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Consistent with patterns from past administrations, we expect U.S. securities enforcement to accelerate modestly in 2026. The SEC and FINRA will likely focus increasingly on cases about foreign actors, artificial intelligence (AI), and other emerging technologies, alongside traditional areas of enforcement with an emphasis on addressing investor harm. 

The UK regulatory landscape is evolving towards more subject-led enforcement models designed to accelerate investigations and deliver swifter outcomes. Early Account Schemes (EAS), implemented by the Prudential Regulation Authority (PRA) and now contemplated by the Office for Financial Sanctions Implementation (OFSI), allow firms to self-investigate and report misconduct in exchange for the opportunity of enhanced settlement discounts, quicker resolution, and greater visibility and control over the process. While an EAS scheme offers clear benefits, it also raises complex legal and strategic considerations – particularly for financial sector firms facing overlapping regulatory regimes, where a single issue may trigger scrutiny from multiple regulators. Navigating overlapping regulatory regimes requires careful consideration and planning. Choosing to cooperate through an EAS scheme may present additional challenges and risks, particularly where an alleged sanctions breach could expose the firm to potential criminal liability.