SEC Enforcement Sweep Targets Companies and Insiders for Late Filings under Section 16 and 13(d), (g), and (f)

The SEC’s fiscal year is winding down, and once again, we are seeing what is becoming a predictable, if not formalized, year-end tradition: a broad Enforcement sweep targeting companies and insiders for failing to meet timely filing requirements under Sections 16(a), 13(d), 13(g), and 13(f) of the Exchange Act. This year, 23 respondents—both corporate entities and individuals—were charged for violations stemming from late short-swing trading reports (Forms 3, 4, and 5) and beneficial ownership reports (Schedules 13D and G). Penalties ranged from $10,000 to $750,000, totaling more than $3.8 million. The SEC’s use of data analytics to identify these reporting failures continues to demonstrate the agency’s commitment to leveraging technology to enforce even technical compliance obligations.