The SEC has fined 12 registrants $63.1 million in a new round of settlements under its risk-based initiative (Initiative) to investigate registrants’ preservation of electronic communications on unapproved electronic devices and systems (off-channel communications). As in other settlements under the Initiative, the latest respondents allegedly failed to preserve their employees’ off-channel communications and supervise employees with a view to preventing violation of SEC recordkeeping requirements. Separately, the SEC announced it had commenced a record-setting number of enforcement actions in the first quarter of its 2025 fiscal year, which ran from October through December 2024. This article discusses the increased enforcement activity and the eight new settled enforcement orders. See “26 Firms Fined Nearly $393 Million in Newest Off‑Channel Communications Settlements” (Sep. 26, 2024).