Crystallex did not need to consent to accept the SEC enforcement action. It is all about possible extended litigation, and rights to appeal. A settlement with consent gives up those rights, keeps things under wraps, and is quite typical/normal in SEC regulatory enforcement.

2011 fins were 10 months late, being due by end of April 2012. However, it is common knowledge that the SEC is very lax enforcing filing requirements (numerous companies can be found several years in arrears). As to expense saving through the stopped audit of 2012 filings, time extensions for SEC filings are easily obtained, without permission, by only filing a form. Also, in some cases of a financially struggling company, depending on circumstance, unaudited financials are acceptable. Regardless, the 2012 fins were never the issue, as your quoting of the enforcement action shows the 2011 filings as the reason to revoke.

At first, this looked like the SEC is setting Crystallex as an example, because it is well known the SEC has increased efforts to clean up the pinks/greys. However, looking further I found there seems to be about a two-year break point. SEC filers in arrears two-plus years, that are revoked, are supposedly about filings (plus maybe other things). Filers in arrears of less than two years are revoked purportedly for other reasons than just late filings, using the late filings excuse in settlements/consents to keep things under wraps. Crystallex coming forward five weeks early gives the impression they wanted this SEC enforcement action out of the way for some reason. It may be about CCAA, or about Fung's past, or something else completely.