In November 2018, the SEC published its second annual enforcement report which provides a summary of the SEC’s enforcement-related work during 2018. Although the SEC and FCA hold different remits, it is instructive to consider the SEC report against the annual enforcement report which was published by the FCA earlier in 2018 to identify not only where both regulators have been active in the past but also possible future enforcement trends. Although the two reports are not directly comparable in certain respects (for example, aspects of the content, the periods covered by, and the amount of detail in, the two reports differ), the key similarities and differences are noteworthy, particularly given the multi-jurisdictional and overlapping subject matter of many SEC and FCA investigations.
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