UNITED STATES OF AMERICA
                                     before the
                         SECURITIES AND EXCHANGE COMMISSION

          SECURITIES EXCHANGE ACT OF 1934
          Release No.  40891 / January 7, 1999

          ADMINISTRATIVE PROCEEDING
          File No. 3-9402

                                             :    ORDER MAKING FINDINGS
          In the Matter of                   :    AND IMPOSING REMEDIAL
                                             :    SANCTIONS AGAINST
          EURO-ATLANTIC SECURITIES, INC.,    :    JOHN T. MADDEN
          BRIAN A. SCHMIDT,                  :
          DARLAN E. GORDON,                  :
          JOHN T. MADDEN,                    :
          WILLIAM AVENT, and                 :
          JOHN ARISTOTLE DILWORTH            :
                                             :
               Respondents.                  :
          :
                                             :

                                         I.

               The   Securities   and  Exchange  Commission  ("Commission")
          instituted public administrative  proceedings pursuant to Section
          15(b) of the Securities Exchange Act  of  1934  ("Exchange  Act")
          against  Respondent  John  T.  Madden ("Madden") on September 10,
          1997.

                                         II.

               Respondent Madden has submitted  an  Offer  of Settlement to
          the  Commission, which the Commission has determined  to  accept.
          Solely  for  the  purpose  of  these  proceedings  and  any other
          proceeding brought by or on behalf of the Commission, or in which
          the  Commission is a party, and without admitting or denying  the
          findings  contained  herein, except as to the jurisdiction of the
          Commission over Respondent  Madden and over the subject matter of
          these proceedings and as to Section  III.,  paragraph  1., below,
          which  are  admitted, Respondent Madden consents to the entry  of
          findings and remedial sanctions set forth below.

                                        III.

               On the basis  of this Order and the Offer of Settlement, the
          Commission finds that:[1]

               The Fraudulent T-Bill Scheme by a Euro-Atlantic Registered
          Representative

                    1.   At all relevant times, Respondent Madden  was  the
          branch  office  manager of, and a registered representative with,
          the  Chicago branch  office  of  Euro-Atlantic  Securities,  Inc.
          ("Euro-Atlantic"), a   broker-dealer   registered   with   the
          Commission.

                    2.   From July  to  about  October  1995,  a registered
          representative   in   the   Chicago  branch  office  ("Registered
          Representative") and others perpetrated  a  scheme  whereby  they
          defrauded an investor ("Investor") of $300,000 in connection with
          the  purported "leasing" of U.S. Treasury Bills ("T-Bills").  The
          Investor  was  a businessman from the British Virgin Islands, who
          was badly in need  of  financing for his business.  Upon learning
          of  the  Investors predicament,  the  Registered  Representative
          began to lay  the  foundation of the convoluted scheme to defraud
          him.  The Registered  Representative  told  the  Investor that he
          could arrange for the Investor to "lease" or borrow  T-Bills, but
          that  the minimum amount available was $10 million at a  cost  of
          $300,000 per month.  Although this was more than the Investor had
          intended  to borrow, the Registered Representative explained that
          if the Investor  leased  the  full  $10  million and followed his
          advice, the leased T-Bills would actually pay for themselves.

                    3.   Under the Registered Representatives  scheme, the
          leased T-Bills were to be used as collateral for a margin account
          to  be  opened  in  the Investors name at another broker-dealer.
          Using the margin account, the Registered Representative explained
          that the Investor could  obtain  $2  million for his business and
          invest the remaining $8 million in a "high yield" trading program
          at  the  other  broker-dealer.   According   to   the  Registered
          Representative,  this  trading program would generate  sufficient
          returns to pay the cost  ($300,000 per month) of borrowing the T-
          Bills.  The Registered Representative  told  the Investor that he
          had a supplier ("Supplier"), who had been assigned $10 million in
          T-Bills, which he had available for lease.

                    4.   The Registered Representative put  the Investor in
          contact with the purported Supplier of the T-Bills, who confirmed
          the    Registered    Representatives    plan.   The   Registered
          Representative  handled all of the negotiations  regarding  costs
          and fees and some  of  the  paperwork  for the Investor to open a
          margin  account  at  the  other  broker-dealer.   The  Registered
          Representative was to receive $25,000  for  arranging  the T-Bill
          lease and commissions on trades in the Investors margin account.

                    5.   The   Registered   Representative   pressured  the
          Investor to proceed with the deal, urging him not to delay and to
          trust  him  because  "this  [was]  a  good  deal."  The Investor,
          however,  wanted  more  information  about  the  trading  program
          because, without the promise of substantial returns, the Investor
          could  not  afford the monthly lease payments.  In response,  the
          Registered  Representative   sent  the  Investor  two  fabricated
          letters supposedly from the other  brokerage  firm that would run
          the trading program.  The letters, which were signed  by  another
          registered  representative  purportedly associated with the other
          firm, assured the Investor that  he  could margin the T-Bills and
          trade the proceeds in a program with a  weekly  yield of at least
          3%.   All along, the Investor was led to believe that  the  other
          registered representative was associated with the other brokerage
          firm.   However,  the  letters  supposedly from the other broker-
          dealer were provided to the Investor  after  the other registered
          representative was no longer associated with that firm.

