Within the NASAA community, the Annual Enforcement Report is regarded as one of the association’s most valuable and interesting annual publications. It consistently provides not just raw numbers, but insights into emerging risks and enforcement priorities — making it a report that practitioners, policymakers, and regulators alike look forward to each year.
The newly released 2025 NASAA Enforcement Report, which is based on data collected during 2024, offers a comprehensive look at how state and provincial regulators are tackling fraud and protecting investors.
One change immediately worth noting is in the composition of the Enforcement Section itself. Amanda Senn of Alabama, who had chaired the Section with a pragmatic, consensus-oriented style, has now been termed out. Leadership shifts to Anthony Leone, the Second Deputy Secretary of State and Deputy Secretary for the Securities Division of the Office of the Secretary of the Commonwealth, serving under Secretary William Galvin — one of the few elected securities regulators in the country. That distinction matters. Elected officials often bring different incentives than their appointed peers, with an emphasis on visibility and headline-driven cases. This leadership change could influence not only the priorities of NASAA’s Enforcement Section, but also the tone and intensity with which they are pursued.
1. Enforcement activity remains consistently high.
In 2024, regulators opened 8,833 investigations and brought 1,183 enforcement actions — almost identical to the to 2023. Stability in the raw numbers masks deeper shifts in the nature of cases: more are centered on digital and hybrid frauds rather than purely traditional misconduct.
2. Criminal referrals are rising.
Of the 1,183 enforcement actions, 145 were criminal, 69 civil, and 853 administrative. The increase in criminal matters marks a departure from the heavier reliance on administrative actions in prior years, reflecting regulators’ willingness to pursue more severe consequences when deterrence demands it. In prior years, criminal referrals typically numbered closer to 100, with the vast majority of actions resolved administratively. For example, in the 2023 Report (2022 data), there were roughly 950 administrative actions, 50 civil actions, and 90 criminal actions. In the 2024 Report (2023 data), the mix shifted slightly, with about 1,000 administrative actions, 60 civil actions, and 110 criminal actions.
In 2024, state securities regulators reported that registrants were most commonly investigated for potential violations related to record-keeping, supervision, dishonest or unethical business practices, unregistered activity, and securities fraud. In enforcement actions involving registrants, NASAA’s U.S. members most commonly reported violations involving unregistered activity, recordkeeping violations, failure to supervise, suitability, and dishonest or unethical business practices.
3. Monetary relief declined from 2023.
Regulators secured over $190 million in restitution and nearly $70 million in fines in 2024. While substantial, this is well below the more than $333 million reported in 2023. The drop appears linked to a different mix of cases — fewer legacy frauds with large recoveries and more digital-asset schemes, where clawbacks are difficult.
4. Artificial intelligence is now on the radar.
For the first time, NASAA broke out AI-related matters, documenting six investigations and two enforcement actions. Most involve “AI washing,” where firms falsely claim to use AI in their strategies. Though still small in number, regulators’ decision to track these cases formally shows they expect AI misuse to become a meaningful enforcement frontier.
5. Social media fraud and pig-butchering schemes are exploding.
The report highlights a near doubling of impersonation investigations from 2023 to 2024. Scams using WhatsApp, Telegram, Facebook, and X are now central vectors, and “pig-butchering” has become a staple threat. (Pig butchering is an investment scam where fraudsters gain the trust of victims over time and then deceive them into investing in fake crypto assets or another fraudulent investment opportunity. The term refers to the agricultural practice of fattening pigs before slaughter, symbolizing how scammers “fatten” their victims with false attention before exploiting them financially.)
6. Senior investors remain a prime target.
Regulators received 3,613 complaints from individuals aged 65 and older, leading to 1,652 investigations and 53 enforcement actions. That’s a notable increase from the 2023 report, underscoring both the scale of exploitation and the resources regulators are dedicating to this vulnerable demographic.
7. Real estate investment fraud is rising.
For the first time, NASAA placed real estate alongside digital assets and promissory notes as a top investor threat. This marks a change from prior years, when real estate was less visible in the rankings. Tokenized and fractional property schemes are likely drivers of this increased attention.
8. Data collection is evolving.
The 2025 survey introduced new categories, including recordkeeping violations and unethical business practices. These refinements give regulators and the public more insight into registrant misconduct, but they also complicate comparisons with earlier years. Analysts must be careful not to misinterpret growth that may reflect reporting changes rather than actual increases in misconduct.
9. Registration gatekeeping is gaining emphasis.
Hundreds of registration applications were denied, conditioned, or withdrawn in 2024, and 94 bars or revocations were issued. This preventative enforcement strategy — keeping bad actors from entering the market in the first place — has become more pronounced across successive reports.
10. Leadership dynamics will shape the next phase.
With Massachusetts at the helm of the Enforcement Section, NASAA may lean into a more assertive and high-visibility posture. Galvin’s office has long favored aggressive, headline-driven enforcement, and under its influence the Section could pursue sharper public messaging, aggressive stances on digital assets, and potentially more friction with federal agencies or industry groups.
Final Thought
Fraud techniques are evolving rapidly, from pig-butchering to AI washing, yet the tools of state securities regulation remain consistent: registration, disclosure, supervision, and deterrence. What distinguishes 2025 is not only the nature of the cases, but the leadership style now guiding NASAA’s Enforcement Section.
The leadership changes are not confined to the Section. Whereas NASAA Past-President Leslie Van Buskirk is a twenty-three year veteran of the Wisconsin Department of Financial Institutions and a relatively well-known quantity, we know considerably less about NASAA’s new President, Marni Gibson of Kentucky,
The combination of shifting threats and new incentives at the top means state regulators are likely to approach the coming year with both vigilance and a sharper edge.
