DISCLAIMER 

This is a report of the staff of the U.S. Securities and Exchange Commission. The Commission 

has expressed no view regarding the analysis, findings, or conclusions contained herein. 

Report available on the Web at https://www.sec.gov/reports 

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CONTENTS 

MESSAGE FROM THE DIRECTOR...........................................................................................1 

INTRODUCTION........................................................................................................................9 

Focus on Financial Fraud and Issuer Disclosure ....................................................................9 

Focus on Investment Professionals ......................................................................................11 

Initiatives ..............................................................................................................................11 

Preserving Market Integrity...................................................................................................12 

Uncovering and Prosecuting Abusive Trading ......................................................................13 

Achieving Results Through Litigation....................................................................................14 

DISCUSSION AND ANALYSIS OF FISCAL YEAR 2020..........................................................16 

Overall Results .....................................................................................................................16 

Types of Cases.....................................................................................................................16 

Disgorgement and Penalties Ordered...................................................................................17 

Tips, Complaints, and Referrals............................................................................................19 

Whistleblower Program.........................................................................................................20 

Individual Accountability .......................................................................................................21 

Non-Monetary Relief Obtained .............................................................................................21 

Challenges ...........................................................................................................................23 

NOTEWORTHY ENFORCEMENT ACTIONS...........................................................................24 

APPENDIX ...............................................................................................................................29 

ENDNOTES .............................................................................................................................47 

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MESSAGE FROM THE DIRECTOR 

I am pleased to share the Division of Enforcement’s annual report for 

Fiscal Year 2020. And what a year it was. Like everyone, the 

challenges we faced – and continue to face – were unexpected and 

beyond imagination. In response to these extraordinary challenges, 

the women and men of the Enforcement Division rose to the occasion 

and achieved extraordinary results. In the midst of massive change, 

one thing remained the same: we continued to vigorously enforce the 

federal securities laws to protect investors and maintain the integrity 

of the markets. 

In Fiscal Year 2020, the Division continued to investigate and 

recommend actions addressing conduct that spanned the securities 

markets, including conduct involving financial fraud, insider trading, 

offering fraud, Foreign Corrupt Practices Act violations, misconduct 

by broker-dealers and investment advisers, and more. Based on this work, the Commission 

brought hundreds of enforcement actions and secured meaningful remedies to protect investors 

and our markets against wrongdoing. 

But the real story of 2020 was COVID-19. It colored so much of the last half of the year – what 

we focused on, investigations we opened, actions we recommended, how we did our work, 

where we did our work, and how we allocated our resources. By mid-March, the entire Division 

had transitioned to mandatory telework and essentially all of our operations were conducted 

remotely. Despite the shift in working conditions – and the still-ongoing efforts to adapt to those 

conditions – we quickly dedicated substantial resources to address the emerging threats presented 

by COVID-19 and the ensuing dynamic market conditions. At the same time, we continued to 

focus on the multitude of existing and new non-COVID-related enforcement issues arising in the 

normal course. We confronted these challenges head on and, in so doing, remained steadfast in 

our mission to protect investors. 

This year also put a spotlight on issues of diversity, equity, and inclusion. Across the 

Enforcement Division, we addressed these issues directly. Together with our partners in the 

Office of Minority and Women Inclusion and the Office of the Chairman, we facilitated many 

large and small group discussions across the country in an effort to educate ourselves and each 

other about the issues and challenges we face. The effort and willingness to communicate openly 

is the first step. We will continue to tackle these issues and make changes that will benefit all of 

us in the Division of Enforcement. 

Lastly, Steve Peikin, my co-director for more than three years, stepped down in August. The job 

has not been the same without him. But with endings come beginnings, and I am pleased to 

welcome Marc Berger as Deputy Director. Marc brings a dozen years of experience as a federal 

prosecutor as well as almost three years of leading the Commission’s New York Regional 

Office. All of us in Enforcement are incredibly fortunate that Marc has agreed to join me in 

leading the Division. 

I am proud of everything the Division accomplished this last fiscal year. This report presents 

these accomplishments, highlights some of our most significant achievements, and discusses 

areas of strategic change. In this report, we have tried to illustrate the critical role the 

Enforcement Division plays in advancing the Commission’s mandate to protect investors, 

maintain fair, orderly, and efficient markets, and facilitate capital formation. 

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COVID-19 

Like our colleagues across the Commission, we in the Division of Enforcement have focused 

significant time and resources responding to challenges created by the global pandemic. 

First, we quickly committed substantial resources to protecting retail investors by actively 

looking for misconduct. In March, we formed a Coronavirus Steering Committee to oversee this 

effort by coordinating investigations relating to a wide variety of potential misconduct in the 

areas of microcap, insider trading, and financial fraud and issuer disclosure. 

One important result from this approach was our quick investigative work in identifying and 

then recommending trading suspensions to the Commission. In March and April alone, the 

Commission suspended trading in the securities of two dozen issuers where there were questions 

regarding the accuracy and adequacy of information related to COVID-19 that those issuers 

injected into the marketplace, including claims about potential COVID-19 treatments, the 

manufacture and sale of personal protection equipment, and disaster-response capabilities. 

All told, from mid-March through the end of the fiscal year, the Division’s Office of Market 

Intelligence triaged approximately 16,000 tips, complaints, and referrals (a roughly 71% increase 

over the same time period last year), and the Division opened more than 150 COVID-related 

inquiries and investigations and recommended several COVID-related fraud actions to the 

Commission. We think this triage and investigative work, and the resulting Commission trading 

suspensions and fraud actions, meaningfully changed the landscape for investors during a period 

of significant market uncertainty. 

Second, a big part of our year was learning how to do our job in new ways. In the early months 

of the pandemic, many of us spent the bulk of our time focused on learning and guiding our staff 

how to effectively do our job remotely. 

But we moved past that initial period of uncertainty and ultimately achieved a remarkable level 

of success, including bringing more than 700 enforcement cases during the fiscal year. Viewed 

against the backdrop of COVID-19, this was an extraordinary accomplishment. I am proud that 

we were able to do so much in the face of so many challenges. This success is a testament to the 

tenacity, ingenuity, and drive of the staff of the Enforcement Division. 

How we conducted our work has certainly changed. Investigations were impacted as we – 

and lawyers across the defense bar – figured out how to modify our approaches to normal 

investigative steps. For example, while investigations are now advancing much more smoothly, it was several months before we took the first remote testimony and, even now, it remains a 

learning process in terms of best practices. 

To highlight a few examples of the ingenuity and drive of our staff, a group took the lead on 

working to change and adjust our processes - figuring out how to take testimony and depositions 

remotely, how to provide and show exhibits, and how to do test runs with witnesses and counsel. 

People pitched in in various new ways, including by volunteering to help on the Steering 

Committee. And many staff redirected newly-freed-up time elsewhere, including by taking on 

whistleblower claims and distributions to injured investors, or strategically pivoting to cases and 

aspects of investigations that could be advanced while we were finding ways to adjust to the 

move away from in-person work. 

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Ultimately, in the midst of COVID-19, it was a year of contrasts. While the number of cases the 

Commission filed was down as compared to last year, the financial remedies ordered set a new 

high. Similarly, the number and amount of whistleblower awards exceeded prior years – in fact, 

awards issued in 2020 accounted for roughly 37% of the total number of individuals awarded 

over the entire life of the whistleblower program. 

COVID-19 made Fiscal Year 2020 the most challenging year in recent memory. But the Division 

demonstrated its agility and its commitment to the SEC’s mission as it moved quickly to address 

the ongoing crisis. This rapid response protected investors and helped preserve the integrity of 

our markets. 

Detecting, Remedying, and Punishing Misconduct by Issuers and Registrants 

A cornerstone of our enforcement program is ensuring that entities are held accountable for their 

misconduct. In Fiscal Year 2020, the Commission brought actions against financial institutions, 

automobile and engine manufacturers, and technology, telecommunications, and pharmaceutical 

companies, to name a few. The following subset of cases is illustrative: 

• Wells Fargo & Co. In a settled action, the Commission found that Wells Fargo misled 

investors about the success of its core business strategy at a time when it was opening 

unauthorized or fraudulent accounts for unknowing customers and selling unnecessary 

products that went unused. Wells Fargo was ordered to pay the SEC a $500 million civil 

penalty as part of a combined $3 billion settlement with the SEC and the Department of 

Justice.1 

• Telegram Group Inc. The Commission filed an emergency action and obtained a temporary 

restraining order against Telegram and its wholly-owned subsidiary TON Issuer Inc. for 

allegedly operating an unregistered offering of digital tokens called “Grams” in violation of 

the federal securities laws.2 On the Commission’s motion, the court issued a preliminary 

injunction barring the delivery of Grams and finding that the Commission had shown a 

substantial likelihood of proving that Telegram’s sales were part of a larger scheme to 

unlawfully distribute the Grams to the secondary public market. Following this decision, the 

defendants agreed to settle the action and were ordered to return more than $1.2 billion to 

investors and to pay an $18.5 million civil penalty.3 

• Bausch Health, formerly Valeant Pharmaceuticals. In a settled action, the Commission found 

that Valeant improperly recognized revenue and made misleading disclosures in SEC filings 

and earnings presentations. Bausch was ordered to pay a $45 million civil penalty.4 

• BMW AG. In a settled action, the Commission found that BMW and two of its U.S. 

subsidiaries disclosed inaccurate and misleading information about BMW’s retail sales 

volume in the U.S. while raising approximately $18 billion from investors in several 

corporate bond offerings. The three companies were ordered to pay a joint penalty of $18 

million.5 

• SCANA Corp. In a litigated action, the Commission charged SCANA Corp., two of its former 

top executives, and South Carolina Electric & Gas Co. with allegedly defrauding investors by 

making false and misleading statements about a nuclear power plant expansion that was 

ultimately abandoned.6 

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• Novartis AG. In a settled action, the Commission found that local subsidiaries or affiliates of 

Novartis or its former subsidiary Alcon Inc. engaged in bribery schemes in South Korea, 

Vietnam, and Greece. Novartis paid over $112 million to settle charges that it violated the 

books and records and internal accounting controls provisions of the Foreign Corrupt 

Practices Act (FCPA).7 

• Telefonaktiebolaget LM Ericsson. In a settled action, the Commission alleged that Ericson 

engaged in a large-scale bribery scheme involving the use of sham consultants to secretly 

funnel money to government officials in multiple countries. In resolving this matter, Ericsson 

was ordered to pay more than $1 billion to the SEC and the Department of Justice and to 

install an independent compliance monitor.8 

• J.P. Morgan Securities LLC. In a settled action, the Commission found that J.P. Morgan 

fraudulently engaged in manipulative trading of U.S. Treasury securities. J.P. Morgan 

admitted the findings in the SEC’s order, and was ordered to pay disgorgement of $10 

million and a civil penalty of $25 million to settle the action. The Department of Justice and 

the Commodity Futures Trading Commission resolved parallel matters against J.P. Morgan 

Chase & Co. and certain of its affiliates.9 

Holding Individuals Accountable 

We have long recognized that individual accountability is critical to an effective enforcement 

program. Institutions act through their employees, and holding culpable individuals responsible 

for wrongdoing is essential to achieving our goals of general and specific deterrence and 

protecting investors by removing bad actors from our markets. The SEC’s actions over the past 

year illustrate the premium we place on establishing individual liability where appropriate. In 

Fiscal Year 2020, the Commission charged individuals in 72% of the standalone enforcement 

actions it brought. Those charged include individuals at the top of the corporate hierarchy, 

including numerous CEOs and CFOs, as well as accountants, auditors, and other gatekeepers. Just by way of example, former executives of Valeant Pharmaceuticals,10 Goldman Sachs Group 

Inc.,11 and Iconix Brand Group Inc.,12 as well as former audit partners of KPMG LLP,13 were 

charged with a range of violations, including fraud, reporting, books and records, and internal 

accounting controls. 

Continued Focus on Retail Investors 

Protecting retail investors continued to be a focus in 2020. Over the last year, we brought several 

cases involving the conduct of investment professionals as it relates to retail investors. For 

example, as part of the Chairman’s Teachers’ Initiative, the Commission charged VALIC 

Financial Advisors Inc. (VFA) for failing to disclose that its parent company paid a for-profit 

company owned by the Florida K-12 teachers’ unions to promote VFA’s products and services to 

those teachers.14 As part of resolving this matter, VFA agreed to cap advisory fees for certain 

groups of teachers in VFA programs, which will result in significant savings for thousands of 

teachers. 

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The Commission also filed an action against Wells Fargo for failing reasonably to supervise 

investment advisers and registered representatives who recommended complex, high-volatility 

single-inverse ETFs to retail investors, and for lacking adequate compliance policies and 

procedures with respect to the suitability of those recommendations.15 As part of the resolution 

of that matter, the Commission imposed a penalty of $35 million, which will be distributed to 

investors. 

Bringing About Strategic Change 

In Fiscal Year 2020, the Division continued to focus on bringing impactful cases in areas of 

importance to the protection of investors. To do this more efficiently and effectively, we made a 

number of strategic changes in how we operate. This has led to continued improvement in 

several key areas, most notably our handling of whistleblower claims; our distributions to 

harmed investors; the pace of our investigations; and communicating the benefits of cooperating 

with our investigations. 

Record Year for Whistleblowers 

Fiscal Year 2020 was a record year for the Whistleblower Program. Since the program was 

established in 2011, whistleblower tips have resulted in numerous high-quality enforcement 

actions, and, as of the end of Fiscal Year 2020, the Commission had awarded 106 individuals 

approximately $562 million. In last year’s annual report we stated that we were working to 

streamline and substantially accelerate the evaluation of claims for whistleblower awards. I am 

pleased to report that these process improvements yielded considerable results. In Fiscal Year 

2020, we substantially increased the rate at which whistleblower claims were evaluated and 

awards were issued. As a result, the Commission issued approximately $175 million in total 

awards to 39 individuals.16 This represents a 200% increase in number of individuals awarded in 

a single year over the next-highest year. In Fiscal Year 2020, there was also a record number of 

preliminary determinations, which set forth the assessment of the Division’s Claims Review 

Staff regarding whether a claim should be approved or denied and, if approved, the proposed 

award amount, as well as final Commission orders of awards and denials. In the brief time since 

the Fiscal Year ended, the Whistleblower Program has continued to achieve new milestones, as 

the Commission issued the largest award in its history – approximately $114 million to a single 

whistleblower – on October 22, 2020.17 

Commitment to Returning Money to Harmed Investors 

Distributing money to harmed investors remains a core component of the Commission’s investor 

protection mission. In Fiscal Year 2020, the Commission distributed more than $600 million to 

harmed investors. 

To further build upon improvements in distributing money to investors, we created the Office of 

Bankruptcy, Collections, Distributions, and Receiverships within the Division of Enforcement. 

This new office is led by Nichola Timmons, who previously led our Distributions Group. 

Ms. Timmons will, among other things, oversee the processes through which the Commission 

collects outstanding monetary judgments in district court and bankruptcy proceedings, monitors 

the work of court-appointed receivers, and returns money to harmed investors through distri- butions. By centralizing existing functions, we expect to achieve additional efficiencies and 

maximize results for investors. 

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A recent final distribution by a receiver worth highlighting is that made in connection with the 

WG Trading Investment fraud.18 In total, this distribution returned more than $1 billion to 

affected investors after the Commission years ago charged Paul Greenwood, Steven Walsh, and 

their affiliated WG Trading entities with orchestrating a brazen investment fraud involving the 

misappropriation of investor assets. The Commission obtained emergency relief and, ultimately, 

judgments against the defendants. Through this receivership and distribution, harmed investors 

have received payments totaling 100% of their net principal investments. 

Accelerating the Pace of Investigations 

In Fiscal Year 2020, we continued to focus on shortening the amount of time it takes to complete 

investigations and recommend enforcement actions. Our actions have the greatest impact when 

filed as close in time to the conduct as possible. Our median time to file this past year was 21.6 

months – a five-year best.19 An example of swift action is the Commission’s recently-filed 

district court action against the co-chair of the unsecured creditors committee in the Neiman 

Marcus Group Ltd. LLC Chapter 11 bankruptcy proceedings.20 The Commission filed its action 

within five weeks of the alleged misconduct. 

More specifically, we have also seen improvements in the length of time it takes to bring 

financial fraud and issuer disclosure cases. In appropriate cases, we are increasing staffing, working to more efficiently triage issues, making more targeted requests at the outset, 

substantively engaging early in an investigation with relevant parties, and leveraging 

cooperation. These changes have had the desired effect: in Fiscal Year 2020, we reduced the 

average amount of time it takes to complete these investigations from 37 months to 34 months. Some notable examples include settled charges against a Bermuda-based insurance company for 

failing to fully disclose perquisites and benefits provided to its former chief executive officer, brought fifteen months after the Division opened an investigation,21 and a settled action against 

Hilton Worldwide Holdings Inc. addressing similar violations, brought roughly eight months 

after the Division began its investigation.22 This is particularly meaningful given COVID-related 

challenges – both because regrouping amid mandatory telework necessarily slowed 

investigations and because we reallocated resources to address near-term investor protection 

concerns related to COVID-19. We will continue to look for ways to accelerate the pace of these 

investigations and we expect to see additional improvement in the near and long term. 

Rewarding Cooperation 

One way to substantially accelerate an investigation is through meaningful cooperation. In Fiscal 

Year 2020, we continued to focus on rewarding cooperation and providing greater transparency 

into how the Commission considers and weighs cooperation credit. Below are two examples for 

consideration – in one the Commission ordered a reduced penalty in recognition of substantial 

cooperation and in the other the Commission determined to not impose a penalty at all. 

In the Commission’s action against BMW, the Commission imposed a reduced civil penalty 

against BMW in recognition of its extensive cooperation, especially in light of COVID-19 

challenges.23 Despite considerable constraints, including travel restrictions, work-from-home 

orders, and office closures, BMW gathered and made available a large volume of information in 

response to document, information, and data requests. BMW also made multiple current and 

former employees available for interviews, and provided presentations and narrative submissions 

that highlighted critical facts. Due in large part to this cooperation, we were able to complete this 

case within 12 months of opening it. 

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In the Commission’s action against Transamerica Asset Management, Inc., a registered 

investment adviser based in Denver, Colorado, the Commission did not impose a penalty where 

Transamerica self-reported the conduct, took prompt steps to remediate the violations, and 

cooperated with the staff’s investigation.24 We recognize the value in communicating such 

examples of meaningful cooperation and we will continue to look for opportunities to improve 

our messaging going forward. 

The Impact of SEC v. Liu 

In Fiscal Year 2020, the Division was faced with another impactful Supreme Court decision. 

In June 2020, the Supreme Court in SEC v. Liu affirmed the authority of courts to order 

disgorgement through their power to order “equitable relief” under Section 21(d)(5) of the 

Exchange Act. This was an important decision for the Commission. However, it also imposed 

some limitations and left open some questions. The Court held that disgorgement should reflect 

net profits, and that “legitimate” expenses should generally be backed out. The Court also 

emphasized the importance of returning disgorged funds to harmed investors. 

The Division continues to evaluate the impact of this decision and how the questions that the 

Court left open will affect us going forward. As a result, there have been and will continue to be 

changes in the balance between the penalties and disgorgement that the Division seeks and 

recommends to the Commission. Among other things, we may recommend higher penalties in 

some cases where the statutory scheme permits us to do so. The Division’s recommendations 

will be consistent with the Court’s decision, while continuing to seek the relief necessary to 

achieve our mission of protecting investors and maintaining market integrity. 

Measuring the Results of Fiscal Year 2020 

As I have said many times, statistics can never present a full picture of the effectiveness of an 

enforcement program. To see this full picture requires a review of the nature and quality of our 

enforcement actions, and an understanding of the market conditions in which they occurred and 

the impact they have had. This was true in Fiscal Year 2019, when the Commission filed a nearrecord number of enforcement actions despite a near-total cessation of enforcement activity for 

more than one month that was caused by a lapse in appropriations. And it remains true this year, 

as we faced COVID-related challenges and added new enforcement efforts to our existing 

responsibilities, and obtained significant results in both areas. 

However, statistics do have value, and a variety of metrics underscore that the Division 

continued to achieve great things on behalf of investors in Fiscal Year 2020. In the face of so 

many unprecedented challenges, the Commission brought 715 enforcement actions – 405 of 

which were “standalone” actions. Seventy-two percent of these standalone actions included 

charges against one or more individuals. The Commission also obtained more than 475 bars or 

suspensions against market participants and suspended trading in the securities of 196 issuers. 

In addition, the Division triaged approximately 23,650 tips, complaints, and referrals and opened 

close to 1,200 new inquiries and investigations. Finally, the Commission obtained judgments and 

orders totaling approximately $4.68 billion in disgorgement and penalties – the highest amount 

on record. 

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But the greatest of our achievements this year was the everyday work of the women and men of 

the Enforcement Division. The fact that they kept going. That they did their jobs. That they kept 

protecting investors. Through the darkness of late March and early April, through school 

closures, through work-from-home, through illnesses and worse. Since mid-March, these women 

and men recommended 492 enforcement actions and 36 COVID-related trading suspensions, 

opened approximately 640 inquiries and investigations (over 150 of which were COVIDrelated), received and triaged approximately 16,000 TCRs, conducted numerous remote 

interviews, testimonies and depositions, and conducted (and won) one virtual trial. That we 

all kept going is the success of 2020. I could not be more proud of my colleagues and what 

we achieved together in Fiscal Year 2020. 

