The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Wed, 24 Jun 2026 11:32:04 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png SEC Enforcement in 2009: A Year of Changes, with More This Year – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 SEC Enforcement in 2009: A Year of Changes, with More This Year https://corpgov.law.harvard.edu/2010/02/01/sec-enforcement-in-2009-a-year-of-changes-with-more-this-year/?utm_source=rss&utm_medium=rss&utm_campaign=sec-enforcement-in-2009-a-year-of-changes-with-more-this-year https://corpgov.law.harvard.edu/2010/02/01/sec-enforcement-in-2009-a-year-of-changes-with-more-this-year/#comments Mon, 01 Feb 2010 14:36:52 +0000 http://blogs.law.harvard.edu/corpgov/?p=6752?d=20150120104310EST Posted by Eduardo Gallardo, Gibson, Dunn & Crutcher LLP, on Monday, February 1, 2010
Editor's Note:

Eduardo Gallardo is a partner focusing on mergers and acquisitions at Gibson, Dunn & Crutcher LLP. This post is based on a Gibson Dunn client memorandum by Mark Schonfeld, John Sturc, Barry Goldsmith, Eric Creizman, Ladan Stewart, Akita St. Clair, Siham Nurhussein, Matthew Estabrook, Darcy Harris, Jonathan Fortney, Nili Wexler and Karen Grus.

In our 2009 “Mid-Year Review of SEC Enforcement,” we reviewed the transformation that had begun in 2009 at the SEC’s Division of Enforcement under the agency’s new Chairman, Mary Schapiro, and the Division’s new Director, Robert Khuzami, as well as the measurable increase in enforcement activity that had resulted. Since then, Mr. Khuzami has articulated more specifically the changes the he plans to make, some of which are already in effect and others that have yet to be implemented. Nevertheless, the results of the Enforcement Division continue to reflect the heightened enforcement initiative that has been the calling card of this Commission. In this review of enforcement in 2009, we focus on the significant enforcement developments of the second half of the year, as well as notable cases and important trends revealed by annual enforcement statistics, both those disclosed by the SEC, as well as those that result from our own analysis. We also look ahead to the significant developments to anticipate this year.

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