While not nearly as transformative and dramatic as the first half of 2013 and the early days of Chair Mary Jo White and Director of Enforcement Andrew Ceresney, the first six months of 2014 was just as busy and productive with major court victories and significant and novel enforcement actions. The SEC obtained a long-awaited and favorable decision from the United States Court of Appeals for the Second Circuit in the Citigroup case in which the SEC’s “neither-admit-nor-deny” policy had been taken to task by Judge Rakoff in the Southern District of New York. The Commission secured admissions of wrongdoing from high-profile defendants in connection with five settlements. In addition, the Commission entered into its first non-prosecution agreement with an individual defendant and its first enforcement action for retaliation against a whistleblower. More controversially, the Commission continues to have mixed results at trial. Undeterred, the Enforcement Division has indicated that it intends to keep marching forward with its aggressive stance and keep bringing important cases in each of its priority areas. In May 2014, the Enforcement Division announced that SEC-veteran Stephanie Avakian would return as its new Deputy Director, no doubt to have more leaders focused on the implementation of Chair White’s aggressive, all encompassing enforcement agenda.