Sincerely, 

Stephanie Avakian 

Director, Division of Enforcement 

U.S. Securities and Exchange Commission 

November 2, 2020 

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INTRODUCTION 

The Division of Enforcement’s efforts to deter misconduct and punish securities law violators 

are critical to protecting millions of investors and instilling confidence in the U.S. securities 

markets. Each year, the Division recommends, and the Commission brings, hundreds of 

enforcement actions against individuals and entities for fraud and other misconduct and secures 

remedies that protect investors by punishing misconduct, deterring wrongdoing, removing bad 

actors from our markets, and, where possible, compensating harmed investors. This report 

summarizes some of the major accomplishments and key priorities of the Division over the last 

fiscal year. 

Focus on Financial Fraud and Issuer Disclosure 

Integrity and accuracy in financial statements and issuer disclosures are critical to the 

functioning of our capital markets. During the last fiscal year, the Division maintained its 

ongoing focus on identifying and investigating securities laws violations involving different 

components of the financial reporting process. 

In addition to traditional case sources, the Division took a proactive, risk-based analytic 

approach to identifying potential violations, which resulted in several important actions. For 

example, the Division’s EPS (Earnings Per Share) Initiative uses risk-based data analytics to 

uncover potential accounting and disclosure violations caused by, among other things, earnings 

management practices to mask unexpectedly weak performances. Investigations under the EPS 

Initiative resulted in settled actions against Interface Inc. and two of its former executives, and 

against Fulton Financial Corporation, for improper accounting practices that resulted in the 

reporting of quarterly EPS that met or exceeded analyst consensus estimates.25 The Division also 

used risk-based data analytics to uncover potential violations related to corporate perquisites, which led to a settled enforcement action against Hilton Worldwide Holdings Inc. for failing to 

fully disclose perquisites and personal benefits provided to executive officers.26 

The Division’s financial fraud and issuer disclosure focus remained on matters involving 

financial statement misstatements and the executives responsible for the violations. For example, 

the Commission brought actions against: 

• Revolution Lighting Technologies, Inc. and four executives, including the CEO and former 

CFO, for allegedly falsely inflating its reported revenues over a four-year period;27 

• Super Micro Computer, Inc. and its former CFO for prematurely recognizing revenue and 

understating expense over a period of at least three years;28 

• Power Solutions International Inc. and three individuals, for the fraudulent overstatement of 

revenues by nearly $25 million;29 

• Iconix Brand Group Inc. and its former CEO and COO for allegedly devising a fraudulent 

scheme to create fictitious revenue, allowing Iconix to meet or beat Wall Street analysts’ 

consensus estimates in the second and third quarters of 2014;30 

• MiMedx Group Inc. its former CEO, CFO and COO for allegedly defrauding investors by 

misstating the company’s revenue and attempting to cover up their misconduct by misleading 

the company’s auditor, audit committee and outside lawyers;31 

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• Manitex International, Inc. and its former COO, former Controller and CFO, and General 

Manager of a subsidiary for engaging in two accounting fraud schemes that resulted in the 

issuance of materially misstated financial statements;32 

• Outcome Health, a private healthcare advertising company, and four former executives with 

alleged fraud in raising nearly half a billion dollars by falsely portraying the company as an 

overwhelming success to investors, clients, and auditors; and33 

• Hill International, Inc., a Pennsylvania-based construction management consulting company, 

and two of its former executives for allegedly engaging in fraudulent accounting practices.34 

Accurate corporate disclosures that include material information about an issuer’s condition lie at 

the heart of our securities laws. Last fiscal year, the Commission confirmed the importance of 

such disclosures with several cases charging issuers with materially misleading and incomplete 

disclosures. In February 2020, the Commission announced settled charges against alcohol 

producer Diageo plc for failing to make required disclosures of known trends relating to the 

shipments of unneeded products by its North American subsidiary to distributors.35 In the same 

month, the Commission charged SCANA Corp., two of its former top executives, and South 

Carolina Electric & Gas Co. with allegedly defrauding investors by making false and misleading 

statements about a nuclear power plant expansion that was ultimately abandoned.36 Similar 

disclosure issues animated the Commission’s settled action against Fiat Chrysler Automobiles 

N.V. for misleading disclosures about an internal audit of its emissions control systems.37 

Further, the Commission settled with HP Inc. for misleading investors by failing to disclose the 

impact of sales practices undertaken in an effort to meet quarterly sales and earnings targets.38 

Another priority for the Division is recommending actions against issuers that distort non-GAAP 

metrics, key performance indicators, and related disclosures. The Commission brought actions 

against: 

• Wells Fargo & Co. for misleading investors about the success of its core business strategy at 

a time when it was opening unauthorized or fraudulent accounts for unknowing customers 

and selling unnecessary products that went unused;39 

• BMW AG and two of its U.S. subsidiaries for disclosing inaccurate and misleading 

information about BMW’s retail sales volume in the U.S.;40 

• Bausch Health, formerly Quebec, Canada-based Valeant Pharmaceuticals, and three former 

executives for improper revenue recognition and misleading disclosures in SEC filings and 

earnings presentations, including by touting double-digit same store organic growth, a nonGAAP financial measure, when much of that growth came from sales to a mail order 

pharmacy Valeant helped establish, fund and subsidize;41 

• BCG Partners, Inc. for allegedly false and misleading disclosures concerning how it 

calculated a key non-GAAP financial measure, which it called post-tax distributable 

earnings;42 and 

• Publicly-traded real estate investment trust VEREIT, Inc., formerly known as American 

Realty Capital Properties, Inc., with intentionally overstating a key performance metric.43 

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Focus on Investment Professionals 

The Division continued to prioritize identifying misconduct that occurs in the interaction 

between investment professionals and retail investors. Investment professionals occupy positions 

of tremendous importance to those who entrust them with their children’s college funds, their 

retirement funds, and other savings. 

One such responsibility – long recognized under federal law – is an adviser’s fiduciary obligation 

to disclose to their clients material conflicts of interest. Disclosure of such conflicts remains a 

priority. The importance of such disclosures is illustrated by the Share Class Selection Disclosure 

Initiative (Share Class Initiative) that we concluded during Fiscal Year 2020. Ultimately, this 

initiative resulted in the SEC ordering nearly 100 investment advisory firms that voluntarily selfreported to the Division to return more than $139 million to investors.44 

Other potential undisclosed conflicts can include advisers’ use of cash sweep arrangements. Cash 

in advisory accounts is often automatically swept into a money market mutual fund or a bank 

deposit sweep program. In some cases, an adviser that is either dually-registered or has an 

affiliated broker-dealer has a conflict of interest in recommending one cash investment over 

another because it receives revenue sharing payments from its clearing broker when selecting 

particular cash sweep products. Just as with mutual fund share class selections, advisers 

recommending or choosing between different cash sweep products must make full and fair 

disclosure of these types of conflicts. In bringing settled charges against Fresno, California-based 

SCF Investment Advisors, Inc., the Commission found that SCF failed to disclose conflicts 

related to revenue sharing from cash sweep money market funds.45 

Another potential area of concern for advisory clients is the transparency of fee structures 

around their accounts. For example, “wrap fee programs” offer accounts in which clients pay an 

asset-based “wrap fee” that covers investment advice and brokerage services, including trade 

execution. In May 2020, the Commission found that Morgan Stanley Smith Barney had 

disseminated marketing and client communications that gave the misleading impression that 

wrap fee clients were not likely to incur additional trade execution costs, even though the firm’s 

order routing practices resulted in some instances in the clients paying additional transaction 

fees that were not visible to them.46 In settling the charges, Morgan Stanley agreed to pay a $5 

million penalty and create a Fair Fund to distribute the penalty moneys to harmed investors. 

Initiatives 

Protecting investors remains a critical focus of our Enforcement program. Investor protection 

takes a variety of forms, as illustrated by the below examples. 

COVID-19 Steering Committee 

Recognizing that the pandemic posed significant risks to investors and market integrity across a 

variety of market segments and types of conduct, in late March, we established a Coronavirus 

Steering Committee to centralize and coordinate our efforts. The Steering Committee’s mandate 

was to ensure a consistent Division-wide approach to coronavirus-related matters, ensure 

appropriate allocation of our resources, avoid duplication of efforts, and coordinate as appro- priate with state and federal agencies. The Steering Committee also worked to proactively 

identify and monitor areas of potential misconduct associated with COVID-19, and to detect 

and address potential misconduct in areas such as insider trading, financial fraud and issuer 

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disclosure, and misconduct by regulated entities and individuals. As a result of our efforts to 

uncover potential wrongdoing in these and other areas, between mid-March and the end of the 

fiscal year the Division opened more than 150 COVID-related inquiries or investigations, many 

of which are ongoing. 

Given the widespread switch to remote work and the increased market volatility, we recognized 

the potential for the misuse of material nonpublic information and, on March 23, 2020, put out a 

public statement addressing our concerns in this regard.47 The statement highlighted that material 

nonpublic information was potentially even more valuable amid the dynamic market conditions 

of the pandemic’s early days than under normal market conditions. The statement reminded 

issuers and registrants to follow their disclosure controls and procedures to protect against the 

improper dissemination and use of such information. 

Finally, the Steering Committee also included members of the Division’s Retail Strategy Task 

Force (RSTF) who, in collaboration with the SEC’s Office of Investor Education and Advocacy, 

issued an Investor Alert warning of potential COVID-19-related scams targeting retail investors, 

highlighting specific types of frauds investors should be wary of, and providing specific steps 

that retail investors could take to protect themselves. 48 

Retail Investor Protection 

Staff across the Division continued to work to protect retail investors from threats apart from 

those related to COVID-19. Cases in this area span a wide range of conduct, and address 

violations that affected a variety of investor populations, including seniors,49 the Hispanic 

community,50 African immigrants,51 Amish and Mennonite community members,52 police 

officers and other first responders,53 and cadets at the U.S. Air Force Academy.54 

In addition, staff, and particularly the RSTF, worked to educate vulnerable investors about 

potential scams targeting members of identifiable groups, such as religious or ethnic communities, the elderly, or the differently abled. For example, in Fiscal Year 2020, the RSTF helped 

create a video designed to teach investors in the Deaf, Hard of Hearing, and Hearing Loss 

communities about how to spot frauds in their communities.55 This was tied to the Commission’s 

September 2020 action against a Swedish national living in Thailand who allegedly conducted a 

multi-million dollar online offering fraud that victimized thousands of retail investors world- wide.56 According to the complaint, at least 847 of the investors were members of a community 

for the Deaf that invested more than $2 million in the scheme since 2015 as their retirement 

investment. 

Preserving Market Integrity 

As a number of the Commission’s enforcement actions demonstrate, the Division remains 

focused on uncovering violations at major financial institutions over the last year. Such matters 

are essential to maintaining the integrity of the securities markets. 

One market structure issue that has been a major area of ongoing focus is the “pre-release” of 

American Depository Receipts (ADRs). ADRs are U.S. securities that represent foreign shares of 

a foreign company and require a corresponding number of foreign shares to be held in custody at 

a depositary bank. The practice of pre-release allows ADRs to be issued without the deposit of 

foreign shares, provided the broker receiving them has an agreement with a depositary bank and 

the receiving broker or its customer owns a number of foreign shares that corresponds to the 

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number of shares the ADRs represent. Since late 2018, and continuing through Fiscal Year 2020, 

the Commission has brought enforcement actions against depositary banks and brokers 

comprising some of the world’s largest financial institutions, including JP Morgan Chase, 

Citibank, and Merrill Lynch, for engaging in improper conduct that undermined market integrity 

in connection with the “pre-release” of ADRs. In total, the Commission brought actions against 

15 firms and 4 individuals, ordering more than $432 million in disgorgement and penalties.57 

This important initiative, which has now concluded, illuminated misconduct in the gateway to 

U.S. markets for issuers from across the world. 

In 2020, the Commission also brought several actions in connection with order routing practices. In May 2020, the Commission charged Bloomberg Tradebook LLC with making material mis- representations and omitting material facts about how the firm handled certain customer trade 

orders.58 The Commission found that Tradebook allowed unaffiliated broker-dealers to make 

order routing decisions for certain customer orders, contradicting its marketing materials, which 

represented that orders would be routed by Tradebook’s own “advanced” technology. In August 

2020, the Commission charged affiliated registered investment advisers WBI Investments Inc. 

and Millington Securities Inc. with making material misrepresentations to clients about 

compensation Millington received in an institutional payment for order flow arrangement for 

routing client orders to certain brokerage firms for execution.59 

Nationally recognized statistical rating organizations (NRSROs), or credit rating agencies, also 

play a critical role in ensuring market integrity. Over the last year, the Commission brought 

several actions addressing issues in the credit rating process. For example, the Commission 

charged Morningstar Credit Ratings LLC with violating a conflict of interest rule designed to 

separate credit ratings and analysis from sales and marketing efforts, finding that Morningstar 

had permitted a wholesale integration of its ratings analysts into its business development 

efforts.60 The Commission also instituted two actions against Kroll Bond Rating Agency, Inc. 

(KBRA) relating to the rating of commercial mortgage-backed securities (CMBS) and of 

collateralized loan obligation (CLO) combination notes.61 In connection with the CMBS ratings 

matter, the Commission found that KBRA permitted analysts to make adjustments that had a 

material effect on the final ratings, but did not require any analytical method for determining 

when and how those adjustments should be made, and that KBRA’s internal controls failed to 

monitor whether analysts were making adjustments at the loan level, as KBRA’s procedures 

required, or at the portfolio level. With regard to the CLO combo notes matter, the Commission 

found that KBRA’s policies and procedures were not reasonably designed to ensure that KBRA 

rated the notes in accordance with their terms. 

Uncovering and Prosecuting Abusive Trading 

Detecting and punishing those who engage in insider trading, and those who trade on the basis of 

misappropriated information, remain central to our mission. The Commission, often in coordination with criminal law enforcement authorities, brought a number of actions covering a wide 

array of such abusive trading practices. For example, the Commission charged a former finance 

manager at Amazon.com Inc. and two family members with insider trading in advance of 

Amazon earnings announcements between January 2016 and July 2018.62 The Commission also 

charged a former IT administrator at Palo Alto Networks Inc., who allegedly used his IT credentials and work contacts to obtain highly confidential information about Palo Alto Network’s 

quarterly earnings and financial performance, then traded in the company’s securities based on 

the confidential information and tipped his friends, four of whom were also charged.63 

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In addition to such “classical” insider trading cases, the Commission brought enforcement 

actions against financial professionals for allegedly misappropriating material nonpublic 

information that they and/or others then traded on. In one action, the Commission charged a 

senior index manager at a globally recognized index provider and his friend with perpetrating an 

insider trading scheme that generated more than $900,000 in illegal profits.64 The pair allegedly 

purchased call or put options of publicly traded companies hours before public announcements 

that those companies would be added to or removed from a popular stock market index that the 

index manager helped his employer manage, and then liquidated their options positions for a 

substantial profit. And in a series of enforcement actions arising from an alleged international 

insider trading scheme, the Commission charged an investment banker at a large investment 

bank and a New York-based trader,65 two former investment bankers and a London-based 

trader,66 and two traders based in Switzerland.67 These actions, like a number of other significant 

cases involving complex, abusive trading, originated from the Analysis and Detection Center 

housed within the Division’s Market Abuse Unit, which uses data analysis tools to detect 

suspicious trading patterns, such as improbably successful trading across different securities 

over time. 

Notably, parallel criminal actions were filed by separate U.S. Attorney’s Offices in connection 

with each of the four cases mentioned above. This reflects the success of our ongoing efforts to 

coordinate with our criminal law enforcement counterparts as appropriate. Fittingly, Fiscal Year 

2020 began with a Criminal Coordination Conference that the Division hosted on October 3, 

2019. The main goals of this event were to continue to build relationships between the Division 

and our criminal law enforcement counterparts and to strengthen our coordination. 

A critical element in preventing illegal trading is robust corporate controls and compliance 

policies around the use and safeguarding of material nonpublic information. The importance of 

such policies was central to the Co-Directors’ Statement of March 23, 2020, referenced above, 

and it also animated the Commission’s enforcement action against Ares Management LLC, 

a Los Angeles-based private equity firm and registered investment adviser.68 In that matter, 

the Commission found that Ares’s compliance policies failed to account for the special 

circumstances presented by having an employee serve on the portfolio company’s board while 

that employee continued to participate in trading decisions regarding the portfolio company. 

Our efforts to curb abusive trading extend beyond insider trading. For example, the Commission 

filed an emergency action and obtained an asset freeze against eighteen traders in a complex 

scheme to manipulate more than 3,000 U.S.-listed securities for more than $31 million in illicit 

profits.69 The Commission alleged that the traders, who are primarily based in China, mani- pulated the prices of thousands of thinly traded securities by creating the false appearance of 

trading interest and activity in those stocks, artificially boosting or depressing stock prices. 

Achieving Results Through Litigation 

The majority of the Commission’s enforcement actions are filed as settled matters, but the 

Division stands ready to litigate matters where necessary to protect investors, markets, and the 

Commission’s interests. Over 40% of the standalone matters the Commission brought in Fiscal 

Year 2020 were filed in whole or in part as litigated actions. These matters, against both entities 

and individuals, span a wide range of misconduct and represent the Division’s commitment of 

resources to litigation when a satisfactory resolution by settlement cannot be reached. 

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The Division had a number of significant wins before juries, in bench trials, and in contested 

administrative and cease-and-desist proceedings in Fiscal Year 2020. In fact, every proceeding 

that the Division litigated to a verdict or decision this year resulted in a win for the Commission. 

The Division’s ability to prevail before a jury on even the most complex fact patterns was on 

display in the Commission’s action against Ukraine-based trading firm Avalon FA Ltd. and its 

principals for allegedly manipulating the U.S. markets hundreds of thousands of times and 

generating more than $25 million in illicit proceeds.70 The Commission alleged that Avalon 

engaged in layering, which involved placing and canceling orders to trick others into buying or 

selling stocks at artificial prices, and cross-market manipulation, which involved buying or 

selling stocks to artificially impact options prices. In November 2019, following a three week- long trial, the jury found Avalon and its principals liable for its unlawful trading schemes. 

Another win came on September 24, 2020, when, after a nine-day bench trial, a New York 

federal judge ordered a former private equity executive liable on the Commission’s charges that 

he had fraudulently spent his clients’ funds on vacations, salon trips, clothing and other personal 

expenses.71 

The Commission also obtained asset freezes and emergency relief in a number of actions. One 

particularly significant example was the Commission’s October 2019 emergency action against 

Telegram.72 The court issued a preliminary injunction barring delivery of the tokens at issue and 

finding that the Commission had shown a substantial likelihood of proving that Telegram’s sales 

were part of a larger scheme to unlawfully distribute “Gram” tokens to the secondary public 

market. Ultimately, the Commission reached a settlement whereby Telegram agreed to return 

more than $1.2 billion to investors.73 

Further, the Commission also had success at the summary judgment stage. For example, in 

August 2020, the District Court for the Southern District of Florida granted the Commission 

summary judgment in a case charging a Florida-based individual and his company with acting as 

unregistered dealers in the sale of billions of shares of numerous penny stock issuers.74 And on 

September 30, 2020, the District Court for the Southern District of New York awarded the 

Commission summary judgment on its charges against Kik Interactive Inc. in connection with 

that company’s 2017 initial coin offering.75 The court found that undisputed facts established that 

Kik’s sales of “Kin” tokens were sales of investment contracts, and therefore of securities, and 

that Kik violated the federal securities laws when it conducted an unregistered offering of 

securities that did not qualify for any exemption from registration requirements. The court 

further found that Kik’s private and public token sales were a single integrated offering. 

Through such actions, the Division obtained significant relief on behalf of the Commission and 

investors. These and other cases also remind potential bad actors that the Commission will 

aggressively litigate even the most difficult cases where appropriate. 

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DISCUSSION AND ANALYSIS OF FISCAL YEAR 2020 

Overall Results 

Fiscal Year 2020 was another successful year for the Division of Enforcement, despite the 

unprecedented challenges posed by the global COVID-19 pandemic. Since mid-March, the 

entire Division has been working from home, which has created unique impediments to several 

important aspects of our work, such as taking testimony from live witnesses, gathering evidence, 

and litigating our cases in court. Nevertheless, the Division found ways to recommend meaningful cases to the Commission and to protect the investing public. In the face of great adversity, 

the Commission brought 715 enforcement actions in Fiscal Year 2020. Impressively, the 

Commission brought 492 of these cases after the instituting mandatory telework in mid-March. 

Of the cases brought this fiscal year: 

• 405 were “standalone” actions brought in federal court or as administrative proceedings; 

• 180 were “follow-on” proceedings seeking bars based on the outcome of Commission actions 

or actions by criminal authorities or other regulators; and 

• 130 were proceedings to deregister public companies–typically microcap–that were 

delinquent in their Commission filings.* 

Notwithstanding the challenges we faced, the total numbers of cases were down only 17% from 

last year. 

Types of Cases 

As the chart below illustrates, the majority of the SEC’s 405 standalone cases in Fiscal Year 

2020 concerned securities offerings (32%), investment advisory and investment company issues 

(21%), and issuer reporting/accounting and auditing (15%) matters. The SEC also continued to 

bring actions relating to broker-dealers (10%), insider trading (8%), and market manipulation 

(5%), as well as other areas such as Public Finance (3%) and FCPA (2%). 

