BRAEDEN ANDERSON
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The SEC’s New Enforcement Manual Signals a Procedural Reset in Securities Enforcement
On February 24, 2026, the SEC’s Division of Enforcement published a revised Enforcement Manual. This article is a clean-room, original discussion of the press release and the 2026 Enforcement Manual. It is also meant to sit naturally inside the enforcement “throughline” I have been building on Anderson Insights: the idea that enforcement outcomes are increasingly driven by (i) data and surveillance sophistication, (ii) procedural architecture, and (iii) the downstream consequences of resolutions, often more than the headline penalty itself.
About the Author - Braeden Anderson is a partner at Gesmer Updegrove LLP, where he leads the Securities Regulatory and Enforcement and Digital Assets practice areas. Prior experience includes roles at Robinhood Markets, Inc., Kirkland & Ellis LLP, Sidley Austin LLP, Anderson P.C., and FINRA. He’s been nationally recognized by Best Lawyers in America: Ones to Watch® for Financial Services and Securities Regulation, and listed in Marquis Who’s Who in America for contributions to law and public service.