                    6.   The Investor then indicated that  before  he would
          proceed  with the transaction, he wanted written assurances  from
          the assignor  of the T-Bills.  In response, the Investor was told
          that  he needed  to  wire  a  good  faith  deposit  of  $300,000,
          representing  one  months lease payment, to a Euro-Atlantic safe
          keeping account before the written assurances would be given. The
          Investor  was  told  that  the  Registered  Representative  would
          release the $300,000 to  the Supplier only after the Investor had
          received the written assurances, and simultaneously, the Supplier
          would assign the $10 million  in  T-Bills  to  the  Investor  and
          deposit them into the Investors margin account.

                    7.   Accordingly,  the  Registered  Representative sent
          the  wire  instructions  to  the  Investor  along  with  a  cover
          memorandum  assuring  him  that  the  $300,000  would be held  in
          "safekeeping" until the Investor received the written  assurances
          that  he  wanted  from the assignor of the T-Bills.  The Investor
          immediately wired the $300,000 deposit to Euro-Atlantic according
          to the instructions  provided  by  the Registered Representative.
          Rather than directing that the funds  be wired into a safekeeping
          account, however, the Registered Representative had directed that
          they be wired into an account at Euro-Atlantic  controlled  by an
          associate of the Supplier ("Associate"). Almost immediately after
          receiving   the   wire   from   the   Investor,   the  Registered
          Representative wired $294,900 of the Investors funds out of  the
          Associates  account.   Of  this  amount,  $44,900  went  to  the
          Supplier and the Associate, and the remaining $250,000  was  used
          to pay the purported assignor of the T-Bills.  The $5,100 left in
          the account was the Registered Representatives finders fee.

                    8.   The Investor never received the written assurances
          he was promised before the funds would be released.  In addition,
          the  Investor never received any T-Bills nor did he have a margin
          account opened in his name.

          **FOOTNOTES**

          [1]: The finding herein are made pursuant to Respondent Maddens
          Offer of Settlement and are not binding on any other person or
          entity in this or any other proceeding.

         Primary Violations of the Federal Securities Laws by the 
         Registered Representative:

                    1.   The  Registered  Representative  violated  Section
          17(a)  of  the  Securities  Act  of 1933 and Section 10(b) of the
          Exchange Act and Rule 10b-5 thereunder,  by  engaging in a scheme
          to  defraud  the  Investor  out  of  $300,000.   The   Registered
          Representative  falsely  represented  to  the  Investor that  his
          $300,000  would be used to "lease" T-Bills, which  would  fund  a
          margin  trading   account   opened   in  his  name.   He  further
          represented  that  the  Investors  funds   would   remain  in  a
          safekeeping account at Euro-Atlantic until the Investor  received
          adequate  written  assurances as to the ownership of the T-Bills.
          He also provided the  Investor  with  phony documentation to make
          the transaction appear legitimate.  Each  of  these misstatements
          of fact would be material to a reasonable investor in determining
          whether to proceed with the transaction.  See Basic  v. Levinson,
          485 U.S. 224 (1988).

               Respondent Maddens Failure to Supervise

                    1.   At  all relevant times, as branch manager  of  the
          Chicago branch office,  Respondent  Madden  was  responsible  for
          supervising  the  Registered  Representative.   Madden  failed to
          reasonably supervise the Registered Representative by failing  to
          follow  Euro-Atlantics supervisory procedures designed to detect
          the kind  of  fraudulent  activity  perpetrated by the Registered
          Representative  with the help of his accomplices.   Specifically,
          Madden failed to  review  incoming  and  outgoing correspondence,
          including  facsimiles,  that were sent to and  from  the  Chicago
          branch  as  required  by Euro-Atlantics  supervisory  procedures
          manual.  Virtually all  of  the  documents relating to the T-Bill
          transaction passed through the Chicago  branch  office, including
          lease  contracts,  wire  instructions, and margin account  forms.
          The Registered Representative also sent the Investor memoranda he
          prepared  himself  on Euro-Atlantic  letterhead.   In  turn,  the
          Investor sent numerous  documents,  including overnight packages,
          to the Registered Representative at the  Chicago  branch  office.
          In  sum,  almost  all  of  the  documents  relating to the T-Bill
          transaction  went  through  the  Chicago  branch  office  without
          Respondent Madden's review or approval.