* In Fiscal Year 2020, the Commission’s deregistration and/or suspension orders instituted a proceeding as to a 

single issuer. In prior years, such orders typically instituted a proceeding as to two or more, usually unrelated, 

issuers. This change in practice achieves consistency with the Commission’s general practice of issuing separate 

orders for individual respondents except when charges arise from related investigations, and streamlines the process 

relating to contested orders. 

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A breakdown of the number and percentage of the types of actions brought in Fiscal Year 2020 

is set forth in the attached appendix. 

Disgorgement and Penalties Ordered 

In Fiscal Year 2020, the Commission obtained record-breaking monetary remedies in enforce- ment actions. All told, parties in the Commission’s actions and proceedings were ordered to pay 

a total of $3.589 billion in disgorgement of ill-gotten gains. Penalties imposed totaled $1.091 

billion, in line with Fiscal Year 2019’s $1.101 billion penalty total. Total monetary relief ordered 

in Fiscal Year 2020 was $330 million higher than in Fiscal Year 2019, an approximately 

8% increase. 

Money ordered is also high when viewed in terms of the median case: the median amount of 

total money ordered in Fiscal Year 2020 was over $530,000. 

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In Fiscal Year 2020, the 5% of cases that involve the largest financial remedies again accounted 

for the majority of all financial remedies the Commission obtained. 

The Commission places a significant priority on returning funds to harmed investors whenever 

possible. Consistent with that goal, the Commission returned $602 million to harmed investors in 

Fiscal Year 2020. These distributions comprised over 800,000 individual payments to investors 

from 91 fair funds and court-appointed administrators. 

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Tips, Complaints, and Referrals 

Each year, the Commission receives thousands of tips, complaints, and referrals, or TCRs, that 

need to be reviewed and analyzed by Enforcement staff to identify those that warrant potential 

further investigation or response. Staff quickly triages each TCR to determine whether we should 

open an inquiry or investigation. In Fiscal Year 2020, the Commission received over 23,650 

TCRs, a substantial increase over the approximately 16,850 TCRs received in Fiscal Year 2019. 

Further, the Commission received a majority of these TCRs during the pandemic: between midMarch and the end of the fiscal year, the Division triaged approximately 16,000 TCRs, a 71% 

increase from the same time period in 2019. We also saw an increase in the number of new 

inquiries and investigations. Overall, we opened 1,181 new inquiries and investigations in Fiscal 

Year 2020, compared to 1,082 in Fiscal Year 2019. From mid-March through the end of the 

fiscal year, we opened over 640 new inquiries/investigations, a 7% increase over the same period 

in Fiscal Year 2019. The staff’s dedication to quickly assessing TCRs and opening new cases is 

extraordinary. In addition, we believe this work has created a strong pipeline for future 

enforcement actions. 

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Whistleblower Program 

Over the past ten years, the whistleblower program has been a critical component of the 

Commission’s efforts to detect wrongdoing and protect investors in the marketplace, particularly 

where fraud is concealed or difficult to detect. Enforcement actions from whistleblower tips have 

resulted in more than $2.5 billion in ordered financial remedies, including more than $1.4 billion 

in disgorgement of which almost $750 million has been, or is scheduled to be, returned to 

harmed investors. Recognizing the importance of rewarding meritorious whistleblowers in a 

timely manner, we have made efforts to streamline and substantially accelerate the evaluation of 

claims for whistleblower awards. These efforts paid off. Fiscal Year 2020 was a record-breaking 

year for the whistleblower program. The Commission issued awards totaling approximately $175 

million to 39 individuals, both greater than any other year in the program’s history. 

Importantly, the Division also issued substantially more preliminary determinations, which set 

forth its assessment of whether a claim should be approved or denied and, if approved, the 

proposed award amount, and final Commission orders of awards and denials.† In Fiscal Year 

2020, the Division issued 315 preliminary determinations, a more than 95% increase over the 

next highest year, and the Commission issued 197 final orders, an approximately 19% increase 

over the next highest year. 

† Note that in Fiscal Years 2014 and 2015, a large number of preliminary determinations denials were issued to two 

serial submitters (both of whom were barred from the program), and these preliminary determinations became final 

orders during those same years. Specifically, in Fiscal Year 2014, 144 denials were issued to one claimant and, in 

Fiscal Year 2015, 40 denials were issued to another. 

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Further, in Fiscal Year 2020, the Commission adopted amendments to the rules governing the 

whistleblower program that were designed to provide greater clarity to whistleblowers and 

increase the program’s transparency and efficiency, including around the review and processing 

of whistleblower award claims. 

Individual Accountability 

Holding individuals accountable is among the Commission’s most effective methods of 

achieving deterrence. Experience teaches that individual accountability drives behavior and can 

also broadly impact corporate culture. In Fiscal Year 2020, 72% of the Commission’s standalone 

actions involved charges against one or more individuals. This percentage is in line with the 

results of the last several fiscal years. The individuals charged in our actions include those at the 

top of the corporate hierarchy—including chief executive officers, chief financial officers, and 

chief operating officers—as well as gatekeepers like accountants, auditors, and attorneys. 

Non-Monetary Relief Obtained 

In every enforcement action, the Division seeks appropriately tailored sanctions that advance 

enforcement goals. In addition to the monetary relief discussed above (disgorgement and 

penalties), there are a variety of potential non-monetary remedies available in the Commission’s 

actions. Non-monetary remedial relief is important to the Commission’s effort to ensure future 

compliance with the securities laws. For example, the Commission may seek undertakings, the 

appointment of independent compliance consultants, and/or conduct-based injunctions to protect 

the investing public on a going-forward basis. In each case, the Division seeks authorization to 

pursue those non-monetary remedies that will have the greatest impact. In Fiscal Year 2020, the 

Division continued to think creatively about how to craft relief to best protect investors. Some of 

these remedies are discussed in more detail below. 

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Undertakings 

Undertakings require a defendant to take affirmative steps—either in conjunction with entry of 

the order or in the future—to come into and remain in compliance with the specific terms of a 

court’s order. The Commission also has authority to impose similar obligations on respondents in 

administrative proceedings. Undertakings are a forward-looking remedy, specifically designed 

with an eye toward what happens after settlement. Well-designed undertakings provide unique 

long-term benefits to investors, and are one of the most effective forms of equitable relief in SEC 

enforcement actions. 

Many undertakings require a settling party to retain a compliance consultant or monitor to make 

recommendations to the issuer and report to the staff. In some cases, undertakings may reflect 

different affirmative steps to remediate structural or other problems. Several actions from Fiscal 

Year 2020 illustrate the Division’s use of undertakings that are tailored to remedial objectives 

and specific to the wrongful conduct at issue. For example, in the matter involving VFA’s failure 

to disclose to teachers practices that generated millions of dollars in fees and other financial 

benefits for VFA, VFA agreed to certain undertakings, including capping management fees for 

Florida K-12 teachers participating in 403(b) and 457(b) retirement plans under VFA’s 

management and certain other VFA advisory products.76 

Another example of tailored undertakings in Fiscal Year 2020 comes from the BitClave PTE 

Ltd. matter, involving an unregistered sale of digital tokens.77 As part of the relief obtained, the 

Commission ordered BitClave to transfer all of its digital tokens to a fair fund administrator to 

allow the fund administrator to permanently disable the tokens and take action to remove its 

tokens from digital asset trading platforms. These undertakings seek to remedy the harm from 

the illegal token offering by BitClave and the risks associated with the tokens trading freely 

without proper disclosure. 

Bars and Suspensions Imposed 

Bars and suspensions are also important forms of remedial relief available to the Commission. Bars and suspensions remove bad actors from positions where they can engage in future wrong- doing and thereby cause harm to investors and markets. Accordingly, the Division frequently 

asks the Commission to bar, or suspend for a period of time, wrongdoers from serving as officers 

or directors of public companies, dealing in penny stocks, associating with registered entities 

such as broker-dealers and investment advisers, or appearing or practicing before the 

Commission as accountants or attorneys. Enforcement actions resulted in 477 bars and 

suspensions of wrongdoers in Fiscal Year 2020. 

Trading Suspensions 

The federal securities laws allow the SEC to suspend trading in a security for up to ten business 

days when the SEC determines that a trading suspension is required in the public interest and for 

the protection of investors. In Fiscal Year 2020, the Commission suspended trading in the 

securities of 196 issuers. 

Court-Ordered Asset Freezes 

Court-ordered asset freezes are important to the Commission’s ability to protect investors 

because they prevent alleged wrongdoers from dissipating assets that could be distributed to 

harmed investors. Wrongdoers often attempt to hide assets and/or move them offshore, and the 

Commission’s ability to obtain meaningful financial remedies and to return money to harmed 

investors may therefore depend on the ability to obtain an asset freeze at an early stage. These 

circumstances require seeking federal court action on an emergency basis. 

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In Fiscal Year 2020, the Commission obtained 24 court-ordered asset freezes. These actions 

involve a range of misconduct. For example, in the Telegram Group Inc. matter, the Commission 

obtained an asset freeze against two offshore entities that conducted an unregistered digital 

token offering in the U.S. and overseas, raising more than $1.7 billion.78 The Commission also 

obtained an asset freeze that halted a series of alleged microcap market manipulation schemes 

aimed at defrauding retail investors.79 These matters demonstrate swift action by the 

Commission designed to preserve investor funds. 

Challenges 

The COVID-19 pandemic has disrupted many of the Division’s traditional methods of 

conducting investigations as it works to promote the safety and well-being of its staff while 

bringing meaningful cases to protecting investors. The ability to take live witness testimony, 

conduct in-person Wells meetings, and litigate cases in court, for example, have all been 

impacted. Although these methods cannot be completely replaced, the Division has worked hard 

to find innovative ways to ensure that investigations continue to move efficiently and quickly. 

While under mandatory telework orders, the Division of Enforcement has conducted numerous 

remote testimony sessions through internet-based video platforms, which allow staff to share 

documents with the witness while asking questions. The Division also held Wells meetings by 

video with multimedia presentations. Even courts have begun conducting remote hearings and 

bench trials by video, allowing our trial unit to successfully litigate several important cases as a 

result. As it is uncertain when we will be able to return to our offices and begin live meetings and 

testimony, we will continue to find ways to improve upon our remote capabilities and ways to 

conduct investigations efficiently remotely. 

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NOTEWORTHY ENFORCEMENT ACTIONS 

The Division’s efforts resulted in many noteworthy enforcement actions in Fiscal Year 2020. 

The matters described below give some sense of the actions the Commission brought in areas of 

the Division’s greatest focus and demonstrate the breadth of the landscape the Division covers. 

In addition to those actions discussed above, significant Commission enforcement actions in 

Fiscal Year 2020 also included charges against the following: 

Financial Institutions 

• Jefferies LLC and ABN AMRO Clearing Chicago LLC for their improper handling of 

“pre-released” American Depositary Receipts.80 

• Morgan Stanley Smith Barney LLC for providing misleading information to clients in its 

retail wrap fee programs regarding trade execution services and transaction costs.81 

• Morgan Stanley & Co. LLC for violations of Regulation SHO for failing to correctly net their 

positions and mark their long and short sales.82 

• Interactive Brokers LLC for repeatedly failing to recognize red flags and file suspicious 

activity reports for U.S. microcap securities trades it executed on behalf of customers.83 

• Broker-dealers Bluefin Trading LLC and Critical Trading LLC for violating the short tender 

rule in a partial tender offer.84 

• Broker-dealer SG Americas Securities LLC for failing to provide complete and accurate blue 

sheet trading data.85 

• Broker-dealer JonesTrading Institutional Services LLC for failing to preserve businessrelated text messages exchanged on the personal devices of several of its registered 

representatives.86 

Issuer Reporting and Disclosure Issues and Auditor Issues 

• RSM LLP for deficiencies in its quality control system related to staffing certain private 

investment fund financial statement audits.87 

• MetLife, Inc. for violating the books and records and internal accounting controls provisions 

of the federal securities laws relating to two errors in its accounting for reserves associated 

with its annuities business.88 

• Chicago-area engine manufacturing company Power Solutions International Inc. for 

overstating its revenues by almost $25 million.89 

• BorgWarner Inc. for materially misstating its financial statements by failing to account for 

certain asbestos liabilities.90 

• Pennsylvania-based owner and operator of cemeteries and funeral homes StoneMor Partners 

L.P. for failing to adequately disclose material liquidity problems and making misstatements 

in its financial statements.91 

• Three former executives of Ironclad Performance Wear Corp. for allegedly inflating 

Ironclad’s revenues through manipulative and deceptive accounting gimmicks.92 

• RCI Hospitality Holdings, Inc. and its CEO and CFO for RCI’s disclosure and controls 

failures concerning executive compensation and related party transactions.93 

• PLS CPAs and three of its auditors for engaging in improper professional conduct in 

connection with audit reports issued by PLS.94 

• Silicon Valley-based data storage company Quantum Corporation for internal accounting 

controls violations that resulted in repeated revenue recognition errors from 2015 to 2017.95 

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Public Finance Abuse 

• UBS Financial Services Inc. for improperly allocating bonds intended for retail customers to 

parties, known in the industry as “flippers,” who then immediately resold or “flipped” the 

bonds to other broker-dealers at a profit.96 

• Roosevelt & Cross and two of its registered representatives for circumventing the priority 

given to retail and institutional investors in certain municipal bond offerings.97 

• A state-funded, nonprofit charter school and its former President for allegedly misleading 

investors in a municipal bond offering.98 

• Two former executives of Tri-Valley Learning Corporation, which operated two public 

charter schools, for allegedly misleading investors who purchased over $25 million in bonds 

issued by Tri-Valley.99 

Individual Accountability 

• Two former top executives of Indiana-based trucking company Celadon Group Inc. for their 

alleged participation in an accounting fraud that included concealing losses by buying and 

selling trucks at inflated prices.100 

• Three former KPMG audit partners for improperly sharing answers to internal training exams 

testing whether audit professionals understood accounting and auditing principles and 

subsequent misconduct related during an investigation of the exam sharing.101 

• Former Hertz CEO and Chairman for allegedly aiding and abetting the company’s filing of 

inaccurate financial statements and disclosures that included inaccurate accounting for 

various reserve accounts.102 

• The former CFO of AmTrust Financial Services Inc. for allegedly failing to disclose material 

facts about how the company estimated its insurance losses and reserves.103 

• Three executives of a California solar panel company for allegedly diverting millions of 

dollars in investor funds earmarked for development of solar panel nanotechnology toward 

personal expenses.104 

• A supervisor of the securities lending desk at Industrial and Commercial Bank of China 

Financial Services LLC for the improper handling of transactions involving American 

Depositary Receipts.105 

• The former CEO of an online auction site for his alleged involvement in seeking to prevent 

whistleblowers from communicating with the SEC.106 

COVID-19 

• An emergency action and asset freeze in an alleged fraudulent scheme that generated more 

than $25 million from sales of multiple microcap companies’ stock, including four 

companies that were the subject of recent SEC trading suspension orders.107 

• A California-based penny stock trader for allegedly conducting a fraudulent pump-and-dump 

scheme by making hundreds of misleading statements in an online investment forum, 

including that a company had developed an approved blood test for COVID-19.108 

• Applied Biosciences Corp. for allegedly making false or misleading claims regarding its 

distribution of supposed rapid result finger-prick COVID-19 tests to the general public.109 

• Turbo Global Partners, Inc. and its CEO for allegedly issuing false and misleading press 

releases regarding the company’s purported partnership to sell thermal scanning equipment 

that would detect individuals with fevers.110 

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• Praxsyn Corp. and its CEO for allegedly issuing false and misleading press releases claiming 

that Praxsyn was able to acquire and supply large quantities of N95 or similar masks to 

protect wears from the COVID-19 virus.111 

• The President and Chief Science Officer of Arrayit Corporation for allegedly making false 

and misleading statements concerning Arrayit’s development of a COVID-19 blood test.112 

Cyber 

• A digital-asset entrepreneur and his company for allegedly defrauding investors in an ICO 

that raised more than $42 million from hundreds of investors.113 

• NAC Foundation, NAC’s CEO, and a political lobbyist for allegedly defrauding investors in 

an ICO by misrepresenting to investors that they were purchasing tokens that could be 

converted to a digital asset security that was superior to the original bitcoin.114 

• Blockchain services company BitClave PTE Ltd for conducting an unregistered ICO. As part 

of a settlement, BitClave agreed to pay over $25 million to harmed investors.115 

• Unikrn Inc., an operator of an online eSports gaming and gambling platform, for conducting 

an unregistered ICO. As part of a settlement, Unikrn agreed to pay $6.1 million to harmed 

investors.116 

• Boon Tech and its CEO for a fraudulent, unregistered offering of digital asset securities in 

connection with the sale of approximately $5 million in Boon Coins to more than 1,500 

investors.117 

• Actor Steven Seagal for failing to disclose payments he received for promoting an 

investment an ICO conducted by Bitcoiin2Gen.118 

Insider Trading 

• A California husband and wife in an alleged multi-million-dollar insider trading scheme 

involving the securities of Sagent Pharmaceuticals, Inc. in advance of an announcement 

about the company’s acquisition.119 

• Former executives of PetMed Express, Inc. for allegedly trading in advance of marketmoving earnings announcements between 2014 and 2018.120 

• The former Controller of Aceto Corporation for allegedly trading ahead of the now-bankrupt 

company’s earnings results showing poor sales and a pending impairment charge.121 

• An investor relations consultant for allegedly trading ahead of at least eleven earnings 

announcements in several public companies between Feb. 2016 and March 2018.122 

• Two former Rite Aid Corp. employees for allegedly disposing of shares of Rite Aid prior to a 

negative announcement regarding the status of a potential merger between Rite Aid and 

Walgreens Boots Alliance, Inc.123 

• A former investment adviser for allegedly trading in the securities of COPsync, Inc. stock on 

the basis of material, non-public information he gained while consulting for the company.124 

• A North Carolina-based actuary for alleged insider trading in the stock of Piedmont Natural 

Gas Company, Inc. on the basis of confidential information about a potential merger with 

Duke Energy Corp.125 

26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Foreign Corrupt Practices Act 

• Herbalife Nutrition Ltd. for violating the books and records and internal accounting 

controls provisions of the FCPA, in connection with payments to Chinese officials made 

by Herbalife’s Chinese subsidiaries.126 

• Boston-based pharmaceutical company Alexion Pharmaceuticals, Inc. for violating the books 

and records and internal accounting controls provisions of the FCPA by making payments to 

government officials in Turkey and Russia.127 

• South Carolina-based consumer loan company World Acceptance Corporation for violating 

the anti-bribery, books and records and internal accounting controls provisions of the FCPA 

in connection with bribe payments made to Mexican officials.128 

• A former executive of a financial services company for allegedly violating the anti-bribery 

provision of the FCPA by orchestrating a bribery scheme to win a government contract in the 

Republic of Ghana.129 

Criminal Coordination 

• Executives at a healthcare advertising company, who allegedly raised almost half a billion 

dollars from investors by misrepresenting their company’s business track record to 

investors.130 In a parallel criminal case, the U.S. Attorney's Office for the Northern District of 

Illinois and Fraud Section of the Department of Justice charged the executives with mail 

fraud, wire fraud, and bank fraud.131 

• Six individuals and their companies for allegedly coordinating illegal sales and transfer of 

stock.132 In a parallel criminal case, the U.S. Attorney’s Office for the Southern District of 

New York charged one individual and his firm with securities fraud.133 

• A California-based couple for allegedly orchestrating a nearly billion-dollar Ponzi scheme 

promising investors tax credits, lease payments, and profits from the operation of mobile 

solar generators.134 In a parallel criminal case, the U.S. Attorney’s Office for the Eastern 

District of California charged both with wire fraud and money laundering.135 

• A Russian businessman for allegedly creating fraudulent websites that resembled reputable 

financial institutions to solicit funds from individuals seeking CDs with high rates.136 In a 

parallel criminal case, the U.S. Attorney’s Office for the District of New Jersey the fraudster 

with wire fraud.137 

• Trustify Inc and its founder for allegedly lying to investors about the financial standing of the 

business and misappropriating investor funds for personal use.138 In a parallel criminal 

action, the U.S. Attorney’s Office for the Eastern District of Virginia and the Fraud Section 

of the Department of Justice charged the founder with wire fraud, securities fraud and money 

laundering.139 

• A film financier for allegedly defrauding a publicly traded fund of at least $13.8 million and 

using the funds to pay personal expenses.140 In a parallel criminal case, the U.S. Attorney’s 

Office for the Southern District of New York charged the financier with wire fraud.141 

• The president of a real estate development and management company for allegedly running a 

Ponzi scheme that targeted the elderly and misappropriating over $26 million.142 In a parallel 

criminal case, the U.S. Attorney's Office for the Northern District of California charged the 

executive with wire fraud. 143 

• An investment adviser for allegedly running a Ponzi scheme that targeted members of the 

Haitian community.144 In a parallel criminal case, the U.S. Attorney’s Office for the Southern 

District of New York charged the adviser with securities and wire fraud.145 

27 
 

 

 

 

 

 

 

 

 

 

 

 

Other Noteworthy Actions 

• A penny stock dealer who allegedly engaged in the business of purchasing convertible notes 

from penny stock issuers, converting the notes into shares of stock, and selling those newly 

issued shares into the public market, without registering with the Commission as a dealer.146 

• Abra, a California-based app developer, for offering and selling security-based swaps to 

retail investors without registration and for failing to transact those swaps on a registered 

national exchange.147 

• A former Georgia state legislator for allegedly defrauding at least 100 investors by making 

misrepresentations to them regarding expected investment returns and misappropriating their 

funds to make Ponzi-like payments to other investors and for personal use.148 

• Florida-based real estate firm EquiAlt LLC, its CEO, and its Managing Director for an 

alleged fraudulent unregistered securities offering that raised more than $170 million from at 

least 1,100 investors, a number of whom invested their retirement funds.149 

• A registered broker-dealer and investment adviser, and a company that designs, 

manufacturers, installs, and services fuel cell power plants, for failing to deliver final 

prospectuses to purchasers in connection with the public sale of more than $148 million in 

FuelCell stock.150 

28 
APPENDIX 

29 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Case Name Type of Action Release 

No. 

