The SEC recently announced that Gurbir Grewal (Director of the Division of Enforcement) will depart the SEC on October 11, 2024.
The SEC release touts various enforcement figures during Grewal’s tenure (which began in July 2021) such as “During Mr. Grewal’s tenure, the Division of Enforcement recommended, and the Commission authorized, more than 2,400 enforcement matters resulting in orders for more than $20 billion in disgorgement, prejudgment interest, and civil penalties, more than 340 industry bars against individuals, more than $1 billion in awards to whistleblowers, and the return of billions of dollars to harmed investors.”
But one meaningful enforcement figure is not mentioned.
FCPA enforcement is a “high priority” for the SEC and the SEC has a specialized FCPA unit “to further enhance its enforcement of the FCPA.”
SEC officials, including Grewal, have long talked about the importance of individual accountability – in the FCPA context and for other securities laws violations. As Grewal stated “holding individuals accountable is also critical to our [enforcement] efforts.”
During Grewal’s tenure as Enforcement Director (July 2021 to the present), the SEC brought 20 corporate FCPA enforcement actions.
However, not one involved a related individual prosecution.
Zero. Zilch. Nada.
