The SEC’s focus on registrants’ practices for monitoring and preserving employee communications on unapproved devices and systems continues unabated. In the latest round of settlements under its Initiative to Investigate Off-Channel Communications at Registered Entities (Initiative), the SEC has imposed nearly $393 million in civil penalties on 26 firms that failed to preserve employees’ electronic communications and supervise employees with a view to preventing violation of the recordkeeping requirements under the Investment Advisers Act of 1940 and/or the Securities and Exchange Act of 1934. As in most other recent resolutions under the Initiative, 25 of the respondents have agreed to retain an independent compliance consultant to review their electronic communications policies, procedures and practices. This article discusses the new settled enforcement orders and an associated order waiving “bad actor” disqualification. For more enforcement actions resulting from the Initiative, see “16 Firms Fined $81 Million in Latest SEC Electronic Communications Recordkeeping Settlements” (Apr. 11, 2024).