How long enforcement cases take
Across 622 records with a measurable span, the median from filing to the latest recorded resolution is about 1.6 years, against 0.24 years on the 85 records timeable before the 4 October 2026 status rounds. Of the 733 records once marked "filed", 543 now have an outcome and 190 remain filed; 190 is a ceiling on truly pending cases.
After the 4 October 2026 status rounds, 622 of the library’s 2,428 case records carry two different dates that let anyone time a case from filing to a recorded end. Among them the median is 1.60 years, about 19 months, with the middle half running from 0.82 to 2.81 years. The first version of this post found only 85 such records and a median of 0.24 years, because 733 records then had no outcome at all. A hand-checked random sample of 100 of those 733 had suggested most had in fact ended; two full research rounds have since confirmed it: 543 of the 733 (74%) now have a settled, judgment or dismissed status and 190 remain “filed”. The 190 is an upper bound on truly pending cases: 122 were checked and no outcome was recorded (some because pages could not be fetched) and 68 were not reached.
How it was measured
A Node script, scripts/analysis/time-to-resolution.mjs, reads every case file and prints every number below. It
runs in two parts, and the figures are as of the evening of 2026-10-04, after two status rounds and the flag corrections.
What changed in the inputs. Earlier on 4 October, 733 records had status “filed”. AI agents then researched them in
two rounds and set a status for 543 (295 settled, 232 judgment, 16 dismissed), a resolution date, and often money fields and
timeline events. The other 190 remain “filed”. Outcomes often cover only some defendants, and the record narratives
say so. The original list of 733 slugs is frozen in scripts/analysis/time-to-resolution-filed-733.json.
Part 1, the records that can be timed. Of 2,428 records, 1,450 have a resolution date equal to the filing date (mostly SEC orders instituted and settled the same day), 346 have no resolution date, and 632 have a resolution date that differs. Ten of those 632, all SEC litigation releases, show a resolution a few days before the recorded filing date. In those records the “filed” date appears to be the release date, so they were left out, leaving 622. The status rounds supplied the date for 538 of them; 84 were already dated. A second measure, filing to the latest dated event in a record’s timeline, covers 677 records with two or more events. It agrees closely (median 1.58 years) and 617 records appear in both, so it is not an independent check. The figures use calendar days divided by 365.25.
Part 2, the “filed” records, in two stages. The first stage is the original test and is kept as the account of how this was found. The script sorts the 733 slugs, shuffles them with a fixed seed (20261004) and takes the first 100, printing the list so anyone can redraw it. Five Claude AI agents each took 20 and looked for how the matter ended, first in the cached regulator documents and then on the regulator’s own site or a court record. The allowed answers were settled, judgment, dismissed, still pending, or could not find. I opened three of the sources myself (CFTC release 8467-21, the SEC Lek Securities release and the Darvasi final judgment) and all three said what the agent reported. No lawyer reviewed any of this. Where a matter had several defendants the outcome is the lead defendant’s. Intervals are Wilson 95% intervals. The second stage is the full round described above, whose result is read straight from the case files.
What it shows
Timing, among the records that can be timed. Half took under 1.60 years, a quarter took more than 2.81 years, and the longest, an SEC insider-trading case, 10.6 years. 195 records (31%) were resolved within a year and 39 (6%) took over five years. Without the slowest tenth (63 records) the median is 1.48 years and the mean falls from 2.03 to 1.60.
Settled and judgment records are close: 1.57 years against 1.69, so the earlier finding that settlements ran a week against five months for judgments no longer holds. It came from a set dominated by Ontario consents. The SEC (1.77, n = 439), CFTC (1.77, n = 81) and ASIC (1.62, n = 34) medians are close to each other. Records with a criminal parallel (296) took longer than those without (326): 2.00 against 1.29 years. Both groups mix short and long cases, and the data cannot show cause. Dismissals (18, median 1.42) are few, and appeals (1) and unknowns (2) too few to say anything.
Why the first figure was so low. 68 of the 622 are Ontario, with a median of 0.21 years; excluding them the median is 1.75 years (n = 554). Before the status rounds, 84 records had a later resolution date, and their median was 0.25 years, 68 of them Ontario. The 538 dated by the rounds have a median of 1.75 (middle half 0.99 to 2.97). The earlier “0.24 years” was a statement about the Ontario records, not about US or UK enforcement. The data still skews: of the SEC’s 1,860 records, 1,182 have a same-day resolution, 229 none and 449 a different date, and all 48 FCA records are same-day, so none can be timed.
