The morning kicked off with Sarah Heaton Concannon moderating an insightful discussion on parallel investigations. Jonathan Barr noted that while DOJ enforcement has been steadily declining for decades, SEC enforcement has increased. Particularly striking was his observation that 25% of FBI white collar agents have been reassigned to cartel work, though SDNY continues searching for resources. Other agencies are stepping in — SEC IG is supporting fraud cases and Postal Inspectors are ramping up financial fraud work.
Alex Koch predicted we’ll see different focuses from the SEC, with parallel investigations continuing but with different partners. He highlighted increased involvement of state AGs, a focus on Chinese issuers, and more OCC debanking cases. Susan Markel reminded the audience that accounting issues and internal control investigations will remain steady, though criminal parallel investigations may decrease while embezzlement work continues. She noted that pre-Enron, selling criminal financial fraud work to DOJ was difficult — now cases that start civil can evolve to criminal when you “poke the bear” of SEC staff.
Source: Key Takeaways from the SEC Enforcement Forum 2025: Insights on the New Era of Securities Enforcement