SEC’s 2027 Exam Priorities for 34,000 Firms Add Tokenisation Checks

The US Securities and Exchange Commission has named tokenisation, super intelligence (SI), anti-money laundering controls and private credit among the areas its examiners will focus on in fiscal 2027. The Division of Examinations’ annual priorities, announced on 23 October, cover what the SEC calls “more than 34,000 registrants, including investment advisers, investment companies, broker-dealers, self-regulatory organizations, clearing agencies, municipal advisors, transfer agents, funding portals, security-based swap entities, and others”.

The release arrived more than three weeks earlier in the calendar than last year’s, which the SEC’s examination priorities page dates to 17 November 2025. The new document is a staff statement. The full report says it is “not a rule, regulation, or statement” of the Commission and “has no legal force or effect”. For compliance teams, it is the clearest public signal of where examiners will look over the coming year.

The eight areas the SEC listed

The press release names eight areas for “heightened attention”:

• investment advisers’ fiduciary obligations, conflicts of interest, recommendations and compliance programmes;
• retail investor protection, “particularly regarding complex, higher-risk, and illiquid products”;
• “Private funds, private credit, and other complex investment strategies”;
• broker-dealer financial responsibility, trading, supervision and “anti-money laundering compliance”;
• operational resiliency, cybersecurity and protection of customer information;
• “Emerging technologies, including super intelligence and other advanced technologies”;
• “Risks associated with evolving market infrastructure, including Treasury clearing reforms, tokenization, and related developments”;
• oversight of self-regulatory organisations and other critical market participants.

SEC Chairman Paul Atkins said: “Examinations are one of the Commission’s most important tools for promoting compliance with the federal securities laws and helping protect investors.” Keith Cassidy, director of the Division, said: “The markets we oversee continue to evolve rapidly, and the examination program must evolve with them.”

The Division adds that the list is “not an exhaustive list” and that examiners will still look across the full range of registrant activity.

Tokenisation enters the exam plan through clearing and market systems

The report places tokenisation in two parts of the market. For clearing agencies, examiners will cover high-risk areas “including risk management of defaults, recovery and wind-down, securities lending, operations, and tokenization”. Under Regulation SCI, which covers the core technology systems of exchanges, clearing agencies and other key market entities, exams will focus on “emerging trends, including SI, tokenization of securities, extended trading hours, and quantum computing”. Transfer agents will be examined on their “use of emerging technology to perform transfer agent functions”.

Last year’s report did not use the word at all. The change comes as tokenisation projects reach the firms in scope: DTCC has set out what its tokenization service will cover at launch, and Perpetuals.com has filed to offer tokenized US stocks under the SEC’s innovation exemption.

Neither this year’s report nor last year’s uses the words “crypto” or “digital asset”. Policy on custody is moving through rulemaking instead, including the SEC’s proposal on adviser self-custody and state trust companies. The exam plan therefore reaches tokenised securities through the plumbing that settles and records them, not through a crypto label. For a transfer agent or clearing agency piloting a ledger, the likely questions are about operational risk, wind-down planning and vendor dependence, the same tests applied to legacy systems.

UK regulators have framed the near-term case narrowly too. The FCA and Bank of England’s feedback statement FS26/1 says that “at least in the short to medium-term, the main benefit to wholesale markets is likely to be in improving collateral mobility”, as TSN reported in its tokenisation round-up.

The AML section points at foreign omnibus accounts

The anti-money laundering section is specific. Examiners will check whether broker-dealers are “(1) appropriately tailoring and updating their AML program to their business model and associated AML risks, including accounting for risks associated with omnibus accounts, particularly omnibus accounts maintained for foreign financial institutions”, as well as independent testing, ongoing customer due diligence and Suspicious Activity Report filing.

The report flags the risk where the identity of a foreign institution’s underlying customer or beneficial owner is “unknown to the broker-dealer because of the omnibus accounts structure (e.g., due to ‘nested’ account relationships)”. It says examiners may review “special due diligence” programmes for foreign correspondent accounts and whether firms are monitoring Office of Foreign Assets Control sanctions. Reviews of trading in foreign-based companies will look for “pump-and-dump”/”ramp-and-dump” schemes and will “be coordinated with the SEC Cross-Border Task Force”.

For a compliance team, this reads less like a general reminder and more like a test plan. Nested relationships are where transaction monitoring loses sight of the end customer, and the report ties that gap directly to market manipulation in foreign-based issuers. Firms that rely on a correspondent’s own know-your-customer checks should expect to show how they assessed that reliance, how they tested it independently and when it produced a SAR. A programme that cannot answer those questions with documents will struggle in an exam room.

SI becomes both a cyber threat and a control to be tested

The report moves from the term “artificial intelligence” used last year to “super intelligence”, the wording the SEC also chose for its 9 November roundtable on machine-readable data. It says “Threat actors are using SI to automate and accelerate cyberattacks, making those attacks more efficient and harder to detect.” Examiners will review how firms prepare for “SI-generated phishing messaging and synthetic or deepfake voice and video used for social engineering”.

Firms’ own SI tools are also in scope. The Division will examine policies for monitoring SI “including its use in fraud prevention and detection, back-office operations, compliance with AML and Reg BI obligations, and trading functions”. The leadership message says the Division is “intensifying its efforts to understand how the technologies influence outcomes and whether firms continue to comply with existing, technology-neutral obligations”.

That phrase “technology-neutral” carries the weight. The SEC is not proposing SI-specific rules here; it is saying that an SI-driven alert system must still meet the same AML and suitability standards as a manual one. A firm that has automated its alert review will need records showing why the model closed what it closed.

Private credit appears in adviser, fund and broker-dealer exams

Private credit appears across the report rather than in one place. Advisers recommending illiquid products “such as loans provided by private funds or business development companies (BDCs)” are a priority. Fund reviews cover “less liquid or illiquid investments, including private credit”, and broker-dealer exams will look at “pricing and valuation of illiquid instruments, such as private credit and private equity”.

The report also notes an enhanced memorandum of understanding with the Commodity Futures Trading Commission that allows “opportunities for joint or aligned examinations”. The next public marker comes on 9 November, when the SEC holds its roundtable on machine-readable data and SI.

Sources

• SEC press release 2026-109, “SEC Announces Fiscal Year 2027 Examination Priorities”, 23 October 2026.
• SEC Division of Examinations, “Examination Priorities: Fiscal Year 2027” (PDF).
• SEC, Examination Priorities index page (FY2026 report dated 17 November 2025).
• FCA and Bank of England, FS26/1, September 2026.

Related stories

• SEC crypto custody proposal: adviser self-custody and state trust companies
• DTCC Sets Out What Its Tokenization Service Covers at Launch
• Perpetuals.com Files to Offer Tokenized US Stocks Under the SEC’s Innovation Exemption
• SEC Sets November Roundtable on Super Intelligence and Machine-Readable Data