                    2.   Respondent  Madden  was  also  informed   by   the
          operations  manager  at  the  Chicago  branch office that she had
          discovered  the  Registered Representative  using  the  facsimile
          machine to send out  documents  that  had  not  been  approved by
          Madden.   The operations manager repeatedly complained to  Madden
          about the Registered  Representatives  unauthorized  use  of the
          facsimile   machine.    Nevertheless,   Respondent  Madden  never
          disciplined  or  reprimanded  the Registered  Representative  for
          violating Euro-Atlantic procedures or enhanced his supervision of
          the Registered Representative.

                    3.   Respondent Madden also ignored several "red flags"
          that indicated the Registered Representative  was  involved  in a
          fraudulent  transaction.   For example, Madden was aware that the
          Registered Representative had  received  several phone calls from
          the  Investor  and  "witnessed"  the Registered  Representatives
          signature  on a document..  The document  purported  to  pay  the
          Registered Representative  commissions  in connection with a "$10
          million T-Bill Trade Program," yet Madden  made no inquiry of the
          Registered  Representative.  Madden also allowed  the  Registered
          Representative  to  open  four trading accounts controlled by the
          Associate.  Although each new  account  form (one of which Madden
          had  signed) indicated that the Associates  company  had  a  net
          worth  of  $500 million, Madden failed to question the Registered
          Representative  about  it  further.   Nor  did  Madden direct the
          Registered  Representative to obtain independent verification  of
          that figure even  though no other Euro-Atlantic customer had ever
          claimed a net worth  even  near that amount.  Instead, Respondent
          Madden allowed the Registered  Representative  to  open  the four
          accounts  without further inquiry.  As noted above, one of  these
          accounts was  used  to  temporarily  "park"  the Investors funds
          before they were misappropriated.

                    4.   Respondent  Madden  also  failed  to  prevent  the
          Investors   $300,000  from  being  disbursed  to  the  Supplier,
          Associate, and  purported  assignor  of the T-Bills when he first
          learned  of  the  transaction.   Madden  was  notified  by  Euro-
          Atlantic's clearing firm that $300,000 had been wired into one of
          the Associates accounts with no trade pending.  Upon questioning
          the Registered Representative about the wire,  Madden  was  given
          information  and  documents  which should have alerted him to the
          dubious nature of the T-Bill transaction and the central role the
          Registered Representative may  have  played.   Madden should have
          also  been  suspicious  since  the Registered Representative  had
          never given notice to the firm that  he  intended  to engage in a
          transaction  away from the firm, as he was required to  do  under
          Euro-Atlantic  procedures. Moreover, Madden admitted he had never
          heard  of "leasing"  T-Bills,  did  not  understand  how  it  was
          supposed  to  work,  and  could not find anyone who would confirm
          that it was a legitimate transaction.

                    5.   Accordingly, Madden failed reasonably to supervise
          the Registered Representative  who was subject to his supervision
          with  a  view  to  preventing  the  Registered   Representatives
          violations described above of Section 17(a) of the Securities Act
          and   Section   10(b)  of  the  Exchange  Act,  and  Rule  10b-5,
          thereunder.

                                         IV.

               Based on the  foregoing, the Commission deems it appropriate
          and in the public interest  to  impose the sanctions specified by
          Respondent Madden in his Offer of Settlement.

               Accordingly, IT IS ORDERED that:

               1.   Respondent Madden be, and  hereby  is,  suspended  from
          association  with  any  broker  or  dealer  for a period of three
          months,  effective on the second Monday following  the  entry  of
          this Order.   Madden  shall provide to the Commission, within ten
          (10) days after the end  of  the  three  month  suspension period
          described above, an affidavit that he has complied fully with the
          terms of the suspension.

               2.   Respondent  Madden  be,  and hereby is, suspended  from
          association in a supervisory and proprietary  capacity  with  any
          broker  or  dealer  for  a  period  of  nine  months  immediately
          following the period of his suspension from association.   Madden
          shall  provide to the Commission, within ten (10) days after  the
          end of the  nine  month  suspension  period  described  above, an
          affidavit  that  he  has  complied  fully  with  the terms of the
          suspension.

               3.   Respondent  Madden  shall, within thirty (30)  business
          days after the entry of the Order,  pay  a civil money penalty in
          the amount of $5,000 to the United States Treasury.  Such payment
          shall be: (a) made by United States postal money order, certified
          check, bank cashiers check or bank money order; (b) made payable
          to the Securities and Exchange Commission;  (c) hand-delivered to
          the  Comptroller, Securities and Exchange Commission,  450  Fifth
          Street,  N.W.,  Washington,  D.C.  20549,  Mail Stop 0-3; and (d)
          submitted  under  cover  letter  which  identifies  Madden  as  a
          respondent  in  these  proceedings,  the  file   number  of  this
          proceeding, a copy of which cover letter and money order or check
          shall be sent to J. Cindy Eson, Esq., Southeast Regional  Office,
          Securities  and  Exchange Commission, 1401 Brickell Avenue, Suite
          200, Miami, FL 33131.

               By the Commission.

                                  Jonathan G. Katz
                                     Secretary