Wolters Kluwer analysis finds federal regulatory enforcement remains at historic lows as states and private litigants attempt to fill accountability void
Slight decline in overall violations underscores continued selective federal action and a patchwork state response shaped by differing priorities
While total violations remained relatively flat at 132 in the second half of 2025, enforcement activity had already declined significantly earlier in the year. The combination of limited federal supervision and lower penalties is reshaping the compliance landscape, increasing reliance on state regulators and private litigation.
“Fewer federal actions paired with dramatically lower penalties weaken traditional deterrence signals,” said
Key findings
Consumer protection violations
- 69 violations, down from 95 in H1 2025
- 61% decline in penalties
- Only one federal action; the remainder driven by states or private litigation
Financial violations
- 51 violations, up from 35 in H2 2024
- 89% decline in penalties
- Federal actions fell from 45 in H2 2024 to just five in H2 2025
Competition-related offenses
- Enforcement doubled from a low base
- Penalties declined 66%
State regulators and private litigants fill the gap
As federal rulemaking and enforcement continue to recede, state authorities and private plaintiffs played an increasingly prominent role in shaping compliance risk.
“The balance has fundamentally shifted,” Ross said. “Firms operating across multiple states are now navigating dozens of enforcement regimes instead of a single federal standard—making compliance more complex and less predictable.”
Ross added that the shift appears structural rather than temporary, particularly as states step up enforcement efforts in response to the federal pullback.
Powered by Wolters Kluwer’s proprietary enforcement database, third‑party data sources including GoodJobsFirst.org, and AI‑driven semantic analytics, the Regulatory Violations Intelligence Index helps compliance professionals anticipate regulatory shifts, benchmark risk exposure, and allocate resources more effectively. Third‑party data is augmented through proprietary analysis capturing enforcement actions from key supervisory bodies such as the CFTC,
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