In its Enforcement Results for Fiscal Year 2025, the SEC noted that it had made a necessary course correction in its approach to enforcing the federal securities laws in the context of crypto assets and singled out seven crypto-related cases the agency now views as a "misinterpretation" of the federal securities laws. As an extension of this sentiment, Q1 2026 crypto enforcement activity was focused on dismissing prior cases rather than bringing new cases. In March, the SEC dismissed the 2024 enforcement action against Nader Al-Najo and relief defendants for perpetrating a multi-million-dollar fraudulent crypto asset scheme involving a social media platform called BitClout and its native token. This dismissal follows a pattern under the SEC’s new leadership of scaling back on its "regulation by enforcement" approach toward crypto, including similar actions against other firms. The dismissal does not mean that original allegations were unfounded but indicated that the agency lacked sufficient evidence to succeed. (See https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26499.) In January, the SEC dismissed the 2023 enforcement action against Gemini Trust Company, a cryptocurrency exchange founded by Tyler and Cameron Winklevoss, after investors in its lending program recovered their assets in full through the Genesis Global Capital bankruptcy process between May and June 2024. The SEC noted that it took into account the “100 percent in-kind return of Gemini Earn investors’ crypto assets,” as well as state and regulatory settlements involving Gemini related to the Gemini Earn program. (See https://www.sec.gov/enforcement-litigation/litigation-releases/lr-26465.)