SEC Announces Departure of Enforcement Director Gurbir S. Grewal; Sanjay Wadhwa Named Acting Director, Sam Waldon Named Acting Deputy Director
On October 2, 2024, the Securities and Exchange Commission (SEC) announced the departure of Gurbir S. Grewal, Director of the Division of Enforcement, effective October 11, 2024. Following his departure, Sanjay Wadhwa, the current Deputy Director of the Division, will step into the role of Acting Director. Meanwhile, Sam Waldon, Chief Counsel of the Division, will assume the position of Acting Deputy Director.
Gurbir S. Grewal’s Legacy at the SEC
During his three-year tenure, Mr. Grewal made significant strides in bolstering investor trust and enhancing market integrity through a series of aggressive enforcement initiatives. Under his leadership, the SEC’s Division of Enforcement pursued more than 2,400 enforcement matters, securing over $20 billion in disgorgement, prejudgment interest, and civil penalties, and delivering meaningful outcomes for harmed investors. Mr. Grewal’s tenure was marked by a focus on recalibrating penalties to act as true deterrents rather than just the cost of doing business and holding gatekeepers—including auditors and corporate officers—accountable for their roles in securities law violations.
In his farewell statement, Mr. Grewal expressed gratitude for the opportunity to lead the Division, highlighting the dedication of its staff and the robust enforcement program developed under Chair Gary Gensler’s leadership. He noted that the Division’s work was critical in addressing emerging risks and safeguarding investors across a wide range of cases, from the crypto industry to insider trading and private fund misconduct.
A Look Back: Key Achievements During Grewal’s Tenure
Mr. Grewal leaves behind an impressive track record of enforcement actions and regulatory accomplishments. Among the notable achievements during his time as Enforcement Director:
Crackdown on Crypto Industry Noncompliance: The SEC brought over 100 enforcement actions against various participants in the rapidly evolving crypto industry. These actions included charges against some of the world’s largest crypto asset trading platforms for operating outside the boundaries of federal securities laws, depriving investors of necessary protections.
Strengthening Gatekeeper Accountability: Grewal’s tenure saw a heightened focus on gatekeepers—such as auditors and compliance professionals—who enabled misconduct. The Division pursued actions against several audit firms, including a massive fraud case affecting more than 1,500 SEC filings, one of the largest ever wholesale failures by an audit firm.
Recordkeeping Initiative: The SEC’s proactive recordkeeping initiative, launched in December 2021, resulted in charges against more than 100 firms and over $2 billion in penalties. These cases highlighted deficiencies in maintaining and preserving electronic communications, a critical compliance area for regulated entities.
Insider Trading and Market Integrity: The Division continued to aggressively pursue insider trading and other forms of market manipulation. Landmark cases during this period included enforcement actions against insiders who abused access to material non-public information (MNPI), as well as firms that failed to maintain appropriate controls to prevent such misconduct.
Protecting Investors in Private Funds: Under Mr. Grewal’s guidance, the SEC brought numerous actions to protect investors in private funds from manipulative practices, inadequate disclosures, and conflicts of interest, demonstrating a commitment to safeguarding investors across the financial ecosystem.
New Leadership: Sanjay Wadhwa and Sam Waldon
Sanjay Wadhwa, a seasoned enforcement professional with over two decades at the SEC, will step into the role of Acting Director. Mr. Wadhwa has served as Deputy Director of the Division since August 2021, where he worked closely with Mr. Grewal to advance the Division’s agenda. His extensive experience includes leading the SEC’s New York Regional Office in several high-profile cases, including enforcement actions against hedge funds and prominent Wall Street figures such as Raj Rajaratnam and Steven A. Cohen.
Joining Mr. Wadhwa in the leadership transition is Sam Waldon, who will serve as Acting Deputy Director. Mr. Waldon has been the Division’s Chief Counsel since March 2022 and brings a wealth of experience from both the public and private sectors. Before joining the SEC, he was a partner at Proskauer Rose LLP and previously served in various roles within the SEC’s Division of Enforcement.
What’s Next for the SEC’s Enforcement Program?
The departure of Mr. Grewal marks a new chapter for the SEC’s Enforcement Division. With Sanjay Wadhwa and Sam Waldon at the helm, the Division is well-positioned to continue its rigorous enforcement efforts and maintain its focus on emerging issues, such as digital assets and ESG disclosures, while building on the strong foundation laid by Mr. Grewal.
The transition in leadership is unlikely to alter the SEC’s aggressive approach to market oversight and investor protection. Both Wadhwa and Waldon have been integral to the Division’s operations under Grewal’s leadership, and their deep institutional knowledge and enforcement expertise will ensure continuity in the Division’s priorities.
The SEC’s enforcement efforts have a profound impact on market behavior and investor confidence. As new challenges and risks emerge, the Division’s leadership team will play a crucial role in shaping the agency’s responses and continuing to safeguard the integrity of U.S. financial markets.
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