Marking the first comprehensive update in eight years, the SEC’s Division of Enforcement (the Division) released a revised edition of its Enforcement Manual (the 2026 Manual). SEC Chairman Paul Atkins called the update a “long-overdue step,” and Division Director Margaret Ryan said the changes are intended to “ensure greater uniformity” and “reflect the Division’s best practices.” Although the 2026 Manual has many changes from the previous version, some will have a greater impact. In this article, we highlight the most significant revisions and discuss their practical implications.

On February 24, 2026, several media outlets reported that the Trump administration is internally considering requiring banks to collect citizenship information from customers as a condition to opening or maintaining a bank account.