Tom Gorman examines the new direction laid out for the SECs Enforcement Program by Chairman Clayton, trends emerging as the new year begins and significant challenges the Division will face. Emerging trends include the declining number of actions being brought along with a continuing drop in those cooperating with the SEC. Key issues the Division will face include forum selection and the use of ALJs, the impact of the Supreme Courts decision in Kokesh holding disgorgement to be a penalty, the upcoming decision of the Court in Digital Realty on whistleblowers, and the impact of Martoma on insider trading.