Date 

Filed 

BROKER-DEALER 

In the Matter of Moez Ben Mohamed Hedri Follow-on Admin. Proc. 34-87195 10/01/19 

In the Matter of Portfolio Advisors Alliance, Inc. Follow-on Admin. Proc. 34-87238 10/07/19 

In the Matter of Howard J. Allen, III Follow-on Admin. Proc. 34-87239 10/07/19 

In the Matter of Kerri L. Wasserman Follow-on Admin. Proc. 34-87240 10/07/19 

In the Matter of Michael Siva Follow-on Admin. Proc. 34-87245 10/08/19 

In the Matter of Harold Wasserman Follow-on Admin. Proc. 34-87259 10/09/19 

In the Matter of Lek Securities Corporation, et al. Follow-on Admin. Proc. 34-87268 10/10/19 

In the Matter of Domenick Migliorato Stand-alone Admin. Proc. 34-87302 10/15/19 

In the Matter of Richard Andrew Mallion Follow-on Admin. Proc. 34-87334 10/17/19 

In the Matter of Lei (Lily) Lei Follow-on Admin. Proc. 34-87429 10/31/19 

In the Matter of Ira Warkol Follow-on Admin. Proc. 34-87459 11/05/19 

In the Matter of Morgan Stanley Smith Barney, LLC Stand-alone Admin. Proc. 33-10726 11/07/19 

In the Matter of Dale Scott Pearlman Follow-on Admin. Proc. 34-87567 11/18/19 

In the Matter of Michael P. Dunne Follow-on Admin. Proc. 34-87582 11/21/19 

In the Matter of Thomas H. Vetter Follow-on Admin. Proc. 34-87604 11/22/19 

In the Matter of Renwick Haddow Follow-on Admin. Proc. 34-87591 11/22/19 

In the Matter of Michael K. Martin Follow-on Admin. Proc. 34-87616 11/25/19 

In the Matter of Ronald J. Roach Follow-on Admin. Proc. 34-87640 11/27/19 

In the Matter of Jefferies, LLC Stand-alone Admin. Proc. 34-87680 12/09/19 

In the Matter of Ronald R. Roaldsen, Jr. Follow-on Admin. Proc. 34-87751 12/16/19 

In the Matter of Critical Trading, LLC Stand-alone Admin. Proc. 34-87786 12/18/19 

In the Matter of Bluefin Trading, LLC Stand-alone Admin. Proc. 34-87787 12/18/19 

In the Matter of Joseph Ludovico, a/k/a Jay Ludovico Follow-on Admin. Proc. 34-87805 12/19/19 

In the Matter of Richard Johnathan Eden Follow-on Admin. Proc. 34-87827 12/20/19 

In the Matter of Christopher Michael Neumann Follow-on Admin. Proc. 34-87825 12/20/19 

SEC v. Benjamin Mekawy, et al. Civil LR-24702 12/23/19 

In the Matter of Bill Tsai Follow-on Admin. Proc. 34-87840 12/23/19 

In the Matter of Christopher S. Laws Follow-on Admin. Proc. 34-87872 12/30/19 

In the Matter of Ryan K. Dunaske Follow-on Admin. Proc. 34-87878 01/02/20 

In the Matter of Bradley C. Mascho Follow-on Admin. Proc. 34-87904 01/07/20 

In the Matter of J.P. Morgan Securities, LLC Stand-alone Admin. Proc. 33-10741 01/09/20 

In the Matter of Rick D. Mullins Follow-on Admin. Proc. 34-87933 01/10/20 

In the Matter of Jonathan Morrone Follow-on Admin. Proc. 34-87974 01/15/20 

In the Matter of Paul Jurberg Follow-on Admin. Proc. 34-87972 01/15/20 

In the Matter of Brett Hamburger Follow-on Admin. Proc. 34-87975 01/15/20 

In the Matter of Anthony Orth Follow-on Admin. Proc. 34-87973 01/15/20 

SEC v. Thomas Troy Brooks Civil LR-24718 01/15/20 

SEC v. Allan L. Lundervold Civil LR-24719 01/16/20 

In the Matter of Scott Charles Messier Follow-on Admin. Proc. 34-88034 01/24/20 

In the Matter of Jay Zola Scoratow Follow-on Admin. Proc. 34-88035 01/24/20 

In the Matter of Robert S. "Lute" Davis, Jr. Follow-on Admin. Proc. 34-88043 01/27/20 

In the Matter of Aaron R. Andrew Follow-on Admin. Proc. 34-88042 01/27/20 

30 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Gregory W. Anderson Follow-on Admin. Proc. 34-88041 01/27/20 

SEC v. Edward E. Matthes Civil LR-24726 01/28/20 

In the Matter of Donald Anthony Mackenzie Follow-on Admin. Proc. 34-88063 01/28/20 

In the Matter of Richard Fritts Follow-on Admin. Proc. 34-88061 01/28/20 

In the Matter of Gregory A. Koch Follow-on Admin. Proc. 34-88062 01/28/20 

In the Matter of Gary R. Smith Follow-on Admin. Proc. 34-88057 01/28/20 

In the Matter of Paramount Financial Services, Inc., 

d/b/a Live Abundant Follow-on Admin. Proc. 34-88070 01/29/20 

In the Matter of Jeffrey L. Wendel Follow-on Admin. Proc. 34-88073 01/29/20 

In the Matter of Charles N. Nilosek Follow-on Admin. Proc. 34-88071 01/29/20 

In the Matter of Jeffrey Goldman Follow-on Admin. Proc. 34-88072 01/29/20 

In the Matter of Daniel Markel Follow-on Admin. Proc. 34-88104 01/30/20 

In the Matter of Edward E. Matthes Follow-on Admin. Proc. 34-88114 02/03/20 

In the Matter of Gregory Lamont Drake Follow-on Admin. Proc. 34-88116 02/04/20 

In the Matter of Jason David St. Amour Follow-on Admin. Proc. 34-88117 02/04/20 

In the Matter of Glenn Joseph Story Follow-on Admin. Proc. 34-88121 02/05/20 

In the Matter of David Alan Wolfson Follow-on Admin. Proc. 34-88123 02/05/20 

In the Matter of ABN AMRO Clearing Chicago, LLC Stand-alone Admin. Proc. 34-88139 02/06/20 

In the Matter of Thomas Troy Brooks Follow-on Admin. Proc. 34-88150 02/07/20 

In the Matter of Martin J. Kinchloe Follow-on Admin. Proc. 34-88192 02/13/20 

In the Matter of Brett Pittsenbargar Follow-on Admin. Proc. 34-88290 02/26/20 

SEC v. John D. Fierro, et al. Civil LR-24748 02/26/20 

In the Matter of Yaniv Avnon, et al. Follow-on Admin. Proc. 34-88305 02/28/20 

In the Matter of Daniel B. Vazquez, Sr. Follow-on Admin. Proc. 34-88314 03/03/20 

In the Matter of Dennis M. Farrah Follow-on Admin. Proc. 34-88344 03/09/20 

In the Matter of BMA Securities, LLC Stand-alone Admin. Proc. 34-88371 03/12/20 

In the Matter of Gerald C. Parker Follow-on Admin. Proc. 34-88423 03/19/20 

In the Matter of Anthony B. Brandel, et al. Follow-on Admin. Proc. 34-88463 03/24/20 

SEC v. Justin W. Keener, d/b/a/ JMJ Financial Civil LR-24779 03/24/20 

In the Matter of Bryan Cohen Follow-on Admin. Proc. 34-88506 03/27/20 

In the Matter of Donald J. Fowler Follow-on Admin. Proc. 34-88529 03/31/20 

SEC v. Jonah Engler, a/k/a Jonah Engler-Silberman, et al. Civil LR-24788 03/31/20 

In the Matter of Cantor Fitzgerald & Co. Stand-alone Admin. Proc. 34-88567 04/06/20 

In the Matter of Ronald Hardy Follow-on Admin. Proc. 34-88650 04/15/20 

In the Matter of Sergio Ramirez Follow-on Admin. Proc. 34-88651 04/15/20 

In the Matter of Anthony Vassallo Follow-on Admin. Proc. 34-88652 04/15/20 

In the Matter of James Arthur Young, III Follow-on Admin. Proc. 34-88680 04/17/20 

In the Matter of Stephen Douglas Pizzuti Follow-on Admin. Proc. 34-88732 04/23/20 

In the Matter of Biltmore International Corporation Stand-alone Admin. Proc. 34-88744 04/24/20 

In the Matter of RBC Capital Markets, LLC Stand-alone Admin. Proc. 33-10777 04/24/20 

In the Matter of Anthony C. Ciccone Follow-on Admin. Proc. 34-88751 04/27/20 

In the Matter of Lee C. Schlesinger Follow-on Admin. Proc. 34-88773 04/29/20 

In the Matter of Bloomberg Tradebook, LLC Stand-alone Admin. Proc. 33-10783 05/06/20 

In the Matter of Lawrence E. Hagedorn Follow-on Admin. Proc. 34-88848 05/11/20 

In the Matter of Diane Kaylor Follow-on Admin. Proc. 34-88855 05/11/20 

In the Matter of Wallace Byers Follow-on Admin. Proc. 34-88860 05/12/20 

In the Matter of Sergey Pustelnik, a/k/a Serge Pustelnik Follow-on Admin. Proc. 34-88862 05/13/20 

31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Nicholas Fleming, a/k/a "Nick Franklin" Follow-on Admin. Proc. 34-88931 05/21/20 

In the Matter of Paul Ewer Follow-on Admin. Proc. 34-88936 05/22/20 

In the Matter of Robert Gilbert Follow-on Admin. Proc. 34-88937 05/22/20 

In the Matter of Warren A. Davis Follow-on Admin. Proc. 34-88962 05/27/20 

In the Matter of Gibraltar Global Securities, Inc. Follow-on Admin. Proc. 34-88965 05/28/20 

In the Matter of Todd A. Esh Follow-on Admin. Proc. 34-88991 06/02/20 

SEC v. Frederick M. Stow Civil 2020-132 06/11/20 

In the Matter of Michael Douglas Billings, et al. Follow-on Admin. Proc. 34-89144 06/24/20 

In the Matter of SG Americas Securities, LLC Stand-alone Admin. Proc. 34-89143 06/24/20 

In the Matter of Dain F. Stokes Follow-on Admin. Proc. 34-89159 06/25/20 

In the Matter of BNP Paribas Securities Corp. Stand-alone Admin. Proc. 34-89177 06/29/20 

In the Matter of Potamus Trading, LLC, et al. Stand-alone Admin. Proc. 33-10795 06/30/20 

In the Matter of Michael D. Tannen Stand-alone Admin. Proc. 33-10797 07/02/20 

In the Matter of Yong (Michael) Chen Follow-on Admin. Proc. 34-89249 07/08/20 

In the Matter of Jack Alan Abramoff Follow-on Admin. Proc. 34-89336 07/17/20 

In the Matter of Merlyn Curt Geisler Follow-on Admin. Proc. 34-89345 07/20/20 

SEC v. Mark L. Hopkins Civil LR-24856 07/24/20 

In the Matter of Celadon Financial Group, LLC Stand-alone Admin. Proc. 34-89404 07/27/20 

In the Matter of Interactive Brokers, LLC Stand-alone Admin. Proc. 34-89510 08/10/20 

In the Matter of Barbara Desiderio Follow-on Admin. Proc. 34-89522 08/11/20 

In the Matter of Hector Perez Follow-on Admin. Proc. 34-89523 08/11/20 

In the Matter of Joshua Turney Follow-on Admin. Proc. 34-89524 08/11/20 

SEC v. Ross Barish Civil LR-24868 08/13/20 

In the Matter of Garrett Gaylor Stand-alone Admin. Proc. 33-10818 08/13/20 

SEC v. Cecilia Millan, et al. Civil LR-24870 08/18/20 

SEC v. Minish "Joe" Hede, et al. Civil LR-24873 08/21/20 

In the Matter of Steven Pagartanis Follow-on Admin. Proc. 34-89629 08/21/20 

In the Matter of Dale Tenhulzen Follow-on Admin. Proc. 34-89647 08/24/20 

SEC v. Dominic A. Tropiano Civil LR-24878 08/27/20 

In the Matter of Christopher Barone Stand-alone Admin. Proc. 33-10828 08/27/20 

In the Matter of Richard Barone Stand-alone Admin. Proc. 34-89699 08/27/20 

In the Matter of Sean R. Stewart Follow-on Admin. Proc. 34-89720 09/01/20 

In the Matter of Anton Senderov, et al. Follow-on Admin. Proc. 34-89738 09/02/20 

SEC v. John M. Fife, et al. Civil LR-24886 09/03/20 

In the Matter of Steven M. Sexton Follow-on Admin. Proc. 34-89813 09/10/20 

In the Matter of Dominic Tropiano Follow-on Admin. Proc. 34-89829 09/11/20 

In the Matter of Emin Cohen Follow-on Admin. Proc. 34-89857 09/14/20 

In the Matter of Kenneth A. Stromsland Follow-on Admin. Proc. 34-89885 09/16/20 

In the Matter of Navian Capital Securities, LLC, et al. Stand-alone Admin. Proc. 34-89903 09/17/20 

In the Matter of Credit Suisse Securities (USA), LLC Stand-alone Admin. Proc. 34-89947 09/22/20 

In the Matter of JonesTrading Institutional Services, LLC Stand-alone Admin. Proc. 34-89975 09/23/20 

In the Matter of James Vincent Marino Follow-on Admin. Proc. 34-89983 09/24/20 

In the Matter of Emmanuel Kouyoumdjian, 

a/k/a "Manny K" Follow-on Admin. Proc. 34-89980 09/24/20 

In the Matter of Morgan Wilshire Securities, Inc. Stand-alone Admin. Proc. 34-89979 09/24/20 

In the Matter of Dana J. Bradley Follow-on Admin. Proc. 34-90013 09/25/20 

In the Matter of Marlin S. Hershey Follow-on Admin. Proc. 34-90009 09/25/20 

32 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Casimer Anthony Polanchek Follow-on Admin. Proc. 34-90030 09/28/20 

In the Matter of Brian Buckley Follow-on Admin. Proc. 34-90029 09/28/20 

In the Matter of Benjamin Mekawy Follow-on Admin. Proc. 34-90032 09/28/20 

In the Matter of Jeffrey Stebbins Follow-on Admin. Proc. 34-90040 09/29/20 

In the Matter of Gerald Allan Eaton Follow-on Admin. Proc. 34-90053 09/30/20 

In the Matter of Milton J. Dosal, Jr. Follow-on Admin. Proc. 34-90051 09/30/20 

In the Matter of Morgan Stanley & Co., LLC Stand-alone Admin. Proc. 34-90046 09/30/20 

In the Matter of Benjamin Durant, III Follow-on Admin. Proc. 34-90056 09/30/20 

DELINQUENT FILINGS 

In the Matter of BlueFire Renewables, Inc., et al. Stand-alone Admin. Proc. 34-87923 01/09/20 

In the Matter of CannaSys, Inc., et al. Stand-alone Admin. Proc. 34-87925 01/09/20 

In the Matter of Debt Resolve, Inc., et al. Stand-alone Admin. Proc. 34-87931 01/09/20 

In the Matter of Danka Business Systems, PLC Stand-alone Admin. Proc. 34-87922 01/09/20 

In the Matter of Franklin Scientific, Inc., et al. Stand-alone Admin. Proc. 34-87916 01/09/20 

In the Matter of Trimerica Energy Corporation, 

f/k/a Treaty Energy Corporation Stand-alone Admin. Proc. 34-87938 01/10/20 

In the Matter of Toshoan Holdings, Inc., et al. Stand-alone Admin. Proc. 34-87940 01/10/20 

In the Matter of United City Corp., et al. Stand-alone Admin. Proc. 34-87936 01/10/20 

In the Matter of GroGenesis, Inc., et al. Stand-alone Admin. Proc. 34-87949 01/13/20 

In the Matter of Piedmont Mining Company, Inc., et al. Stand-alone Admin. Proc. 34-87954 01/13/20 

In the Matter of Conversion Services International, 

Inc., et al. Stand-alone Admin. Proc. 34-87945 01/13/20 

In the Matter of Primera Foods Corporation, et al. Stand-alone Admin. Proc. 34-87947 01/13/20 

In the Matter of Mongolia Holdings, Inc., et al. Stand-alone Admin. Proc. 34-87961 01/14/20 

In the Matter of MediaWorx, Inc., et al. Stand-alone Admin. Proc. 34-87966 01/14/20 

In the Matter of Genoil, Inc., et al. Stand-alone Admin. Proc. 34-87979 01/15/20 

In the Matter of Great Basin Scientific, Inc. Stand-alone Admin. Proc. 34-87983 01/15/20 

In the Matter of Medical Innovation Holdings, Inc. Stand-alone Admin. Proc. 34-87996 01/16/20 

In the Matter of Soupman, Inc., et al. Stand-alone Admin. Proc. 34-87999 01/16/20 

In the Matter of Medigreen Holdings Corporation, 

a/k/a Rapid Fire Marketing, Inc. Stand-alone Admin. Proc. 34-88024 01/23/20 

In the Matter of Attis Industries, Inc. Stand-alone Admin. Proc. 34-88338 03/05/20 

In the Matter of Endless Charge, Inc. Stand-alone Admin. Proc. 34-88489 03/26/20 

In the Matter of PositiveID Corporation Stand-alone Admin. Proc. 34-88480 03/26/20 

In the Matter of Cybrdi, Inc. Stand-alone Admin. Proc. 34-88544 04/02/20 

In the Matter of American Realty Funds Corporation Stand-alone Admin. Proc. 34-88935 05/22/20 

In the Matter of Consorteum Holdings, Inc., et al. Stand-alone Admin. Proc. 34-89183 06/29/20 

In the Matter of Santa Fe Gold Corporation, et al. Stand-alone Admin. Proc. 34-89181 06/29/20 

In the Matter of Cyclone Power Technologies, Inc., et al. Stand-alone Admin. Proc. 34-89198 06/30/20 

In the Matter of Eos Petro, Inc., et al. Stand-alone Admin. Proc. 34-89204 06/30/20 

In the Matter of ERBA Diagnostics, Inc., et al. Stand-alone Admin. Proc. 34-89208 07/01/20 

In the Matter of Gilla, Inc., et al. Stand-alone Admin. Proc. 34-89210 07/01/20 

In the Matter of HypGen, Inc., et al. Stand-alone Admin. Proc. 34-89229 07/06/20 

In the Matter of Notis Global, Inc., et al. Stand-alone Admin. Proc. 34-89231 07/06/20 

In the Matter of Cür Media, Inc., et al. Stand-alone Admin. Proc. 34-89243 07/07/20 

In the Matter of Protalex, Inc., et al. Stand-alone Admin. Proc. 34-89245 07/07/20 

33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Sirrus Corp., et al. Stand-alone Admin. Proc. 34-89251 07/08/20 

In the Matter of Spotlight Innovation, Inc., et al. Stand-alone Admin. Proc. 34-89253 07/08/20 

In the Matter of Trans-Pacific Aerospace 

Company, Inc., et al. Stand-alone Admin. Proc. 34-89276 07/09/20 

In the Matter of Sky Resort International Limited, et al. Stand-alone Admin. Proc. 34-89278 07/09/20 

In the Matter of Synthonics Technologies, Inc. Stand-alone Admin. Proc. 34-89280 07/09/20 

In the Matter of Aspen Marine Group, Inc., et al. Stand-alone Admin. Proc. 34-89283 07/09/20 

In the Matter of EliteSoft Global, Inc., et al. Stand-alone Admin. Proc. 34-89284 07/09/20 

In the Matter of Wonhe High-Tech International, Inc. Stand-alone Admin. Proc. 34-89298 07/13/20 

In the Matter of World Moto, Inc. Stand-alone Admin. Proc. 34-89300 07/13/20 

In the Matter of Hidden Forest Acquisition Corp., et al. Stand-alone Admin. Proc. 34-89294 07/13/20 

In the Matter of Ultimate Products Corporation, et al. Stand-alone Admin. Proc. 34-89295 07/13/20 

In the Matter of Randolph Acquisitions, Inc. Stand-alone Admin. Proc. 34-89477 08/05/20 

In the Matter of Digiliti Money Group, Inc. Stand-alone Admin. Proc. 34-89644 08/24/20 

