Key Takeaways

  • David Woodcock, a partner at Gibson Dunn & Crutcher and a former U.S. Securities and Exchange Commission (SEC) official, will return to the agency next month to lead its enforcement division. The SEC announced the appointment on Wednesday.
  • Woodcock, who currently chairs Gibson Dunn & Crutcher's securities enforcement practice group, will officially assume the role on May 4, succeeding Margaret "Meg" Ryan, who resigned last month. Sam Waldon will continue as acting director of enforcement until Woodcock arrives.
  • SEC Chairman Paul Atkins said in a statement: "I am deeply gratified that David is returning to the SEC at this critical time. We will continue to focus on the types of misconduct that cause the greatest harm to investors."

In-Depth Analysis

In a 2023 commentary, Woodcock criticized the approach to securities law enforcement under former SEC Chairman Gary Gensler as "regulation by enforcement."

"This reckless approach was part of an aggressive and expansionist regulatory mindset that kept parties regulated by the Commission in a constant state of high alert," Woodcock wrote at the time.

"Because while pushing the boundaries of enforcement, the SEC was also engaging in historic rulemaking at a breakneck pace," Woodcock added.

Woodcock's views align with Atkins' criticism of SEC enforcement during the Gensler era.

"Over the past year, the Commission has halted the practice of 'regulation by enforcement' and refocused enforcement efforts on the Commission's core mission, prioritizing cases that provide tangible investor protection and enhance market integrity," Atkins said in a statement on Tuesday.

"We have redirected resources toward the types of misconduct that cause the greatest harm to investors—especially fraud, market manipulation, and breaches of fiduciary duty—rather than the old approach that prioritized case numbers and record fines over substantive investor protection," Atkins said.

According to SEC data, in fiscal year 2025, the SEC's fines and investor relief amounts doubled to $17.9 billion, including $7.2 billion in civil penalties and $10.8 billion in disgorgement.

The SEC stated that the aggressive enforcement approach during the Biden administration was the primary reason for the surge in fines.

"In recent years, enforcement resources were misused to chase media headlines and inflate numbers, which in turn created false expectations about what constitutes effective enforcement," the SEC said.

Under Atkins' new approach, SEC enforcement will focus on combating securities fraud, curbing abusive securities trading practices, and applying "prudent" regulation to crypto assets.

"A key part of this corrective action is re-emphasizing accountability for individual wrongdoers, which helps enhance deterrence and better protect investors," Atkins said.

According to a report released last month by Cornerstone Research, the number of accounting-related class action lawsuits filed by the SEC last year decreased by 40% compared to 2024, reaching the lowest level in more than two decades.

Meanwhile, Cornerstone noted that settlement amounts in accounting-related securities class actions hit a five-year high, accounting for more than 50% of all settlement amounts in 2025.

The SEC stated that during his time in private practice, Woodcock recently focused primarily on regulatory enforcement, internal investigations, and corporate governance.

According to his LinkedIn profile, before joining Gibson Dunn & Crutcher, he served as assistant general counsel at ExxonMobil from 2020 to 2023.

The SEC stated that during his tenure leading the SEC's Fort Worth Regional Office from 2011 to 2015, Woodcock "oversaw investigations in nearly every major area of the SEC's enforcement program" and served as a member of the agency's Enforcement Advisory Committee.

The agency also stated that Woodcock created and led the Financial Reporting and Audit Task Force, which was designed to detect and prosecute accounting violations and false financial statement cases.