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SEC announces significant updates to enforcement manual

February 27, 2026

On February 24, the SEC’s Division of Enforcement announced numerous revisions to its Enforcement Manual, marking its first significant revision to the manual since 2017. The SEC stated that future revisions to the manual will be posted on an annual basis. Among the highlighted changes are: (i) formalizing the “Wells” process, the SEC’s informal process giving those facing a potential enforcement recommendation a chance to present their position to staff before action is decided; (ii) offering detailed guidance on crafting effective Wells submissions and clarifying timelines to expedite determinations on whether to close investigations or recommend enforcement actions; (iii) restoring the practice of allowing simultaneous consideration of settlement offers and related waiver requests from automatic disqualifications; (iv) outlining frameworks for evaluating cooperation by individuals and companies, including the impact of cooperation on civil penalties; (v) revising procedures for issuing formal orders; and (vi) revising investigative practices to align with current best practices.