In the Matter of THT Heat Transfer Technology, Inc. Stand-alone Admin. Proc. 34-89642 08/24/20 

In the Matter of Agora Holdings, Inc. Stand-alone Admin. Proc. 34-89660 08/25/20 

In the Matter of All Marketing Solutions, Inc. Stand-alone Admin. Proc. 34-89665 08/25/20 

In the Matter of Billion Holding, Inc. Stand-alone Admin. Proc. 34-89650 08/25/20 

In the Matter of Celebiddy, Inc. Stand-alone Admin. Proc. 34-89649 08/25/20 

In the Matter of MC Informatics, Inc. Stand-alone Admin. Proc. 34-89648 08/25/20 

In the Matter of Spindle, Inc. Stand-alone Admin. Proc. 34-89680 08/26/20 

In the Matter of ForeverGreen Worldwide Corporation Stand-alone Admin. Proc. 34-89681 08/26/20 

In the Matter of ICTV Brands, Inc. Stand-alone Admin. Proc. 34-89688 08/27/20 

In the Matter of InventaBioTech, Inc. Stand-alone Admin. Proc. 34-89690 08/27/20 

In the Matter of WeedClub, Inc. Stand-alone Admin. Proc. 34-89696 08/27/20 

In the Matter of American Blockchain Biochar Corporation Stand-alone Admin. Proc. 34-89697 08/27/20 

In the Matter of Terra Telecommunications Corp. Stand-alone Admin. Proc. 34-89698 08/27/20 

In the Matter of Affiliated Food Stores, Inc. Stand-alone Admin. Proc. 34-89701 08/27/20 

In the Matter of GrandBanc, Inc. Stand-alone Admin. Proc. 34-89702 08/27/20 

In the Matter of Northsight Capital, Inc. Stand-alone Admin. Proc. 34-89714 08/31/20 

In the Matter of Oncolix, Inc. Stand-alone Admin. Proc. 34-89716 08/31/20 

In the Matter of US VR Global.com, Inc. Stand-alone Admin. Proc. 34-89726 09/01/20 

In the Matter of Green Technology Solutions, Inc. Stand-alone Admin. Proc. 34-89728 09/01/20 

In the Matter of Unifunds Limited Stand-alone Admin. Proc. 34-89742 09/02/20 

In the Matter of Rorine International Holding Corporation Stand-alone Admin. Proc. 34-89744 09/02/20 

In the Matter of Token Communities, Ltd. Stand-alone Admin. Proc. 34-89762 09/03/20 

In the Matter of AFH Acquisition IX, Inc. Stand-alone Admin. Proc. 34-89791 09/09/20 

In the Matter of American Gene Engineer Corp. Stand-alone Admin. Proc. 34-89815 09/10/20 

In the Matter of Armada Enterprises, LP, 

n/k/a BIM Homes, Inc. Stand-alone Admin. Proc. 34-89814 09/10/20 

In the Matter of Atlas Resources Series 33-2013, L.P. Stand-alone Admin. Proc. 34-89806 09/10/20 

In the Matter of Awareness for Teens, Inc. Stand-alone Admin. Proc. 34-89807 09/10/20 

In the Matter of Benaiah Holdings Group, Inc. Stand-alone Admin. Proc. 34-89808 09/10/20 

In the Matter of G.I. Joe's, Inc. Stand-alone Admin. Proc. 34-89810 09/10/20 

In the Matter of GRG, Inc., n/k/a EFT Holdings, Inc. Stand-alone Admin. Proc. 34-89811 09/10/20 

In the Matter of Gulf Biomedical Corporation, n/k/a 

Southern Star Energy Corporation Stand-alone Admin. Proc. 34-89812 09/10/20 

In the Matter of HD View 360, Inc. Stand-alone Admin. Proc. 34-89803 09/10/20 

34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Hollywood Entertainment Edu 

Holdings, Inc. Stand-alone Admin. Proc. 34-89804 09/10/20 

In the Matter of IHO-Agro International, Inc., 

n/k/a Grandwon Corp. Stand-alone Admin. Proc. 34-89821 09/10/20 

In the Matter of Krystal Industries, Inc. Stand-alone Admin. Proc. 34-89805 09/10/20 

In the Matter of Clontech Laboratories, Inc., 

n/k/a Takara Bio USA, Inc. Stand-alone Admin. Proc. 34-89837 09/11/20 

In the Matter of Escondido Innovations, Inc. Stand-alone Admin. Proc. 34-89838 09/11/20 

In the Matter of Franklin Hill Acquisition Corporation Stand-alone Admin. Proc. 34-89839 09/11/20 

In the Matter of REACH Genetics, Inc. Stand-alone Admin. Proc. 34-89840 09/11/20 

In the Matter of Royale Globe Holding, Inc. Stand-alone Admin. Proc. 34-89841 09/11/20 

In the Matter of Samdrew IX, Inc. Stand-alone Admin. Proc. 34-89842 09/11/20 

In the Matter of Life Critical Care Corporation Stand-alone Admin. Proc. 34-89851 09/14/20 

In the Matter of PeakSoft Multinet Corp. Stand-alone Admin. Proc. 34-89852 09/14/20 

In the Matter of Quest Entertainment Corp. Stand-alone Admin. Proc. 34-89853 09/14/20 

In the Matter of Samdrew VII, Inc. Stand-alone Admin. Proc. 34-89881 09/15/20 

In the Matter of Steri-Oss, Inc. Stand-alone Admin. Proc. 34-89882 09/15/20 

In the Matter of Smartag International, Inc. Stand-alone Admin. Proc. 34-89887 09/16/20 

In the Matter of Vape Holdings, Inc. Stand-alone Admin. Proc. 34-89892 09/16/20 

In the Matter of ExeLED Holdings, Inc. Stand-alone Admin. Proc. 34-89894 09/16/20 

In the Matter of Worldtek Corp., 

f/k/a Lundell Technologies, Inc. Stand-alone Admin. Proc. 34-89889 09/16/20 

In the Matter of Source Media, Inc. Stand-alone Admin. Proc. 34-89890 09/16/20 

In the Matter of Epoxy, Inc. Stand-alone Admin. Proc. 34-89904 09/17/20 

In the Matter of Ezy Cloud Holding, Inc. Stand-alone Admin. Proc. 34-89906 09/17/20 

In the Matter of Players Network, Inc. Stand-alone Admin. Proc. 34-89908 09/17/20 

In the Matter of The General Chemical Group, Inc. Stand-alone Admin. Proc. 34-89910 09/17/20 

In the Matter of Perkins Oil & Gas, Inc. Stand-alone Admin. Proc. 34-89918 09/18/20 

In the Matter of The MIIX Group, Incorporated Stand-alone Admin. Proc. 34-89919 09/18/20 

In the Matter of V3 Semiconductor, Inc. Stand-alone Admin. Proc. 34-89916 09/18/20 

In the Matter of Energy Conversion Services, Inc. Stand-alone Admin. Proc. 34-89917 09/18/20 

In the Matter of iHealthcare, Inc. Stand-alone Admin. Proc. 34-89921 09/18/20 

In the Matter of Tri Clean Enterprises, Inc. Stand-alone Admin. Proc. 34-89922 09/18/20 

In the Matter of HK eBus Corporation Stand-alone Admin. Proc. 34-89938 09/21/20 

In the Matter of Zenergy Brands, Inc. Stand-alone Admin. Proc. 34-89940 09/21/20 

In the Matter of Integral Technologies, Inc. Stand-alone Admin. Proc. 34-89943 09/21/20 

In the Matter of Progreen US, Inc. Stand-alone Admin. Proc. 34-89945 09/21/20 

In the Matter of Genesis Financial, Inc. Stand-alone Admin. Proc. 34-89953 09/22/20 

In the Matter of International Leaders Capital Corporation Stand-alone Admin. Proc. 34-89955 09/22/20 

In the Matter of Core Lithium Corp. Stand-alone Admin. Proc. 34-89957 09/22/20 

In the Matter of Vortex Blockchain Technologies, Inc. Stand-alone Admin. Proc. 34-89959 09/22/20 

In the Matter of Travco, Inc. Stand-alone Admin. Proc. 34-89950 09/22/20 

In the Matter of STRATABASE Stand-alone Admin. Proc. 34-89951 09/22/20 

In the Matter of TSLC I, Inc. Stand-alone Admin. Proc. 34-89965 09/23/20 

In the Matter of LHI Acquisition Corporation Stand-alone Admin. Proc. 34-89966 09/23/20 

In the Matter of the DLD Group, Inc. Stand-alone Admin. Proc. 34-89986 09/24/20 

In the Matter of the ID Perfumes, Inc. Stand-alone Admin. Proc. 34-89988 09/24/20 

In the Matter of the HS3 Technologies, Inc. Stand-alone Admin. Proc. 34-89978 09/24/20 

In the Matter of the LegacyXChange, Inc. Stand-alone Admin. Proc. 34-89981 09/24/20 

35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of the I-Wellness Marketing Group, Inc. Stand-alone Admin. Proc. 34-89992 09/24/20 

In the Matter of Custom Protection Services, Inc., 

f/k/a PowerChannel, Inc. Stand-alone Admin. Proc. 34-89985 09/24/20 

In the Matter of Spring Pharmaceutical Group, Inc. Stand-alone Admin. Proc. 34-89990 09/24/20 

In the Matter of HK Apollo Motors Corporation Stand-alone Admin. Proc. 34-90011 09/25/20 

In the Matter of Big Time Holdings, Inc. Stand-alone Admin. Proc. 34-90012 09/25/20 

In the Matter of Vitro Diagnostics, Inc. Stand-alone Admin. Proc. 34-90047 09/29/20 

FOREIGN CORRUPT PRACTICES ACT 

SEC v. Jerry Li Civil LR-24666 11/14/19 

SEC v. Telefonaktiebolaget LM Ericsson Civil 2019-254 12/06/19 

In the Matter of Tim Leissner Stand-alone Admin. Proc. 34-87750 12/16/19 

In the Matter of Cardinal Health, Inc. Stand-alone Admin. Proc. 34-88303 02/28/20 

SEC v. Asante K. Berko Civil LR-24794 04/13/20 

In the Matter of Eni S.p.A. Stand-alone Admin. Proc. 34-88679 04/17/20 

In the Matter of Novartis AG Stand-alone Admin. Proc. 34-89149 06/25/20 

In the Matter of Alexion Pharmaceuticals, Inc. Stand-alone Admin. Proc. 34-89214 07/02/20 

In the Matter of World Acceptance Corporation Stand-alone Admin. Proc. 34-89489 08/06/20 

In the Matter of Herbalife Nutrition, Ltd. Stand-alone Admin. Proc. 34-89704 08/28/20 

INSIDER TRADING 

SEC v. Bryan Cohen, et al. Civil LR-24649 10/18/19 

SEC v. Benjamin Taylor, et al. Civil LR-24650 10/22/19 

SEC v. John Special, et al. Civil LR-24690 12/12/19 

SEC v. John Kenneth Davidson Civil LR-24690 12/12/19 

SEC v. Janardhan Nellore, et al. Civil LR-24693 12/17/19 

SEC v. Songjiang Wang Civil LR-24697 12/20/19 

In the Matter of Michael Mindlin Stand-alone Admin. Proc. 34-87934 01/10/20 

SEC v. Jon L. Aronson, et al. Civil LR-24742 02/14/20 

SEC v. Bradley C. Davis Civil LR-24750 02/20/20 

In the Matter of Charles F. Kerwin Stand-alone Admin. Proc. 34-88274 02/24/20 

SEC v. Tomer Feingold, et al. Civil LR-24761 03/03/20 

SEC v. Scott O. Hirsch, et al. Civil LR-24772 03/17/20 

SEC v. David M. Mahan Civil LR-24782 03/26/20 

In the Matter of Benjamin Kirkland Stand-alone Admin. Proc. 34-88498 03/27/20 

In the Matter of Wei Duan Stand-alone Admin. Proc. 33-10778 04/30/20 

SEC v. Zhuobin Hong, et al. Civil LR-24810 05/04/20 

In the Matter of Jana Faith Kiena, CPA Stand-alone Admin. Proc. 34-89023 06/05/20 

In the Matter of DanDan Wu Stand-alone Admin. Proc. 34-89178 06/29/20 

In the Matter of Joseph Zhang Stand-alone Admin. Proc. 34-89350 07/21/20 

In the Matter of Edmond Leung Stand-alone Admin. Proc. 34-89352 07/21/20 

SEC v. Jack Brewer Civil LR-24863 08/06/20 

SEC v. Sepehr Sarshar Civil LR-24876 08/25/20 

In the Matter of Yue Li Stand-alone Admin. Proc. 34-89757 09/03/20 

SEC v. Richard M. Kirsch, et al. Civil LR-24892 09/10/20 

36 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Craig P. Moyes Stand-alone Admin. Proc. 34-89816 09/10/20 

SEC v. Steven J. Sheinfeld Civil LR-24903 09/17/20 

SEC v. Robert Hoddes Jacobs Civil LR-24908 09/21/20 

SEC v. Yinghang "James" Yang, et al. Civil LR-24909 09/21/20 

SEC v. Edward T. Kelly Civil LR-24912 09/23/20 

SEC v. Eric M. Hill Civil LR-24919 09/25/20 

In the Matter of Christopher D. Bachinski Stand-alone Admin. Proc. 34-90015 09/25/20 

In the Matter of Rachelle A. Thatcher Stand-alone Admin. Proc. 34-90016 09/25/20 

SEC v. Laksha Bohra, et al. Civil LR-24923 09/28/20 

INVESTMENT ADVISERS / INVESTMENT 

COMPANIES 

In the Matter of Donald Toomer, Jr. Follow-on Admin. Proc. 34-87326 10/17/19 

In the Matter of Thomas D. Conrad, Jr. Follow-on Admin. Proc. IA-5404 10/22/19 

In the Matter of Cameron G. High Follow-on Admin. Proc. 34-87426 10/31/19 

In the Matter of James T. Booth Follow-on Admin. Proc. 34-87447 11/01/19 

SEC v. Bolton Securities Corporation, d/b/a Bolton Global 

Asset Management Civil LR-24660 11/04/19 

SEC v. International Investment Group, LLC Civil 2019-244 11/21/19 

In the Matter of Channing Capital Management, LLC Stand-alone Admin. Proc. IA-5412 11/22/19 

In the Matter of International Investment Group, LLC Follow-on Admin. Proc. IA-5414 11/26/19 

SEC v. Lester Burroughs Civil LR-24681 12/04/19 

In the Matter of Kornitzer Capital Management, Inc., et al. Stand-alone Admin. Proc. IA-5416 12/10/19 

In the Matter of Randall S. Goulding Follow-on Admin. Proc. IA-5417 & 12/13/19 

34-88155 

SEC v. Suneet Singal, et al. Civil LR-24691 12/13/19 

SEC v. Keith Springer, et al. Civil LR-24695 12/19/19 

In the Matter of Stephen Condon Peters Follow-on Admin. Proc. IA-5425 01/06/20 

In the Matter of Lester W. Burroughs Follow-on Admin. Proc. 34-87967 01/14/20 

SEC v. Edward S. Walczak Civil 2020-21 01/27/20 

In the Matter of Catalyst Capital Advisors, LLC, et al. Stand-alone Admin. Proc. IA-5436 01/27/20 

In the Matter of Barton W. Stuck Follow-on Admin. Proc. IA-5439 01/31/20 

In the Matter of Cannell Capital, LLC Stand-alone Admin. Proc. IA-5441 02/04/20 

In the Matter of Jay Costa Kelter Follow-on Admin. Proc. IA-5442 02/06/20 

In the Matter of Joseph A. Meyer, Jr Follow-on Admin. Proc. 34-88153 02/07/20 

SEC v. Criterion Wealth Management Insurance 

Services, Inc., et al. Civil LR-24738 02/12/20 

In the Matter of BPU Investment Management, Inc. Stand-alone Admin. Proc. 34-88202 02/13/20 

SEC v. Kinetic Investment Group, LLC, et al. Civil LR-24767 02/20/20 

In the Matter of Marcus Boggs Follow-on Admin. Proc. 34-88256 02/21/20 

In the Matter of Lone Star Value Management, LLC, et al. Stand-alone Admin. Proc. IA-5448 02/24/20 

SEC v. Dionne Van Zyl Civil LR-24747 02/25/20 

In the Matter of Steven E. Fishman Stand-alone Admin. Proc. IA-5450 02/27/20 

In the Matter of Wells Fargo Clearing Services, LLC, et al. Stand-alone Admin. Proc. 34-88295 02/27/20 

In the Matter of Fortress Investment 

Management, LLC, et al. Stand-alone Admin. Proc. IA-5452 02/27/20 

In the Matter of Sica Wealth Management, LLC, et al. Stand-alone Admin. Proc. IA-5453 02/27/20 

In the Matter of Eric D. Lyons Follow-on Admin. Proc. IA-5458 03/04/20 

37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of E. Herbert Hafen Follow-on Admin. Proc. 34-88316 03/04/20 

In the Matter of Motty Mizrahi Follow-on Admin. Proc. IA-5457 03/04/20 

In the Matter of Bruce C. Worthington Follow-on Admin. Proc. 34-88347 03/10/20 

SEC v. Stacey L. Beane, et al. Civil LR-24769 03/12/20 

SEC v. Bradley C. Reifler, et al. Civil LR-24768 03/12/20 

In the Matter of Naya Ventures, LLC, et al. Stand-alone Admin. Proc. IA-5461 03/12/20 

In the Matter of HSBC Securities (USA), Inc. Stand-alone Admin. Proc. 34-88387 03/16/20 

SEC v. Brandon E. Copeland, et al. Civil LR-24773 03/18/20 

SEC v. Donald H. Hunter Civil LR-24780 03/24/20 

In the Matter of Nicholas J. Genovese Follow-on Admin. Proc. IA-5468 03/24/20 

In the Matter of Adam Matthew Root Follow-on Admin. Proc. IA-5471 04/01/20 

In the Matter of Geoffrey J. Thompson Follow-on Admin. Proc. IA-5474 04/07/20 

In the Matter of Cozad Asset Management, Inc. Stand-alone Admin. Proc. IA-5477 04/17/20 

In the Matter of Merrill Lynch, Pierce 

Fenner & Smith, Incorporated Stand-alone Admin. Proc. IA-5479 04/17/20 

In the Matter of Eagle Strategies, LLC Stand-alone Admin. Proc. IA-5480 04/17/20 

In the Matter of Old Ironsides Energy, LLC Stand-alone Admin. Proc. IA-5478 04/17/20 

In the Matter of Monomoy Capital Management, L.P. Stand-alone Admin. Proc. IA-5485 04/22/20 

In the Matter of N. Scott Gillis, CPA Follow-on Admin. Proc. IA-5484 04/22/20 

In the Matter of Robert J. Jesenik Follow-on Admin. Proc. IA-5482 04/22/20 

In the Matter of Brian A. Oliver Follow-on Admin. Proc. IA-5483 04/22/20 

SEC v. Donald J. Kellen Civil LR-24808 04/28/20 

In the Matter of Semper Capital Management, L.P. Stand-alone Admin. Proc. IA-5489 04/28/20 

In the Matter of Everest Capital, LLC, et al. Stand-alone Admin. Proc. IA-5491 04/30/20 

In the Matter of Monsoon Capital, LLC, et al. Stand-alone Admin. Proc. IA-5490 04/30/20 

In the Matter of Barry R. Bekkedam Follow-on Admin. Proc. IA-5497 05/05/20 

SEC v. TCA Fund Management Group Corp., et al. Civil LR-24815 05/11/20 

In the Matter of Stacy L. Beane Follow-on Admin. Proc. IA-5501 05/12/20 

In the Matter of Justin N. Deckert Follow-on Admin. Proc. IA-5500 05/12/20 

In the Matter of Travis Laska Follow-on Admin. Proc. IA-5502 05/12/20 

In the Matter of Morgan Stanley Smith Barney, LLC Stand-alone Admin. Proc. 34-88856 05/12/20 

SEC v. Ambassador Advisors, LLC, et al. Civil LR-24817 05/13/20 

In the Matter of TSP Capital Management Group, LLC Stand-alone Admin. Proc. IA-5508 05/22/20 

In the Matter of William Andrew Hightower Follow-on Admin. Proc. 34-88941 05/26/20 

In the Matter of Ares Management, LLC Stand-alone Admin. Proc. IA-5510 05/26/20 

In the Matter of Syed Arham Arbab Follow-on Admin. Proc. IA-5511 05/27/20 

In the Matter of Oxbow Advisors, LLC Stand-alone Admin. Proc. IA-5512 05/29/20 

In the Matter of U.S. Bancorp Investments, Inc. Stand-alone Admin. Proc. 34-88976 06/01/20 

In the Matter of William Vescio Stand-alone Admin. Proc. 33-10789 06/02/20 

SEC v. E*Hedge Securities, Inc., et al. Civil LR-24825 06/03/20 

In the Matter of Douglas Leighton Follow-on Admin. Proc. IA-5519 06/05/20 

In the Matter of Tamara Steele Follow-on Admin. Proc. 34-89021 06/05/20 

In the Matter of Louis Navellier, et al. Follow-on Admin. Proc. IA-5520 06/12/20 

In the Matter of Richard T. Diver Follow-on Admin. Proc. IA-5522 06/16/20 

In the Matter of Sultan S. Issa Follow-on Admin. Proc. IA-5524 06/17/20 

In the Matter of Gregory Alan Smith Follow-on Admin. Proc. IA-5527 06/26/20 

In the Matter of John Christopher Polit Follow-on Admin. Proc. 34-89171 06/29/20 

38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Frank Bianco Follow-on Admin. Proc. IA-5529 06/30/20 

