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ARTICLE · 12 MARCH 2026

Key Takeaways From The SEC's Revised Enforcement Manual

Jones Day
Jones Day
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The Situation: The Securities and Exchange Commission ("SEC") has revised its Enforcement Manual (the "Manual") for the first time since 2017, implementing critical changes to enforcement policies and procedures.

United StatesCorporate/Commercial Law
Walter W. Davis
Walter W. Davis
Nina Yadava
Nina Yadava
Nekia S. Hackworth
Nekia S. Hackworth
Sarah L. Levine
Sarah L. Levine
James Loonam
James Loonam
Sidney Smith McClung
Sidney Smith McClung
David Peavler
David Peavler
Evan Singer
Evan Singer
Abby Yager
Abby Yager
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In Short

The Situation: The Securities and Exchange Commission ("SEC") has revised its Enforcement Manual (the "Manual") for the first time since 2017, implementing critical changes to enforcement policies and procedures.

The Result: The updated Manual provides meaningful new guidance on the SEC's Wells process, corporate cooperation credit, collateral waiver requests, and criminal referrals. The SEC also commits to review the Manual for updates at least annually.

Looking Ahead: The updated Manual provides greater transparency, consistency, and predictability for those facing an SEC investigation and their counsel, which should lead to more efficient investigations and outcomes for both the agency and those under investigation.

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