On February 24, 2026, the Securities and Exchange Commission released an updated Enforcement Manual—its first comprehensive revision since 2017. Bienert Katzman Littrell Williams LLP has analyzed the changes in detail to identify the developments most relevant to individuals and entities facing SEC scrutiny and to whistleblowers considering reporting potential securities law violations.

Key Developments for Those Under Investigation

The 2026 manual introduces several procedural enhancements that benefit individuals and entities involved in SEC investigations. Most notably, the SEC provided additional supervisory oversight for the issuance of Wells Notices, provided clearer timelines for Wells submissions, and additional process that Wells recipients should receive from SEC senior leadership. The 2026 manual will help defense counsel more effectively navigate clients through the Wells process.

For settling parties, the SEC has restored its practice of permitting simultaneous consideration of settlement offers and requests for waivers from automatic disqualifications and other collateral consequences. This change allows respondents to address both liability and the downstream impacts of enforcement actions in a single proceeding.

Key Developments for Whistleblowers

The 2026 manual strengthens whistleblower protections. Staff is reminded that whistleblower information is “highly confidential” and subject to “strict limitations” on disclosure. The manual explicitly prohibits disclosure of any information that could “reasonably be expected to reveal” a whistleblower’s identity and requires staff to consult with the Office of the Whistleblower before sharing information with other agencies that might identify a reporting individual.
These enhanced protections reinforce the SEC’s commitment to confidentiality and should provide meaningful reassurance to individuals considering whether to report potential violations.

For more information, please our comparison table of key SEC Enforcement Manual updates.

Our Commitment

At Bienert Katzman Littrell Williams LLP, we remain dedicated to staying at the forefront of SEC enforcement practice. Whether you are responding to an SEC inquiry, negotiating a resolution, or considering reporting potential misconduct through the whistleblower program, our team is prepared to guide you through the process with the strategic insight that these complex matters require.