On February 24, 2026, the SEC Division of Enforcement (“Division”) released the first updates to its Enforcement Manual (“Manual”) since 2017. The updates—which the SEC characterized as underscoring its “ongoing commitment to fairness, transparency, and efficiency in the investigations conducted by the Division”—are an important window into the Division’s expected approach to investigations and will influence strategic decision-making by respondents and their counsel. While many early commentators have described the changes as significant, the revisions are better understood not as a sharp break from the past, but as a formalization of approaches the Division has employed in recent years with targeted enhancements layered on top.
March 3, 2026