In the Matter of Neil Burkholz Follow-on Admin. Proc. IA-5530 07/01/20 

In the Matter of Franklin Advisers, Inc., et al. Stand-alone Admin. Proc. IA-33919 07/02/20 

In the Matter of Benjamin Alderson Follow-on Admin. Proc. IA-5536 07/09/20 

In the Matter of BNB Wealth Management, LLC Stand-alone Admin. Proc. IA-5535 07/09/20 

In the Matter of Temenos Advisory, Inc. Follow-on Admin. Proc. IA-5540 07/14/20 

In the Matter of George L. Taylor Follow-on Admin. Proc. 34-89314 07/14/20 

In the Matter of Dionne Van Zyl Follow-on Admin. Proc. IA-5541 07/16/20 

In the Matter of First Western Capital 

Management Company Stand-alone Admin. Proc. IA-5543 07/16/20 

In the Matter of Robert Russel Tweed Follow-on Admin. Proc. 34-89332 07/16/20 

SEC v. David Hu Civil 2020-157 07/17/20 

SEC v. Michael Barry Carter Civil 2020-158 07/20/20 

In the Matter of Carlos Renato Cano Stand-alone Admin. Proc. 33-10806 07/22/20 

In the Matter of VALIC Financial Advisors, Inc. Stand-alone Admin. Proc. 34-89407 07/28/20 

In the Matter of VALIC Financial Advisors, Inc. Stand-alone Admin. Proc. 34-89405 07/28/20 

In the Matter of Birinyi Associates, Inc. Stand-alone Admin. Proc. IA-5555 07/31/20 

In the Matter of WBI Investments, Inc., et al. Stand-alone Admin. Proc. 34-89481 08/05/20 

In the Matter of Rialto Capital Management, LLC Stand-alone Admin. Proc. IA-5558 08/07/20 

SEC v. Brendan Matthew Ross Civil LR-24865 08/11/20 

In the Matter of SCF Investment Advisors, Inc. Stand-alone Admin. Proc. IA-5560 08/13/20 

SEC v. David C. Coggins, et al. Civil LR-24877 08/19/20 

In the Matter of NPB Financial Group, LLC Stand-alone Admin. Proc. 34-89624 08/20/20 

In the Matter of Patrick Morgan Schiro Follow-on Admin. Proc. IA-5564 08/24/20 

SEC v. Mark J. Boucher, et al. Civil LR-24875 08/25/20 

In the Matter of Aldo Marchena Follow-on Admin. Proc. IA-5566 08/27/20 

SEC v. Matthew O. Clason Civil LR-24881 09/01/20 

In the Matter of Signature Financial Services, Ltd. Stand-alone Admin. Proc. IA-5571 09/03/20 

SEC v. Steven D. Rodemer Civil LR-24891 09/03/20 

In the Matter of Vladislav Khalupsky Follow-on Admin. Proc. IA-5570 09/03/20 

In the Matter of SQN Capital Management, LLC Stand-alone Admin. Proc. IA-5573 09/04/20 

In the Matter of Alexander S. Gould Stand-alone Admin. Proc. IA-5574 09/08/20 

In the Matter of Graham, Bordelon, Golson & Gilbert, Inc. Stand-alone Admin. Proc. IA-5576 09/10/20 

SEC v. Hai Khoa Dang Civil LR-24890 09/10/20 

SEC v. RRBB Asset Management, LLC, et al. Civil LR-24894 09/10/20 

In the Matter of William D. King, CPA Stand-alone Admin. Proc. 34-89848 09/11/20 

In the Matter of Steven D. Rodemer Follow-on Admin. Proc. 34-89843 09/11/20 

In the Matter of John Geraci Follow-on Admin. Proc. IA-5580 09/14/20 

In the Matter of Coordinated Capital Securities, Inc. Stand-alone Admin. Proc. 34-89900 09/17/20 

In the Matter of Steven Fitzgerald Brown Follow-on Admin. Proc. IA-5583 09/17/20 

In the Matter of Gilder Gagnon Howe & Co., LLC, et al. Stand-alone Admin. Proc. IA-5582 09/17/20 

In the Matter of Northern Trust Hedge Fund 

Services, LLC, et al. Stand-alone Admin. Proc. IA-5585 09/18/20 

In the Matter of Keyport Venture Advisors, LLC, et al. Stand-alone Admin. Proc. IA-5584 09/18/20 

In the Matter of Palmer Square Capital Management, LLC Stand-alone Admin. Proc. IA-5586 09/21/20 

In the Matter of Steven Rosen Stand-alone Admin. Proc. 33-10851 09/24/20 

In the Matter of Michael Vernon Stand-alone Admin. Proc. 33-10849 09/24/20 

In the Matter of Platinum Wealth Partners, Inc., et al. Stand-alone Admin. Proc. 33-10852 09/24/20 

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In the Matter of Finser International Corporation, et al. Stand-alone Admin. Proc. IA-5593 09/24/20 

SEC v. Oscar Haynes Morris, Jr., et al. Civil LR-24916 09/24/20 

SEC v. Lindner Capital Advisors, Inc., et al. Civil LR-24922 09/25/20 

In the Matter of Hancock Whitney Investment Services, Inc. Stand-alone Admin. Proc. 34-90004 09/25/20 

In the Matter of Sabra Capital Partners, LLC, et al. Stand-alone Admin. Proc. IA-5594 09/25/20 

In the Matter of Creative Financial Designs, Inc. Stand-alone Admin. Proc. 34-90014 09/25/20 

In the Matter of Gary Edward Haynes Follow-on Admin. Proc. IA-5597 09/28/20 

SEC v. Clifton Curtis Sneed, Jr. Civil LR-24924 09/28/20 

SEC v. Corbin L. Lambert Civil LR-24925 09/28/20 

In the Matter of David C. Coggins Follow-on Admin. Proc. IA-5598 09/29/20 

In the Matter of Transamerica Asset Management, Inc. Stand-alone Admin. Proc. IA-5599 09/30/20 

In the Matter of Great Plains Trust Company, Inc. Stand-alone Admin. Proc. 33-10869 09/30/20 

In the Matter of Meredith A. Simmons, Esq. Stand-alone Admin. Proc. 34-90061 09/30/20 

ISSUER REPORTING / AUDITING AND 

ACCOUNTING 

In the Matter of Northwest Biotherapeutics, Inc. Stand-alone Admin. Proc. 34-87281 10/10/19 

In the Matter of John Busshaus, CPA Follow-on Admin. Proc. 33-10718 10/11/19 

In the Matter of UQM Technologies, Inc. Stand-alone Admin. Proc. 33-10719 10/11/19 

In the Matter of Calumet Specialty Products Partners, L.P. Stand-alone Admin. Proc. 34-87611 11/25/19 

SEC v. MiMedx Group, Inc., et al. Civil LR-24678 11/26/19 

SEC v. Bobby Peavler, et al. Civil LR-24683 12/05/19 

SEC v. Iconix Brand Group, Inc. Civil LR-24682 12/05/19 

SEC v. Neil R. Cole, et al. Civil LR-24682 12/05/19 

In the Matter of Warren Clamen, CPA Stand-alone Admin. Proc. 33-10730 12/05/19 

In the Matter of Jatindar Kapur, CPA Stand-alone Admin. Proc. 33-10731 12/05/19 

In the Matter of StoneMor Partners, L.P., et al. Stand-alone Admin. Proc. 34-87732 12/12/19 

In the Matter of MetLife, Inc. Stand-alone Admin. Proc. 34-87793 12/18/19 

In the Matter of Quantum Corporation Stand-alone Admin. Proc. 34-87812 12/20/19 

In the Matter of Robert A. Karmann, CPA Follow-on Admin. Proc. 34-87884 01/03/20 

In the Matter of Gregory L. Kelly, Esq. Follow-on Admin. Proc. 34-87968 01/15/20 

SEC v. Hill International, Inc., et al. Civil LR-24720 01/16/20 

In the Matter of DIAGEO plc Stand-alone Admin. Proc. 33-10756 02/19/20 

In the Matter of Wells Fargo & Company Stand-alone Admin. Proc. 34-88257 02/21/20 

In the Matter of RSM US, LLP, f/k/a/ McGladrey LLP Stand-alone Admin. Proc. 34-88287 02/26/20 

SEC v. SCANA Corporation, et al. Civil LR-24751 02/27/20 

In the Matter of David G. Dreslin, CPA Follow-on Admin. Proc. 34-88377 03/12/20 

In the Matter of Ronald Emma, CPA Follow-on Admin. Proc. 34-88432 03/20/20 

SEC v. Jeffrey D. Cordes, et al. Civil LR-24792 04/08/20 

In the Matter of Brian Robert Sodi, CPA Follow-on Admin. Proc. 34-88686 04/17/20 

In the Matter of Brian L. Ferdinand Stand-alone Admin. Proc. 33-10775 04/22/20 

In the Matter of Brian M. Storms Stand-alone Admin. Proc. 34-88724 04/22/20 

In the Matter of Kenneth D. Shifrin, CPA Stand-alone Admin. Proc. 34-88723 04/22/20 

In the Matter of PLS, CPA, A Professional Corporation, 

a/k/a PLS CPAs, et al. Stand-alone Admin. Proc. 34-88739 04/24/20 

In the Matter of William M. Aisenberg, CPA Follow-on Admin. Proc. 34-88763 04/28/20 

In the Matter of Todd H. Takeyasu, CA Follow-on Admin. Proc. 34-88791 05/01/20 

40 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Jeffery A. Curran, CA Follow-on Admin. Proc. 34-88808 05/05/20 

In the Matter of Timothy Daly, CPA Stand-alone Admin. Proc. 34-88895 05/18/20 

In the Matter of Michael Bellach, CPA Stand-alone Admin. Proc. 34-88896 05/18/20 

In the Matter of John Donovan, CPA Stand-alone Admin. Proc. 34-88897 05/18/20 

In the Matter of Christopher D. Larson, CPA Follow-on Admin. Proc. 34-88998 06/03/20 

In the Matter of Argo Group International Holdings, Ltd. Stand-alone Admin. Proc. 34-89009 06/04/20 

SEC v. AmTrust Financial Services, Inc., et al. Civil LR-24838 06/17/20 

In the Matter of VEREIT, Inc. Stand-alone Admin. Proc. 33-10793 06/23/20 

In the Matter of Michelle Dipp Stand-alone Admin. Proc. 33-10794 06/30/20 

In the Matter of Paul J. Konigsberg Follow-on Admin. Proc. 34-89326 07/15/20 

In the Matter of Valeant Pharmaceuticals International, 

Inc., n/k/a Bausch Health Companies, Inc. Stand-alone Admin. Proc. 33-10809 07/31/20 

In the Matter of J. Michael Pearson Stand-alone Admin. Proc. 33-10810 07/31/20 

In the Matter of Howard B. Schiller Stand-alone Admin. Proc. 33-10811 07/31/20 

In the Matter of Tanya R. Carro, CPA Stand-alone Admin. Proc. 33-10812 07/31/20 

In the Matter of Brian Dee Matlock, CPA Stand-alone Admin. Proc. 34-89552 08/13/20 

SEC v. Mark P. Frissora Civil LR-24869 08/13/20 

In the Matter of Super Micro Computer, Inc. Stand-alone Admin. Proc. 33-10822 08/25/20 

In the Matter of Howard Hideshima Stand-alone Admin. Proc. 34-89657 08/25/20 

In the Matter of Charles Liang Stand-alone Admin. Proc. 34-89658 08/25/20 

In the Matter of BorgWarner, Inc. Stand-alone Admin. Proc. 34-89677 08/26/20 

In the Matter of Henry Seth Brock, CPA Follow-on Admin. Proc. 34-89861 09/14/20 

In the Matter of the Registration Statement of Loyal 

Source Market Services, Inc. Stand-alone Admin. Proc. 33-10844 09/18/20 

In the Matter of the Registration Statement of 

Crest Radius, Inc. Stand-alone Admin. Proc. 33-10843 09/18/20 

In the Matter of RCI Hospitality Holdings, Inc., et al. Stand-alone Admin. Proc. 34-89935 09/21/20 

In the Matter of Steven L. Jenkins, CPA Stand-alone Admin. Proc. 34-89936 09/21/20 

SEC v. Revolution Lighting Technologies, Inc., et al. Civil LR-24915 09/24/20 

In the Matter of Power Solutions International, Inc. Stand-alone Admin. Proc. 34-89984 09/24/20 

In the Matter of Bayerische Motoren Werke 

Aktiengesellschaft, et al. Stand-alone Admin. Proc. 33-10850 09/24/20 

In the Matter of James L. Thompson, CPA Stand-alone Admin. Proc. 34-90008 09/25/20 

In the Matter of Lam D. Ha, CPA Stand-alone Admin. Proc. 34-90010 09/25/20 

SEC v. Frank G. Mueller Civil LR-24917 09/25/20 

In the Matter of Precigen, Inc., f/k/a Intrexon Corporation Stand-alone Admin. Proc. 34-89997 09/25/20 

In the Matter of Aeon Global Health Corp. Stand-alone Admin. Proc. 34-90003 09/25/20 

In the Matter of Fiat Chrysler Automobiles N.V. Stand-alone Admin. Proc. 34-90031 09/28/20 

In the Matter of Interface, Inc., et al. Stand-alone Admin. Proc. 33-10854 09/28/20 

In the Matter of Fulton Financial Corporation Stand-alone Admin. Proc. 34-90017 09/28/20 

In the Matter of Manitex International, Inc. Stand-alone Admin. Proc. 33-10860 09/29/20 

In the Matter of Andrew Rooke Stand-alone Admin. Proc. 33-10861 09/29/20 

In the Matter of Michael Schneider, CPA Stand-alone Admin. Proc. 33-10863 09/29/20 

In the Matter of Stephen Harrison Stand-alone Admin. Proc. 33-10862 09/29/20 

SEC v. Akazoo S. A. Civil None 09/30/20 

In the Matter of HP, Inc. Stand-alone Admin. Proc. 33-10868 09/30/20 

In the Matter of BGC Partners, Inc. Stand-alone Admin. Proc. 33-10867 09/30/20 

In the Matter of Hilton Worldwide Holdings, Inc. Stand-alone Admin. Proc. 34-90052 09/30/20 

41 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

MARKET MANIPULATION 

SEC v. Jeffrey Auerbach, et al. Civil LR-24637 10/04/19 

SEC v. Shuang Chen, et al. Civil LR-24648 10/15/19 

In the Matter of Michael J. Woodford, Esq. Follow-on Admin. Proc. 34-87764 12/16/19 

SEC v. Steve M. Bajic, et al. Civil LR-24712 01/02/20 

SEC v. Kenneth Ciapala, et al. Civil LR-24712 01/02/20 

SEC v. Ulrik Debo Civil LR-24705 01/02/20 

In the Matter of Luke Christopher Zouvas, Esq. Follow-on Admin. Proc. 34-87899 01/07/20 

In the Matter of Benjamin L. Bunker, Esq. Stand-alone Admin. Proc. 33-10748 01/23/20 

SEC v. Alex C. Procopio, et al. Civil LR-24730 01/29/20 

In the Matter of Faiyaz Dean Follow-on Admin. Proc. 34-88270 02/24/20 

SEC v. Bernard Findley, et al. Civil LR-24781 03/25/20 

SEC v. Douglas Leighton, et al. Civil LR-24791 04/07/20 

SEC v. Praxsyn Corporation, et al. Civil LR-24807 04/28/20 

SEC v. Turbo Global Partners, Inc., et al. Civil LR-24820 05/14/20 

SEC v. Gomes, et al. Civil LR-24839 06/09/20 

SEC v. Jason C. Nielsen Civil LR-24832 06/09/20 

In the Matter of Diane J. Harrison, Esq. Follow-on Admin. Proc. 34-89094 06/18/20 

In the Matter of Matthew Ledvina, Esq. Follow-on Admin. Proc. 34-89111 06/22/20 

In the Matter of Nicholas Mejia Scrivener Stand-alone Admin. Proc. 34-89517 08/10/20 

In the Matter of Milan K. Patel, Esq. Follow-on Admin. Proc. 34-89568 08/14/20 

SEC v. Peter DiChiara Civil LR-24884 09/03/20 

SEC v. Ongkaruck Sripetch, et al. Civil 2020-218 09/21/20 

SEC v. Todd Zinkwich Civil LR-24920 09/24/20 

SEC v. Ronald Phillips Civil None 09/28/20 

In the Matter of J.P. Morgan Securities, LLC Stand-alone Admin. Proc. 33-10858 09/29/20 

SEC v. Drew Morgan Ciccarelli Civil LR-24940 09/30/20 

SEC v. Patrick Jevon Johnson, et al. Civil LR-24937 09/30/20 

SEC v. Joel Stohlman, et al. Civil LR-24935 09/30/20 

MISCELLANEOUS 

In the Matter of Gordon Caplan, Esq. Follow-on Admin. Proc. 34-88119 02/05/20 

In the Matter of Richard Jeffrey Rubin Stand-alone Admin. Proc. 34-88258 02/21/20 

In the Matter of Thomas J. Craft, Jr. Stand-alone Admin. Proc. 34-88280 02/25/20 

In the Matter of 1Globe Capital, LLC, et al. Stand-alone Admin. Proc. 34-88864 05/13/20 

SEC v. Vu Anh Nguyen, et al. Civil LR-24864 08/11/20 

In the Matter of WCAS Management Corporation Stand-alone Admin. Proc. 34-89914 09/17/20 

NATL REC STAT RATING ORG (NRSRO) 

In the Matter of Sebastin Pinto-Thomaz Follow-on Admin. Proc. 34-87504 11/12/19 

In the Matter of Morningstar Credit Ratings, LLC Stand-alone Admin. Proc. 34-88880 05/15/20 

In the Matter of Kroll Bond Rating Agency, LLC Stand-alone Admin. Proc. 34-90036 09/29/20 

In the Matter of Kroll Bond Rating Agency, LLC Stand-alone Admin. Proc. 34-90037 09/29/20 

42 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PUBLIC FINANCE ABUSE 

In the Matter of Boenning & Scattergood, Inc., et al. Stand-alone Admin. Proc. 34-88662 04/16/20 

SEC v. William Alfred Batchelor, et al. Civil LR-24806 04/27/20 

In the Matter of Jerry E. Orellana Stand-alone Admin. Proc. 34-88784 04/30/20 

In the Matter of William S. Costas Stand-alone Admin. Proc. 34-89346 07/20/20 

In the Matter of John J. Marvin Stand-alone Admin. Proc. 34-89347 07/20/20 

In the Matter of UBS Financial Services, Inc. Stand-alone Admin. Proc. 34-89348 07/20/20 

In the Matter of Roosevelt & Cross, Inc. Stand-alone Admin. Proc. 33-10837 09/14/20 

In the Matter of Thomas Vigorito Stand-alone Admin. Proc. 33-10838 09/14/20 

In the Matter of William W. Welsh Stand-alone Admin. Proc. 33-10839 09/14/20 

SEC v. Park View School, Inc. et al. Civil 2020-208 09/14/20 

In the Matter of Eliseo Sampayo Stand-alone Admin. Proc. 34-89961 09/22/20 

In the Matter of Funding the Gap, LLC, et al. Stand-alone Admin. Proc. 34-90002 09/25/20 

SECURITIES OFFERING 

SEC v. Anton Senderov, et al. Civil LR-24641 10/09/19 

SEC v. Richard Andrew Mallion Civil LR-24642 10/10/19 

SEC v. Telegram Group, Inc., et al. Civil 2019-212 10/11/19 

SEC v. Joseph Bayliss, et al. Civil LR-24651 10/22/19 

In the Matter of XBT Corp Sarl, d/b/a First Global Credit Stand-alone Admin. Proc. 33-10723 10/31/19 

SEC v. Richard Johnathan Eden, et al. Civil LR-24657 10/31/19 

In the Matter of Jan D. Atlas, Esq. Follow-on Admin. Proc. 34-87446 11/01/19 

In the Matter of Bethany Liou, et al. Stand-alone Admin. Proc. 33-10725 11/04/19 

SEC v. Dale Scott Pearlman Civil LR-24657 11/04/19 

SEC v. Ruless Pierre, a/k/a Rules Pierre, et al. Civil LR-24670 11/06/19 

SEC v. KRM Services, LLC, et al. Civil LR-24662 11/08/19 

SEC v. Rishi Shah, et al. Civil LR-24675 11/14/19 

SEC v. Neil Burkholz, et al. Civil LR-24669 11/14/19 

SEC v. NIT Enterprises, Inc., et al. Civil LR-24679 11/21/19 

SEC v. Conrad A. Coggeshall, et al. Civil LR-24673 11/22/19 

SEC v. Brett Pittsenbargar, et al. Civil LR-24676 11/25/19 

SEC v. Nanotech Engineering, Inc., et al. Civil LR-24688 12/05/19 

SEC v. Palm Beach Atlantic Financial Group, LLC, et al. Civil LR-24689 12/11/19 

SEC v. Eran Eyal, et al. Civil 2019-259 12/11/19 

SEC v. Robert A. Karmann Civil LR-24692 12/17/19 

SEC v. Sam A. Antar Civil LR-24694 12/17/19 

In the Matter of Blockchain of Things, Inc. Stand-alone Admin. Proc. 33-10736 12/18/19 

