away from aggressive novel theories of liability and expansive technical violations, instead championing enforcement grounded in traditional fraud and clear investor harm.
The alignment between Ryan’s enforcement priorities and Atkins’ broader regulatory philosophy is evident. Both leaders emphasize investor protection through targeting clear wrongdoing, safeguarding fair markets and deploying limited resources in ways that maximize impact. But the question remains: how will a renewed focus on foundational securities laws shape market conduct?