Welcome back to the Compliance In Context podcast! On today’s show, we will be providing a comprehensive, deep-dive look at SEC Enforcement over the last twelve months—including the real story behind some of the recent numbers, distinct areas of focus, and what we’re hearing from the Paul Atkins-led SEC. To help guide us through this important topic and share some fantastic insights for our listeners, we welcome in two expert panelists (and accomplished podcasters), Andrew Dean from Weil Gotshal and Kurt Wolfe from Quinn Emmanuel.

Show

Interview with Andrew Dean and Kurt Wolfe

• Review of SEC Enforcement metrics over the last twelve months
• What are we hearing from the SEC and Chair Atkins?
• Reviewing the takeaways from Atkins’ recent statements on the Wells process
• What are we hearing from the other Commissioners?
• How have the cuts and departures impacted SEC Enforcement? What typically happens during a transition? Are their programmatic impacts?
• Understanding key differences between the Division of Exams and the Division of Enforcement
• How are SEC exams being resolved in the current environment?
• How are firms interacting with the Staff right now?
• What can we expect next in the area of SEC Enforcement?

Quotes

05:11 – “So, you know, the SEC's fiscal year runs October 1 through September 30, and we don't have the final numbers yet from that period. Our friends at Cornerstone always put out a nice report at the end of the year that kind of, you know, tell the story. It will be a little complicated by the fact that this fiscal year was over the course of two commissions that have relatively different approaches to enforcement. And so the first three and a half months of the fiscal year were under Chair Gensler, and the remaining were under interim chair Uyeda, and then Chair Atkins. You know, it’s clear that the enforcement actions are dramatically lower under the Atkins Commission. If we just look at the period, this is our friends at King and Spaulding putout this, and we’re giving a lot of credit to others who have, kind of, done the math for us. Between February and July of 2025 there were 67 enforcement actions. Compare that to 198enforcement actions during the same time period in 2021 when there was another Commission transition.” – Andrew Dean

20:25 – “They should focus on cases where there's a lot of harm to investors or potential harm to investors and not just technical violations, not foot faults. I think many would say that's a different tone or strategy than what we saw in the last administration. He even went out of his out of his way to say, SEC enforcement should never feel like a gotcha game. My third point would be transparency and predictability. I think, again, this is sort of consistent with what we've heard from Chairman Atkins, you know, back when he was a commissioner even, he thinks enforcement action should be consistent. The results should be fairly predictable and tied to SEC policies and coordinated across the divisions.” – Kurt Wolfe

Welcome back to the Compliance In Context podcast! On today’s show, we will be focusing on the impact of mentorship on compliance, and how as mentors and mentees, we can become the best version of our compliance-selves. To help guide us through the conversation, we are very pleased to welcome back to the show, attorney and former regulator (and insightful mentor), Richard Szuch. In our Headlines section, we look a notable decline in SEC enforcement actions in 2025 and review the recently announced rulemaking agenda for the SEC in upcoming months,, and finally, we close up today with another installment of Outtakes, where we see continued focus from SEC Enforcement on the Marketing Rule and accurate disclosure of conflicts of interest.

Show

Headlines

• SEC enforcement actions drop sharply, with focus shifting to investor fraud.
• US SEC unveils agenda to revamp crypto policies, ease Wall Street rules

Interview with Richard Szuch

• How has mentorship shaped your career as a legal and securities compliance professional?
• Reviewing the importance of mentoring and mentorship in compliance
• Understanding the benefits received from mentorship for both the mentee and the mentor
• What were some of the lessons that you received early on as either a mentee or mentor that inspired you in this area?
• What are three questions every compliance professional should ask themselves?
• How does mentorship impact the overall productivity of a compliance team?
• How to find professional fulfillment in your legal/compliance role
• For those that are considering taking on a role as mentor or mentee, what additional advice or words of encouragement would you give them?

Outtakes

• SEC Charges RIA with Marketing, Books and Records, and Compliance Rule Violations

Quotes

16:00 – “Like at the prosecutor’s office. I remember John O’ Reilly saying to me once, ‘Richard, you do not need to be smart enough to know the answer to every question, but you do need tobe smart enough to know when to ask a question.’ And I think the same goes true with navigating with the people you work with.” - Richard Szuch

28:06 – “There is the law, there are the facts, and then there’s the application of judgement to what those facts mean in the legal construct. Same exact thing in compliance. There are the regs. There is the activity, you know, going on, there’s maybe not a bright line answer, and that’s when, you know, having help from older folks or people more experienced than you is really what you’re looking for, or at least as experienced as you.” - Richard Szuch

Welcome back to the Compliance In Context podcast! on today’s show, we will be tackling one of the most significant topics being discussed so far in all of 2025, namely cryptoassets and the SEC’s Crypto Task Force. To help guide us through the conversation, we are very pleased to welcome back to the show, SEC Commissioner Hester Peirce. As the head of the task force, Commissioner Peirce shares her unique perspective regarding specific focus areas, collaboration with the industry, and other notable items from the first of 2025. In our Headlines section, FinCEN recently announced that the compliance date for the AML Rule for investment advisers is being delayed by two years, and finally, we close up today with another installment of History Has Your Back, where the story of a famous stockbroker and humanitarian demonstrates the importance of unsung heroes.

Show

Headlines

• Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that the compliance date for the anti-money-laundering rule for investment advisers is being delayed by two years.

Interview with SEC Commissioner Hester Peirce

• Background on the SEC’s Crypto Task Force
• What areas has the Task Force been focused on of late?
• Has there been additional collaboration with the industry?
• How will the area of issuance evolving over the next few years and how can the SEC establish itself as a leader in this space both domestically and internationally?
• Why is the issue of custody so challenging in the crypto space?
• How might self-custody be a safer option for some crypto assets?
• How will the issue of taking self-custody of crypto assets evolve over the next several years?
• Is there an expectation that broker-dealers will go to market with a “super app” that offers trading in securities and non-securities and other financial services all under a single roof?
• Do you think further guidance or rulemaking may be helpful for enabling the listing and trading of crypto assets on national securities exchanges?

History Has Your Back

• Famous stockbroker Nicholas Winton demonstrates the significance and impact of unsung heroes

Quotes

11:35 - “Well, I’m glad that you highlighted Chairman Atkins’ speech because he has taken a position which has just been really refreshing for me to see, which is that this is work that we can do. It’s work that we should be doing and we’re going to do this work. And really setting the tone for wanting to create a welcoming atmosphere for innovation, but also recognizing that there are areas where our existing regulatory framework touches upon crypto and we have to apply it. Now, we do also have a lot of authority from Congress already to use exemptions as necessary to provide relief from regulatory obligations when that makes sense to do that. And so I think with respect to issuance specifically, we do think that a rulemaking would be helpful.” – Hester Peirce

19:13 - “I should say that self-custody, that term can mean different things, right? I think someone with crypto assets—does that advisor need to go to a third party custodian or can that advisor hold those crypto assets itself? One reason may be that there isn’t a third party that’s out there that’...