SEC v. Edward Espinal, et al. Civil LR-24708 12/19/19 

SEC v. Todays Growth Consultant, Inc., et al. Civil LR-24717 12/27/19 

SEC v. Steven A. Schwartz Civil LR-24707 01/06/20 

SEC v. ARO Equity, LLC, et al. Civil LR-24710 01/08/20 

SEC v. Donald G. Blakstad, et al. Civil LR-24711 01/08/20 

In the Matter of John James Sheehan, Jr. Stand-alone Admin. Proc. 33-10742 01/10/20 

SEC v. Gregory Lamont Drake, et al. Civil LR-24718 01/15/20 

SEC v. Scott Charles Messier, et al. Civil LR-24718 01/15/20 

43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC v. Daniel Markel Civil LR-24721 01/17/20 

SEC v. Boaz Manor, a/k/a Shaun MacDonald, et al. Civil 2020-12 01/17/20 

SEC v. Guy Scott Griffithe, et al. Civil LR-24722 01/21/20 

SEC v. Sergii "Sergey" Grybniak, et al. Civil LR-24723 01/21/20 

SEC v. Jeffrey P. Carpoff, et al. Civil LR-24724 01/24/20 

SEC v. Michael Douglas Billings, et al. Civil LR-24731 01/28/20 

SEC v. Philip E. Riehl Civil LR-24728 01/29/20 

SEC v. Mark Nicholas Pyatt, et al. Civil LR-24741 02/10/20 

SEC v. Brian Davison, et al. Civil LR-24740 02/11/20 

SEC v. Michael W. Ackerman Civil LR-24737 02/11/20 

In the Matter of Marc A. Celello, Esq. Follow-on Admin. Proc. 34-88205 02/13/20 

In the Matter of Enigma MPC Stand-alone Admin. Proc. 33-10755 02/19/20 

In the Matter of Steven Seagal Stand-alone Admin. Proc. 33-10760 02/27/20 

In the Matter of Shawn Severson Stand-alone Admin. Proc. 33-10761 02/28/20 

SEC v. Christopher Joseph Bongiorno, et al. Civil LR-24754 02/28/20 

SEC v. Brook Church-Koegel, et al. Civil LR-24759 03/05/20 

SEC v. Joe Leland Tarver, et al. Civil LR-24777 03/10/20 

SEC v. Denis Georgiyevich Sotnikov, et al. Civil LR-24770 03/13/20 

SEC v. Meta 1 Coin Trust, et al. Civil LR-24775 03/16/20 

SEC v. Todd Lahr, et al. Civil LR-24778 03/24/20 

SEC v. Adam Matthew Root Civil LR-24783 03/26/20 

SEC v. Teshuater, LLC, et al. Civil LR-24787 04/02/20 

SEC v. OwnZones Media Network, Inc., et al. Civil LR-24786 04/02/20 

SEC v. Matthew S. Hilliard, et al. Civil LR-24797 04/16/20 

SEC v. Phillip W. Conley Civil LR-24798 04/16/20 

SEC v. Steven L. Brickner Civil LR-24800 04/21/20 

SEC v. Renew Spinal Care, Inc., et al. Civil LR-24802 04/22/20 

SEC v. Phillip Hudnall, et al. Civil LR-24803 04/23/20 

SEC v. Dropil, Inc., et al. Civil LR-24804 04/23/20 

In the Matter of Jeffrey G. Klein Follow-on Admin. Proc. 34-88747 04/24/20 

In the Matter of American Bondholders 

Foundation, LLC, et al. Stand-alone Admin. Proc. 33-10779 04/30/20 

In the Matter of Wendy Lieberman Kirkland, et al. Stand-alone Admin. Proc. 34-88797 05/01/20 

SEC v. CAN Capital, Inc. Civil LR-24811 05/04/20 

SEC v. Damon Elliott, et al. Civil LR-24813 05/06/20 

SEC v. Daniel F. Putnam, et al. Civil LR-24829 05/07/20 

SEC v. Clinton Maurice Tucker, II Civil LR-24814 05/11/20 

SEC v. Ronald D. Swanson Civil LR-24818 05/14/20 

In the Matter of Ronald D. Swanson, a/k/a Ronald D. 

Swanson-Cerna Follow-on Admin. Proc. 34-88865 05/14/20 

SEC v. Applied Biosciences Corp. Civil LR-24819 05/14/20 

SEC v. Paul Russell Montgomery, Jr., et al. Civil LR-24821 05/18/20 

SEC v. Paul Horton Smith, Sr., et al. Civil LR-24822 05/19/20 

SEC v. William Sadleir Civil LR-24824 05/22/20 

SEC v. Robert W. Wilson Civil LR-24823 05/26/20 

In the Matter of BitClave PTE, Ltd. Stand-alone Admin. Proc. 33-10788 05/28/20 

SEC v. Hvizdzak Capital Management, LLC, et al. Civil 2020-137 06/16/20 

SEC v. Vassilios Trikantzopoulos, et al. Civil LR-24840 06/18/20 

44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In the Matter of Todd H. Lahr, Esq. Follow-on Admin. Proc. 34-89139 06/24/20 

SEC v. NAC Foundation, LLC, et al. Civil 2020-145 06/25/20 

SEC v. Jack Alan Abramoff Civil 2020-145 06/25/20 

In the Matter of David Rumsey Stand-alone Admin. Proc. 33-10796 07/01/20 

SEC v. Matthew Benjamin, et al. Civil LR-24846 07/01/20 

In the Matter of Ralph C. Greaves, Esq. Follow-on Admin. Proc. 34-89221 07/06/20 

In the Matter of Plutus Financial, Inc., d/b/a Abra, et al. Stand-alone Admin. Proc. 33-10801 07/13/20 

SEC v. Thunderbird Power Corp., et al. Civil LR-24853 07/14/20 

In the Matter of Abetterfincialplan.com, LLC, 

d/b/a A Better Financial Plan, et al. Stand-alone Admin. Proc. 33-10802 07/14/20 

SEC v. YouPlus, Inc., et al. Civil LR-24854 07/20/20 

In the Matter of Irth Communications, LLC, et al. Stand-alone Admin. Proc. 33-10805 07/22/20 

SEC v. Complete Business Solutions Group, Inc., 

d/b/a PAR Funding, et al. Civil LR-24860 07/24/20 

SEC v. Daniel K. Boice, et al. Civil 2020-162 07/24/20 

SEC v. Anthony Todd Johnson, a/k/a Todd Johnson, et al. Civil LR-24857 07/28/20 

SEC v. Clarence Dean Alford Civil 2020-168 07/30/20 

SEC v. Victor Lee Farias, et al. Civil LR-24861 07/30/20 

SEC v. Dale Tenhulzen, et al. Civil LR-24866 08/13/20 

In the Matter of Kelvin Boon, LLC, et al. Stand-alone Admin. Proc. 33-10817 08/13/20 

SEC v. Dennis M. Jali, et al. Civil 2020-198 08/28/20 

SEC v. Gary S. Wykle, a/k/a Gary S. Wyckel, et al. Civil LR-24882 08/31/20 

SEC v. John Brian McLane, Jr., et al. Civil LR-24880 08/31/20 

SEC v. Sexton Advisory Group, Inc., et al. Civil LR-24883 09/02/20 

SEC v. Geoffrey J. Thompson Civil LR-24887 09/03/20 

In the Matter of Covalent Collective, Inc. Stand-alone Admin. Proc. 33-10833 09/03/20 

In the Matter of National Financial Services, LLC Stand-alone Admin. Proc. 33-10832 09/03/20 

In the Matter of FuelCell Energy, Inc. Stand-alone Admin. Proc. 33-10831 09/03/20 

SEC v. Steven Fitzgerald Brown Civil LR-24888 09/03/20 

SEC v. Daniel R. Kamensky Civil 2020-203 09/03/20 

SEC v. Kirk Sperry, et al. Civil LR-24889 09/09/20 

SEC v. FLiK, et al. Civil LR-24899 09/10/20 

SEC v. Remington Chase, a/k/a William Westwood, 

a/k/a William Elliott Civil LR-24895 09/11/20 

In the Matter of Clifford Harris, Jr. Stand-alone Admin. Proc. 33-10836 09/11/20 

SEC v. Gary F. Pryor, et al. Civil LR-24898 09/14/20 

SEC v. The Estate of Richard Ventrilla, et al. Civil LR-24901 09/14/20 

In the Matter of Frederick Mintz Follow-on Admin. Proc. 34-89872 09/15/20 

In the Matter of Alan Fraade Follow-on Admin. Proc. 34-89873 09/15/20 

In the Matter of Unikrn, Inc. Stand-alone Admin. Proc. 33-10841 09/15/20 

SEC v. Scott Allen Fries Civil LR-24902 09/17/20 

SEC v. Adam P. Rogas, et al. Civil LR-24905 09/17/20 

SEC v. Milton J. Dosal, Jr. Civil LR-24907 09/21/20 

SEC v. Verley Lee Sembritzky, Jr., et al. Civil LR-24910 09/22/20 

In the Matter of Daniel C. Masters Stand-alone Admin. Proc. 33-10847 09/23/20 

In the Matter of Alan J. Kau Stand-alone Admin. Proc. 33-10848 09/23/20 

SEC v. James M. Rudnick Civil LR-24914 09/24/20 

SEC v. Craig A. Zabala, et al. Civil LR-24913 09/24/20 

In the Matter of SoluTech, Inc., et al. Stand-alone Admin. Proc. 33-10853 09/25/20 

45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC v. Mark Schena Civil 2020-224 09/25/20 

In the Matter of Raymond Allan Fine Stand-alone Admin. Proc. 33-10855 09/28/20 

In the Matter of David Taylor Stand-alone Admin. Proc. 33-10856 09/28/20 

In the Matter of Scott Eugene Bachman Stand-alone Admin. Proc. 33-10857 09/28/20 

SEC v. Andrew Dale Ledbetter, Esq. Civil LR-24926 09/29/20 

SEC v. Mason D. Newman, a/k/a Barry Weiss Civil LR-24936 09/29/20 

SEC v. Christian J. Baquerizo, a/k/a "Teddy Stone", et al. Civil LR-24936 09/29/20 

SEC v. Todd W. Mixon Civil LR-24931 09/29/20 

SEC v. Thomas J. Gity, Sr., et al. Civil LR-24930 09/29/20 

SEC v. Sebastian Silea, et al. Civil LR-24929 09/29/20 

SEC v. Roger Nils-Jonas Karlsson, a/k/a Euclid Diodorus, 

Steve Heyden, Joshua Millard, and Lars Georgsson Civil LR-24932 09/29/20 

SEC v. Lewis I. Wallach Civil LR-24928 09/29/20 

In the Matter of Salt Blockchain Inc., 

f/k/a Salt Lending Holdings, Inc. Stand-alone Admin. Proc. 33-10865 09/30/20 

SEC v. Robert McCabe, et al. Civil LR-24934 09/30/20 

SEC v. Rand Heckler, et al. Civil LR-24938 09/30/20 

SEC v. Michael Staisil Civil LR-24933 09/30/20 

TRANSFER AGENT 

In the Matter of VStock Transfer, LLC Stand-alone Admin. Proc. 34-89687 08/27/20 

46 
 

 

 

 

 

 

 

 

 

 

 

ENDNOTES 

1 Press Release 2020-38, Wells Fargo to Pay $500 Million for Misleading Investors About the Success of Its 

Largest Business Unit (Feb. 21, 2020), available at https://www.sec.gov/news/press-release/2020-38 2 Press Release 2019-212, SEC Halts Alleged $1.7 Billion Unregistered Digital Token Offering (Oct. 11, 2019), 

available at https://www.sec.gov/news/press-release/2019-212 3 Press Release 2020-146, Telegram to Return $1.2 Billion to Investors and Pay $18.5 Million Penalty to Settle 

SEC Charges (June 26, 2020), available at https://www.sec.gov/news/press-release/2020-146 4 Press Release 2020-169, Pharmaceutical Company and Former Executives Charged With Misleading 

Financial Disclosures (July 31, 2020), available at https://www.sec.gov/news/press-release/2020-169 5 Press Release 2020-223, SEC Charges BMW for Disclosing Inaccurate and Misleading Retail Sales 

Information to Bond Investors (Sept. 24, 2020), available at https://www.sec.gov/news/press-release/2020-223 6 Press Release 2020-44, SEC Charges South Carolina Energy Companies, Former Executives With Defrauding 

Investors (Feb.27, 2020), available at https://www.sec.gov/news/press-release/2020-44 7 Press Release 2020-144, SEC Charges Novartis AG with FCPA Violations (June 25, 2020), available at 

https://www.sec.gov/news/press-release/2020-144 8 Press Release 2019-254, SEC Charges Multinational Telecommunications Company With FCPA Violations 

(Dec. 6, 2019), available at https://www.sec.gov/news/press-release/2019-254 9 Press Release 2020-233, J.P. Morgan Securities Admits to Manipulative Trading in U.S. Treasuries (Sept. 29, 

2020), available at https://www.sec.gov/news/press-release/2020-233 10 Press Release 2020-169, Pharmaceutical Company and Former Executives Charged With Misleading 

Financial Disclosures (July 31, 2020), available at https://www.sec.gov/news/press-release/2020-169 11 Press Release 2019-260, SEC Charges Former Goldman Sachs Executive With FCPA Violations (Dec. 16, 

2019), available at https://www.sec.gov/news/press-release/2019-260 12 Press Release 2019-251, SEC Charges Iconix Brand Group and Former Top Executives With Accounting 

Fraud (Dec. 5, 2019), available at https://www.sec.gov/news/press-release/2019-251 13 Press Release 2020-115, SEC Charges Three Former Audit Partners for Exam Sharing Misconduct (May 18, 

2010), available at https://www.sec.gov/news/press-release/2020-115 14 Press Release 2020-164, SEC Charges VALIC Financial Advisors with Failing to Disclose Payments to 

Promote Services to Florida Educators (July 28, 2020), available at https://www.sec.gov/news/press-release/2020- 164 15 Press Release 2020-43, SEC Charges Wells Fargo In Connection With Investment Recommendation 

Practices (Feb. 27, 2020), available at https://www.sec.gov/news/press-release/2020-43 16 Press Release 2020-240, SEC Whistleblower Program Ends Record-Setting Fiscal Year With Four Additional 

Awards (Sept. 30, 2020), available at https://www.sec.gov/news/press-release/2020-240 17 Press Release 2020-266, SEC Issues Record $114 Million Whistleblower Award (Oct. 22, 2020), available at 

https://www.sec.gov/news/press-release/2020-266 18 Press Release 2020-204, SEC Announces Final Distribution in WG Trading Investment Fraud, Totaling Over 

$1 Billion Returned to Harmed Investors (Sept. 11, 2020), available at https://www.sec.gov/news/press- release/2020-204 19 Our average was 24.1 months, second-fastest in the last five years, behind only 2019. 20 Press Release 2020-203, SEC Charges Fund Manager for Fraud in Securities Offering in Neiman Marcus 

Bankruptcy (Sept. 3, 2020), available at https://www.sec.gov/news/press-release/2020-203 21 Press Release 2020-127, Insurance Company Settles SEC Charges for Failing to Disclose Executive Perks 

(June 4, 2020), available at https://www.sec.gov/news/press-release/2020-127 22 Press Release 2020-242, SEC Charges Hospitality Company for Failing to Disclose Executive Perks (Sept. 

30, 2020), available at https://www.sec.gov/news/press-release/2020-242 23 Press Release 2020-223, SEC Charges BMW for Disclosing Inaccurate and Misleading Retail Sales 

Information to Bond Investors (Sept. 24, 2020), available at https://www.sec.gov/news/press-release/2020-223 24 Administrative Proceeding File No. 3-20105, Denver Investment Adviser Settles Charges for Disclosure 

Failures (Sept. 30, 2020), available at https://www.sec.gov/enforce/ia-5599-s 25 Press Release 2020-226, SEC Charges Companies, Former Executives as Part of Risk-Based Initiative (Sept. 

28, 2020), available at https://www.sec.gov/news/press-release/2020-226 26 Press Release 2020-242, SEC Charges Hospitality Company for Failing to Disclose Executive Perks (Sept. 

30, 2020), available at https://www.sec.gov/news/press-release/2020-242 27 Press Release 2020-221, SEC Charges Lighting Products Company and Four Executives With Accounting 

Violations (Sept. 24, 2020), available at https://www.sec.gov/news/press-release/2020-221 28 Press Release 2020-190, SEC Charges Super Micro and Former CFO in Connection with Widespread 

Accounting Violations (Aug. 25, 2020), available at https://www.sec.gov/news/press-release/2020-190 

47 
 

 

 

 

 

 

 

 

 

 

 

29 Press Release 2020-222, Engine Manufacturing Company to Pay Penalty, Take Remedial Measures to Settle 

Charges of Accounting Fraud (Sept. 24, 2020), available at https://www.sec.gov/news/press-release/2020-222 30 Press Release 2019-251, SEC Charges Iconix Brand Group and Former Top Executives With Accounting 

Fraud (Dec. 5, 2019), available at https://www.sec.gov/news/press-release/2019-251 31 Litigation Release No. 24678, SEC Charges Biotech Company and Executives with Accounting Fraud (Nov. 

26, 2019), available at https://www.sec.gov/litigation/litreleases/2019/lr24678.htm 32 Press Release 2020-237, SEC Charges Manitex International and Three Former Senior Executives With 

Accounting Fraud (Sept. 29, 2020), available at https://www.sec.gov/news/press-release/2020-237 33 Press Release 2019-241, SEC Charges Former Top Executives of Healthcare Advertising Company With 

$487 Million Fraud (Nov. 25, 2019), available at https://www.sec.gov/news/press-release/2019-241 34 Litigation Release No. 24720, SEC Charges Construction Management Consulting Company and Former 

Employees with Accounting Fraud (Jan. 17, 2020), available at 

https://www.sec.gov/litigation/litreleases/2020/lr24720.htm 35 Press Release 2020-36, SEC Charges Global Alcohol Producer with Disclosure Failures (Feb. 19, 2020), 

available at https://www.sec.gov/news/press-release/2020-36 36 Press Release 2020-44, SEC Charges South Carolina Energy Companies, Former Executives With 

Defrauding Investors (Feb. 27, 2020), available at https://www.sec.gov/news/press-release/2020-44 37 Press Release 2020-230, Fiat Chrysler Agrees to Pay $9.5 Million Penalty for Disclosure Violations (Sept. 

28, 2020), available at https://www.sec.gov/news/press-release/2020-230 38 Press Release 2020-241, SEC Charges HP Inc. With Disclosure Violations and Control Failures (Sept. 30, 

2020), available at https://www.sec.gov/news/press-release/2020-241 39 Press Release 2020-38, Wells Fargo to Pay $500 Million for Misleading Investors About the Success of Its 

Largest Business Unit (Feb. 21, 2020), available at https://www.sec.gov/news/press-release/2020-38 40 Press Release 2020-223, SEC Charges BMW for Disclosing Inaccurate and Misleading Retail Sales 

Information to Bond Investors (Sept. 24, 2020), available at https://www.sec.gov/news/press-release/2020-223 41 Press Release 2020-169, Pharmaceutical Company and Former Executives Charged With Misleading 

Financial Disclosures (July 31, 2020), available at https://www.sec.gov/news/press-release/2020-169 42 Administrative Proceeding File No. 3-20107, SEC Charges BGC Partners with Making False and Misleading 

Disclosures Concerning a Key Non-GAAP Financial Measure (Sept. 30, 2020), available at 

https://www.sec.gov/enforce/33-10867-s 43 Administrative Proceeding File No. 3-19831, SEC Settles Fraud Charges with Vereit (June 23, 2020), 

available at https://www.sec.gov/enforce/33-10793-s 44 Press Release 2020-90, SEC Orders Three Self-Reporting Advisory Firms to Reimburse Investors (Apr. 17, 

2020), available at https://www.sec.gov/news/press-release/2020-90 45 Press Release 2020-182, Advisory Firm Settles Charges of Defrauding Investors, Agrees to Refund Allegedly 

Ill-Gotten Gains to Harmed Clients (Aug. 13, 2020), available at https://www.sec.gov/news/press-release/2020-182 

(the same firm was also charged for failing to disclose conflicts related to its selection of fee-paying classes of 

mutual funds, which it had not self-reported under the Share Class Initiative). 46 Press Release 2020-109, SEC Charges Morgan Stanley Smith Barney With Providing Misleading Information 

to Retail Clients (May 12, 2020), available at https://www.sec.gov/news/press-release/2020-109 47 Public Statement, Statement from Stephanie Avakian and Steven Peikin, Co-Directors of the SEC’s Division 

of Enforcement, Regarding Market Integrity (Mar. 23, 2020), available at https://www.sec.gov/news/public- statement/statement-enforcement-co-directors-market-integrity 48 Investor Alert: Look Out for Coronavirus-Related Investment Scams (Feb. 4, 2020, updated Sept. 28, 2020), 

available at https://www.sec.gov/oiea/investor-alerts-and-bulletins/ia_coronavirus 49 Press Release 2020-132, SEC Charges Broker Who Defrauded Seniors Out of Almost $1 Million (June 12, 

2020), available at https://www.sec.gov/news/press-release/2020-132 50 Press Release 2019-271, SEC Files Charges in Ponzi Scheme Targeting Hispanic Community (Dec. 19, 

2019), available at https://www.sec.gov/news/press-release/2019-271 51 Press Release 2020-198, SEC Charges Ponzi Scheme Targeting African Immigrants (Aug. 28, 2020), 

available at https://www.sec.gov/news/press-release/2020-198 52 Press Release 2020-26, SEC Brings Charges Against Fraud Targeting Amish and Mennonite Investors (Jan. 

