SEC adds tokenisation and AI to fiscal 2027 exam priorities

The SEC’s October 23 examination priorities add tokenisation and emerging technologies to its risk-based agenda for fiscal 2027. The programme covers advisers, funds, broker-dealers, clearing agencies and other registrants, signaling oversight of new market architectures alongside traditional risks.

Scope

• Applies to investment advisers, investment companies, broker-dealers, clearing agencies and other registered participants.
• Risk-based oversight: not a prohibition on tokenised products and not a finding of violations.

Focus areas

• Core risks: conflicts of interest, custody of customer information, operational resilience.
• Market structure changes: tokenisation and onchain settlement models.
• Advanced technologies: AI and super intelligence with potential impacts on compliance, fraud and market operations.

Implications for tokenised securities

• Obligations persist despite faster or onchain settlement: recordkeeping, failed-transaction handling, investor rights and customer-duty assignments must be clear.
• Firms exploring new trading venues and custody models must show that controls, governance and compliance evolve at the same pace as their technology.