Is the resolution date really a resolution date? Not always. For the 538 records dated by the rounds with a later resolution date, I read the timeline event on that date. In 53 (10%) the wording is of an announcement or publication (“CFTC announces a consent order”, “published 13 January 2022”), 28 CFTC, 23 SEC and 2 ASIC; in 18 (3%) it gives only the announcement and no entry or order wording. Since the order or judgment usually precedes its announcement, these dates may overstate the span by the gap, typically days to weeks but occasionally longer. Those 53 have a median of 1.65 years against 1.77 for the other 485, so they do not drive the result. Some other records, where an event text does not say, may also carry an announcement date; I could not tell. So treat 10% as the share I could see and the true share as uncertain. The multi-defendant effect points the other way: the date is often that of the last defendant’s outcome, which lengthens the span.
What happens to the “filed” records. First the sample of 100, hand-checked:
The 71 that had ended are 71% of the sample (interval 62% to 79%). Scaled to 733, that suggested roughly 450 to 580 with an out-of-date status, about 520 at the midpoint. Among the 77 records where something was found, 92% had ended (interval 84% to 96%). Six were pending and 23 untraced. By agency the sample has 81 SEC, 15 CFTC and 4 ASIC records, which follows the filed group’s mix and is too thin to compare agencies.
Then the two full rounds, which updated the data itself:
543 of the 733 (74%) are now resolved, inside the sample’s interval (62% to 79%), and 190 (26%) remain filed: 157 SEC, 30 CFTC and 3 ASIC. By agency, 157 of 589 SEC records (27%), 30 of 107 CFTC (28%) and 3 of 36 ASIC (8%) are still filed; the one Ontario record is resolved. Of the 190, 122 carry the 4 October review date, meaning the rounds looked at them and recorded no outcome (the status-resolution agents’ notes say this was mostly blocked fetching or nothing found, which I did not re-audit), and 68 were not reached. So 190 is an upper bound on the truly pending, not a count of live cases. I have not checked how many of them have in fact ended.
Cross-check against the sample: 75 of the 100 sampled records are no longer filed. Of the 71 the hand check found ended, 70 are now resolved and 1 is still filed in the data. Of the 23 the hand check could not trace, 5 now have an outcome. Among the 70, the status label matched the hand-found outcome in 63.
What this does not show
- Selection. These are cases regulators chose to bring and publish. Matters closed without a public step, or never announced, are not here, and the speed of a published case says nothing about enforcement in general.
- Timing is still biased toward finished, documented cases. A record needs a second date to be timed, so a case still open, or never followed up, is invisible to Part 1. With 190 records untimed because still filed, the 1.60-year median is not an estimate of how long a typical case takes; open cases, being longer so far, would probably raise it.
- The resolution date is not always a resolution date. It can be an announcement date (53 records show that wording, 10% of the 538), a release date (10 SEC records have it before filing), or the last defendant’s outcome in a multi-defendant matter.
- A sample of 100, then an unaudited round. The sample’s shares carry wide intervals and the agent-found outcomes are only as good as the pages opened. The full round was not independently checked either, and “filed” for 190 means “no outcome recorded”, not “pending”.
- Outcomes often cover only some defendants. Where the status says settled or judgment, other defendants may have ended differently or not been checked. The two Lek Securities records in the library describe one case.
- Checked by AI agents, not lawyers. The library’s records were read by AI agents on 2 and 3 October 2026, the sample and the status rounds on 4 October the same way. A court outcome found on a regulator’s page is a regulator’s report of it, not the docket itself.
If you find a record whose status is wrong, use the error link on its page.
Cases referenced
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| OSC v. Paramount Equity Financial Corporation and others (2019) | OSC | 2019-03-29 | — | judgment | |
| OSC v. Christopher Candusso and others (insider trading, 2018) | OSC | 2018-11-23 | Insider Trading | — | judgment |
| CFTC v. Cohen (Yukom Communications, rigged binary options execution, 2024) | CFTC | 2019-08-12 | Rigged Binary Options Execution | — | settled |
| SEC v. Ariel Darvasi and Amir Waldman (insider trading, 2017) | SEC | 2017-03-24 | Insider Trading | $1.5m | settled |
| CFTC v. Roman Banoczay Jr., Roman Banoczay Sr. and BAZUR Spol. S.R.O. (spoofing, 2020) | CFTC | 2020-09-29 | Spoofing | $750k | settled |
| SEC v. Justin Sun et al. (paid stock promotion, 2023) | SEC | 2023-03-24 | Paid Stock Promotion , Unregistered Distributions +1 | $10m | settled |
| SEC v. William J. Milles, Jr. and Donald J. Lutzko (ponzi schemes, 2019) | SEC | 2019-07-18 | Ponzi Schemes | $414k | judgment |