31, 2020), available at https://www.sec.gov/news/press-release/2020-26 53 Press Release 2020-167, SEC Charges CEO and Company With Defrauding First Responders and Others Out 

of Millions (July 30, 2020), available at https://www.sec.gov/news/press-release/2020-167 54 Press Release 2020-216, SEC Charges Ponzi Scheme Targeting U.S. Military Service Members (Sept. 21, 

2020), available at https://www.sec.gov/news/press-release/2020-216 

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55 Video, SEC Fireside Chat: A Video and Q&A About Red Flags of Investment Fraud Affecting the Deaf, 

Hard of Hearing and Hearing Loss Communities (Sept. 29, 2020), available at https://www.sec.gov/news/sec- videos/protecting-hearing-loss-communities-fraud 56 Press Release 2020-232, SEC Charges Swedish National with Global Scheme Defrauding Retail Investors, 

Including Deaf Community Members (Sept. 29, 2020), available at https://www.sec.gov/news/press-release/2020- 232 57 Press Release 2020-29, ABN AMRO Clearing Chicago Charged With Improper Handling of ADRs (Feb. 6, 

2020), available at https://www.sec.gov/news/press-release/2020-29; see also SEC Enforcement of Pre-Released 

ADRs, available at https://www.sec.gov/adr-enforcement 58 Press Release 2020-104, SEC Charges Bloomberg Tradebook for Order Routing Misrepresentations (May 6, 

2020), available at https://www.sec.gov/news/press-release/2020-104 59 Press Release 2020-175, SEC Charges Affiliated Advisers for Misrepresentations About Payment for Order 

Flow Arrangements (Aug. 5, 2020), available at https://www.sec.gov/news/press-release/2020-175 60 Press Release 2020-112, SEC Orders Credit Rating Agency to Pay $3.5 Million for Conflicts of Interest 

Violations (May 15, 2020), available at https://www.sec.gov/news/press-release/2020-112 61 Press Release 2020-235, SEC Charges Ratings Agency With Internal Controls Failures in Connection With 

Ratings of CMBS and CLO Combo Notes (Sept. 29, 2020), available at https://www.sec.gov/news/press- release/2020-235 62 Press Release 2020-228, SEC Charges Amazon Finance Manager and Family With Insider Trading (Sept. 28, 

2020), available at https://www.sec.gov/news/press-release/2020-228 63 Press Release 2019-261, Silicon Valley IT Administrator and Friends Charged in Multimillion Dollar Insider 

Trading Ring (Dec.17, 2019), available at https://www.sec.gov/news/press-release/2019-261 64 Press Release 2020-217, SEC Charges Index Manager and Friend With Insider Trading (Sept. 21, 2020), 

available at https://www.sec.gov/news/press-release/2020-217 65 Litigation Release No. 24649, SEC Obtains Asset Freeze and Charges Banker and Trader in International 

Insider Trading Scheme (Oct. 18, 2019), available at https://www.sec.gov/litigation/litreleases/2019/lr24649.htm 66 Litigation Release No. 24650, SEC Charges Two Bankers and Trader in Serial International Insider Trading 

Scheme (Oct. 22, 2019), available at https://www.sec.gov/litigation/litreleases/2019/lr24650.htm 67 Litigation Release No. 24761, SEC Charges Two Additional Traders in International Insider Trading Scheme 

(Mar. 6, 2020), available at https://www.sec.gov/ /litreleases/2020/lr24761.htm 68 Press Release 2020-123, Private Equity Firm Ares Management LLC Charged With Compliance Failures 

(May 26, 2020), available at https://www.sec.gov/news/press-release/2020-123 69 Press Release, 2019-216, SEC Charges 18 Traders in $31 Million Stock Manipulation Scheme (Oct. 16, 

2019), available at https://www.sec.gov/news/press-release/2019-216 70 Press Release 2019-236 SEC Wins Jury Trial in Layering, Manipulative Trading Case (Nov. 12, 2019), 

available at https://www.sec.gov/news/press-release/2019-236 71 See Administrative Proceeding File No. 3-20139, In the Matter of Mohammed Ali Rashid (October 26, 2020), 

available at https://www.sec.gov/litigation/admin/2020/ia-5620.pdf 72 Press Release 2019-212, SEC Halts Alleged $1.7 Billion Unregistered Digital Token Offering (Oct. 11, 

2019), available at https://www.sec.gov/news/press-release/2019-212 73 Press Release 2020-146, Telegram to Return $1.2 Billion to Investors and Pay $18.5 Million Penalty to Settle 

SEC Charges (June 26, 2020), available at https://www.sec.gov/news/press-release/2020-146 74 Litigation Release No. 24871, SEC Wins Summary Judgment Against Florida Unregistered Dealers (Aug. 20, 

2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24871.htm 75 Press Release 2020-262, SEC Obtains Final Judgment Against Kik Interactive For Unregistered Offering 

(Oct.21, 2020), available at https://www.sec.gov/news/press-release/2020-262 76 Press Release 2020-164, SEC Charges VALIC Financial Advisors with Failing to Disclose Payments to 

Promoted Services to Florida Educators (July 28, 2020), available at https://www.sec.gov/news/press-release/2020- 164 77 Press Release 2020-124, Unregistered $25.5 Million ICO Issuer to Return Money for Distribution to 

Investors (May 28, 2020), available at https://www.sec.gov/news/press-release/2020-124 78 Press Release 2019-212, SEC Halts Alleged $1.7 Billion Unregistered Digital Token Offering (Oct. 11, 

2019), available at https://www.sec.gov/news/press-release/2019-212 79 Press Release 2020-218, SEC Obtains Emergency Asset Freeze, Charges Ring of Microcap Stock 

Manipulators Targeting Retail Investors (Sept. 23, 2020), available at https://www.sec.gov/news/press-release/2020- 218 

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80 Press Release 2019-256, Jefferies to Pay Nearly $4 Million for Improper Handling of ADRs (Dec. 9, 2019), 

available at https://www.sec.gov/news/press-release/2019-256; Press Release 2019-268, ABM AMRO Clearing 

Charged with Improper Handling of ADRs (Dec. 18, 2019), available at https://www.sec.gov/news/press- release/2019-256 81 Press Release 2020-109, SEC Charges Morgan Stanley Smith Barney with Providing Misleading Information 

to Retail Clients (May 12, 2020), available at https://www.sec.gov/news/press-release/2020-109 82 Press Release 2020-238, Morgan Stanley Agrees to Pay $5 Million for Reg SHO Violations in Prime 

Brokerage Swaps Business (Sept. 30, 2020), available at https://www.sec.gov/news/press-release/2020-238 83 Press Release 2020-178, SEC Charges Interactive Brokers with Repeatedly Failing to File Suspicious 

Activity Reports (Aug. 10, 2020), available at https://www.sec.gov/news/press-release/2020-178 84 Press Release 2019-268, SEC Charges Broker-Dealers With Illicitly Profiting in Partial Tender Offer (Dec. 

18, 2019), available at https://www.sec.gov/news/press-release/2019-268 85 Press Release 2020-142, SG Americas to Pay $3.1 Million to Settle Charges of Providing Deficient Blue 

Sheet Data (June 24, 2020), available at https://www.sec.gov/news/press-release/2020-142 86 Administrative Proceeding File No. 3-20050, SEC Charges Broker-Dealer with Failing to Preserve Required 

Electronic Records (Sept. 23, 2020), available at https://www.sec.gov/enforce/34-89975-s 87 Administrative Proceeding File No. 3-19710, SEC Charges Audit Firm for Improper Professional Conduct 

(Feb. 26, 2020), available at https://www.sec.gov/enforce/34-88287-s 88 Press Release 2019-269, MetLife to Pay $10 Million for Longstanding Internal Control Failures (Dec. 18, 

2019), available at https://www.sec.gov/news/press-release/2019-269 89 Press Release 2020-222, Engine Manufacturing Company to Pay Penalty, Take Remedial Measures to Settle 

Charges of Accounting Fraud (Sept. 24, 2020), available at https://www.sec.gov/news/press-release/2020-222 90 Press Release 2020-195, SEC Charges BorgWarner for Materially Misstating its Financial Statements (Aug. 

26, 2020), available at https://www.sec.gov/news/press-release/2020-195 91 Administrative Proceeding File No. 3-19616, SEC Charges Cemetery and Funeral Home Operator and Its 

General Partner with Disclosure Failures (Dec. 12, 2019), available at https://www.sec.gov/enforce/34-87732-s 92 Litigation Release No. 24792, SEC Charges Former Executives of Apparel Company with Accounting Fraud 

(Apr. 8, 2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24792.htm 93 Administrative Proceeding File Nos. 3-20035 and 3-20036, SEC Charges Texas Company, Executives, and 

Former Board Member with Disclosure Failures (Sept. 21, 2020), available at https://www.sec.gov/enforce/34-

89935-s 94 Administrative Proceeding File No. 19767, Audit Firm Charged with Back-Dating Audit Work Papers 

Provided to SEC and PCAOB (Apr. 24, 2020), available at https://www.sec.gov/enforce/34-88739-s 95 Administrative Proceeding File No. 3-19626, SEC Charges Quantum with Internal Accounting Controls 

Failures (Dec. 20, 2019), available at https://www.sec.gov/enforce/34-87812-s 96 Press Release 2020-159, UBS to Pay $10 Million for Violating Rules Which Give Priority to Retail Investors 

in Municipal Offerings (July 20, 2020), available at https://www.sec.gov/news/press-release/2020-159 97 Administrative Proceeding File Nos. 3-19996, 3-19997, and 3-19998, SEC Charges Roosevelt & Cross and 

Two of its Salespeople for Retail Order Period Misconduct in Municipal Offerings (Sept. 14, 2020), available at 

https://www.sec.gov/enforce/33-10837-s 98 Press Release 2020-208, SEC Charges Charter School Operator and its Former President With Fraudulent 

Municipal Bond Offering (Sept. 14, 2020), available at https://www.sec.gov/news/press-release/2020-208 99 Litigation Release No. 24806, SEC Charges Two California Charter School Officials with Misleading 

Investors in Bond Offering (Apr. 27, 2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24806.htm 100 Press Release 2019-253, SEC Charges Trucking Executives with Accounting Fraud (Dec. 5, 2019), available 

at https://www.sec.gov/news/press-release/2019-253 101 Press Release 2020-115, SEC Charges Three Former Audit Partners for Exam Sharing Misconduct (May 18, 

2010), available at https://www.sec.gov/news/press-release/2020-115 102 Press Release 2020-183, SEC Charges Hertz’s Former CEO with Aiding and Abetting Company’s Financial 

Reporting and Disclosure Violations (Aug. 13, 2020), available at https://www.sec.gov/news/press-release/2020-

103 Press Release 2020-135, Insurance Company and Former CFO Charged with Faulty Loss Reserve 

Disclosures (June 17, 2020), available at https://www.sec.gov/news/press-release/2020-135 104 Press Release 2019-258, SEC Obtains Asset Freeze to Halt Alleged Offering Fraud (Dec. 10, 2019), 

available at https://www.sec.gov/news/press-release/2019-258 105 Press Release 2019-214, Supervisor Charged for Role in Brokerage Firm’s Improper Handling of ADRs 

(Oct. 15, 2019), available at https://www.sec.gov/news/press-release/2019-214 106 Press Release 2019-227, SEC Charges Issuer and CEO with Violating Whistleblower Protection Laws to 

Silence Investor Complaints (Nov. 4, 2019), available at https://www.sec.gov/news/press-release/2019-227 

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107 Press Release 2020-131, SEC Charges Microcap Fraud Scheme Participants Attempting to Capitalize on the 

COVID-19 Pandemic (June 11, 2020), available at https://www.sec.gov/news/press-release/2020-131 108 Press Release 2020-128, SEC Charges California Trader Engaged in Manipulative Trading Scheme 

Involving COVID-19 Claims (June 9, 2020), available at https://www.sec.gov/news/press-release/2020-128 109 Press Release 2020-111, SEC Charges Companies and CEO for Misleading COVID-19 Claims (May 14, 

2020), available at https://www.sec.gov/news/press-release/2020-111 110 Id. 111 Press Release 2020-97, SEC Charges Company and CEO for COVID-19 Scam (Apr. 28, 2020), available at 

https://www.sec.gov/news/press-release/2020-97 112 Press Release, 2020-224. SEC Charges Top Executive of California Microcap Company for Misleading 

Claims Concerning COVID-19 Test and Financial Statements (Sept. 25, 2020), available at 

https://www.sec.gov/news/press-release/2020-224 113 Press Release 2019-259, SEC Charges Founder, Digital Asset Issuer with Fraudulent ICO (Dec 11, 2019), 

available at https://www.sec.gov/news/press-release/2019-259 114 Press Release 2020-145, SEC Charges Issuer, CEO, and Lobbyist With Defrauding Investors in AML 

BitCoin (June 25, 2020), available at https://www.sec.gov/news/press-release/2020-145 115 Press Release 2020-124, Unregistered $25.5 Million ICO Issuer to Return Money for Distribution to 

Investors (May 28, 2020), available at https://www.sec.gov/news/press-release/2020-124 116 Press Release 2020-211, Unregistered ICO Issuer Agrees to Disable Tokens and Pay Penalty for Distribution 

to Harmed Investors (Sept. 15, 2020), available at https://www.sec.gov/news/press-release/2020-211 117 Press Release 2020-181, SEC Charges Issuer and CEO With Misrepresenting Platform Technology in 

Fraudulent ICO (Aug. 13, 2020), available at https://www.sec.gov/news/press-release/2020-181 118 Press Release 2020-42, Actor Steven Seagal Charged With Unlawfully Touting Digital Asset Offering (Feb. 

27, 2020), available at https://www.sec.gov/news/press-release/2020-42 119 Litigation Release No. 24810, SEC Charges Husband and Wife in Insider Trading Scheme (May 5, 2020), 

available at https://www.sec.gov/litigation/litreleases/2020/lr24810.htm 120 Litigation Release No. 24892, SEC Charges Two Former Petmed Executives with Insider Trading (Sept. 10, 

2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24892.htm 121 Litigation Release No. 24912, SEC Charges Former Controller of Now-Bankrupt Company with Insider 

Trading (Sept. 23, 2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24912.htm 122 Litigation Release No. 24908, SEC Charges Investor Relations Consultant with Insider Trading (Sept. 21, 

2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24908.htm 123 Litigation Release No. 24782, SEC Charges Pharmacy Chain Employee with Insider Trading (March 26, 

2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24782.htm; Litigation Release No. 24903, SEC 

Charges Pharmacy Chain Employee with Insider Trading (Sept. 17, 2020), available at 

https://www.sec.gov/litigation/litreleases/2020/lr24903.htm 124 Litigation Release No. 24863, SEC Charges Former Investment Adviser with Insider Trading (Aug. 6, 

2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24863.htm 125 Litigation Release No. 24919, SEC Charges North Carolina Man with Insider Trading (Sept. 25, 2020), 

available at https://www.sec.gov/litigation/litreleases/2020/lr24919.htm 126 Press Release 2020-197, SEC Charges Herbalife With FCPA Violations (Aug. 28, 2020), available at 

https://www.sec.gov/news/press-release/2020-197 127 Press Release 2020-149, SEC Charges Alexion Pharmaceuticals with FCPA Violations (July 2, 2020), 

available at https://www.sec.gov/news/press-release/2020-149 128 Press Release 2020-177. SEC Charges Consumer Loan Company with FCPA Violations (Aug. 6, 2020), 

available at https://www.sec.gov/news/press-release/2020-177 129 Litigation Release No. 24794, SEC Charges Former Executive of Financial Services Company with FCPA 

Violations, (Apr. 13, 2020), available at https://www.sec.gov/litigation/litreleases/2020/lr24794.htm 130 Press Release 2019-241, SEC Charges Former Top Executives of Healthcare Advertising Company With 

$487 Million Fraud (Nov. 25, 2019), available at https://www.sec.gov/news/press-release/2019-241 131 Press Release (USAO ND Ill), Former Executives and Employees of Health Technology Company Outcome 

Health Charged in $1 Billion Fraud Scheme (Nov. 25, 2019), available at https://www.justice.gov/usao- ndil/pr/former-executives-and-employees-health-technology-company-outcome-health-charged-1 132 Press Release 2020-1, SEC Charges Six Individuals in International Microcap Fraud Schemes (Jan. 2, 2020), 

available at https://www.sec.gov/news/press-release/2020-1 133 Press Release (USAO SDNY), Swiss Asset Management Firm And Its Owner Charged In Manhattan Federal 

Court For Orchestrating Stock Manipulation Scheme (Jan. 2, 2020), available at https://www.justice.gov/usao- sdny/pr/swiss-asset-management-firm-and-its-owner-charged-manhattan-federal-court-orchestrating 

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61 

134 Press Release 2020-18, SEC Charges Husband and Wife with Nearly $1 Billion Ponzi Scheme (Jan. 24, 

2020), available at https://www.sec.gov/news/press-release/2020-18 135 Press Release (USAO ED Cal), Top Executives Plead Guilty to Participating in a Billion Dollar Ponzi 

Scheme—the Biggest Criminal Fraud Scheme in the History of the Eastern District of California (Jan. 24, 2020), 

available at https://www.justice.gov/usao-edca/pr/top-executives-plead-guilty-participating-billion-dollar-ponzi- scheme-biggest-criminal 136 Press Release 2020-61, SEC Charges Russian National for Defrauding Older Investors of Over $26 Million 

in Phony Certificates of Deposit Scam (Mar. 13, 2020), available at https://www.sec.gov/news/press-release/2020-

137 Press Release (USAO DNJ), Florida Man Charged With Money Laundering In $30 Million Wire Fraud 

Scheme (Mar. 13, 2020), available at https://www.justice.gov/usao-nj/pr/florida-man-charged-money-laundering- 30-million-wire-fraud-scheme 138 Press Release 2020-162, SEC Charges Trustify Inc. and Founder in $18.5 Million Offering Fraud (July 24, 

2020), available at https://www.sec.gov/news/press-release/2020-162 139 Press Release (USAO ED Va), Former CEO and Founder of Technology Company Charged in Investment 

Fraud Scheme (July 24, 2020), available at https://www.justice.gov/usao-edva/pr/former-ceo-and-founder- technology-company-charged-investment-fraud-scheme 140 Press Release 2020-122, SEC Charges Owner of Film Distribution Company with Defrauding Publicly 

Traded Fund (May 22, 2020), available at https://www.sec.gov/news/press-release/2020-122 141 Press Release (USAO SDNY), Former Chairman And CEO Of Movie Production Company Arrested On 

Fraud Charges (May 22, 2020), available at https://www.justice.gov/usao-sdny/pr/former-chairman-and-ceo-movie- production-company-arrested-fraud-charges 142 Press Release 2020-236, SEC Charges Former Real Estate Executive With Misappropriating $26 Million in 

Ponzi Scheme (Sept. 29, 2020), available at https://www.sec.gov/news/press-release/2020-236 143 Press Release (USAO ND Cal), Los Angeles Man Charged with Running $350 Million Ponzi Scheme (Sept. 

29, 2020), available at https://www.justice.gov/usao-ndca/pr/los-angeles-man-charged-running-350-million-ponzi- scheme 144 Press Release 2019-234, SEC Charges Adviser for Running Ponzi Scheme Targeting Haitian Community 

(Nov. 6, 2019), available at https://www.sec.gov/news/press-release/2019-234 145 Press Release (USAO SDNY), Rockland County Man Charged With Multimillion-Dollar Ponzi And 

Embezzlement Schemes (Nov. 6, 2019), available at https://www.justice.gov/usao-sdny/pr/rockland-county-man- charged-running-multimillion-dollar-ponzi-and-embezzlement-schemes 146 Press Release 2020-72, SEC Charges Unregistered Penny Stock Dealer (Mar. 24, 2020), available at 

https://www.sec.gov/news/press-release/2020-72 147 Press Release 2020-153, SEC Charges App Developer for Unregistered Security-Based Swap Transactions 

(July 13, 2020), available at https://www.sec.gov/news/press-release/2020-153 148 Press Release 2020-168, SEC Charges Former Georgia State Legislator With Defrauding Investors in Ponzi 

Scheme (July 30, 2020), available at https://www.sec.gov/news/press-release/2020-168 149 Press Release 2020-35, SEC Charges Real Estate Company and Executives With Defrauding Retail 

Investors, Obtains Emergency Relief (Feb. 18, 2020), available at https://www.sec.gov/news/press-release/2020-35 150 Administrative Proceeding File No. 3-19957, SEC Charges Broker-Dealer and Issuer with Shelf Offering 

Violations (Sept. 3, 2020), available at https://www.sec.gov/enforce/33-10831-s 

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