Category Archives: Enforcement News

Enforcement Division Director Woodcock Articulates Priorities

On May 13, 2026, in Remarks at the MFA Legal & Compliance 2026 Conference, newly appointed Enforcement Division Director David Woodcock discussed his approach to leading the Division.  Early in his remarks Director Woodcock stated:

“Simply put, my role is to ensure that our staff are empowered, supported, and equipped to execute the Commission’s mission. I intend to provide hands-on leadership that allows our teams to focus on the fundamentals – the blocking and tackling if you will, with professionalism, efficiency, and fairness.”

He then discussed his overall enforcement philosophy:

“As a matter of first principles, my goals are aligned to those of Chairman Atkins: to return the enforcement program back to basics. That means vigorously protecting investors and safeguarding markets, while also providing transparency and certainty to those we regulate.”

In the next section of his remarks, he discussed several types of fraud and manipulation:

  • Offering frauds,
  • 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.

In a deeper discussion of accounting and disclosure fraud, he outlined these recent actions with a focus on the individuals involved in each case:

“We are also prioritizing financial reporting matters that are important to ensure good corporate accounting and disclosures. For example in early 2026, we brought actions against a large agricultural processing and commodities trading company and three former executives for allegedly inflating the performance of a key business segment touted as an important growth driver. In another matter, we settled with a manufacturing company that we alleged violated the internal accounting controls and books and records provisions related to false entries in its inventory system and adjustments it made after reversing the improper income from those entries. In addition, we settled with two of the company’s executives for allegedly causing the violations. And in a third case, we settled with a public company and charged three of its former executives with allegedly making repeated false and misleading statements in public filings and financial statements to conceal unfavorable information about the company’s management and operations.”

As always, your thoughts and comments are welcome!

A Different Twist in Whistleblower Protection Enforcement

On January 16, 2024, the SEC announced a settled enforcement action against J.P. Morgan Securities LLC (JPMS) for violating whistleblower protection laws.  As you can read in this post, we have blogged on a number of occasions about companies that have violated these laws by trying to restrict current and former employees from blowing the whistle.  JPMS’s case involves a very different situation, trying to restrict a customer’s ability to blow the whistle.  When advisory clients and brokerage customers received a credit or settlement of over $1,000 from JPMS, the company required them to sign an agreement to keep the details of the settlement and other information confidential.  While the agreements permitted clients to respond to SEC inquiries, they limited their ability to blow the whistle to the SEC.

In the Press Release announcing the settlement, Enforcement Division Director Gurbir S. Grewal noted:

“For several years, it (JPMS) forced certain clients into the untenable position of choosing between receiving settlements or credits from the firm and reporting potential securities law violations to the SEC.”

You can read more about the settlement, in which JPMS entered into a cease and desist order, paid a $18 million fine and was censured, in the related Press Release and Order.

As always, your thoughts and comments are welcome!