UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 99764 / March 19, 2024

SECURITIES ACT OF 1933

Release No. 11278 / March 19, 2024

ACCOUNTING AND AUDITING ENFORCEMENT

Release No. 4494 / March 19, 2024

ADMINISTRATIVE PROCEEDING

File No. 3-21896

In the Matter of

IMRAN PAREKH, 

Respondent.

ORDER INSTITUTING PUBLIC

ADMINISTRATIVE PROCEEDINGS

PURSUANT TO RULE 102(e) OF THE 

COMMISSION’S RULES OF PRACTICE, 

MAKING FINDINGS, AND IMPOSING 

REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate and in 

the public interest that public administrative proceedings be, and hereby are, instituted against 

Imran Parekh (“Respondent” or “Parekh”) pursuant to Rule 102(e)(3)(i) of the Commission’s 

Rules of Practice.1 

II.

In anticipation of the institution of these proceedings, Respondent has submitted an Offer 

of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the 

purpose of these proceedings and any other proceedings brought by or on behalf of the 

Commission, or to which the Commission is a party, and without admitting or denying the 

1 Rule 102(e)(3)(i) provides, in relevant part, that:

The Commission, with due regard to the public interest and without preliminary hearing, 

may, by order, . . . suspend from appearing or practicing before it any . . . accountant . . . who has

been by name . . . permanently enjoined by any court of competent jurisdiction, by reason of his 

or her misconduct in an action brought by the Commission, from violating or aiding and abetting 

the violation of any provision of the Federal securities laws or of the rules and regulations

thereunder.
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findings herein, except as to the Commission’s jurisdiction over him and the subject matter of 

these proceedings, and the findings contained in Section III.3 below, which are admitted, 

Respondent consents to the entry of this Order Instituting Public Administrative Proceedings 

Pursuant to Rule 102(e) of the Commission’s Rules of Practice, Making Findings, and Imposing 

Remedial Sanctions (“Order”), as set forth below. 

III.

 On the basis of this Order and Respondent’s Offer, the Commission finds that: 

1. Imran Parekh, age 42, is a resident of Hopkinton, Massachusetts. From 2016 to 

August 2018, he was the Finance Director for the Aquatics & Disinfection Division – Americas 

at Evoqua Water Technologies Corp. (“Evoqua”). Parekh is not currently and has never been 

registered as an accountant. Parekh most recently worked as the CFO of a private company with 

offices in North Carolina and New York. 

2. Evoqua Water Technologies Corp. is a Delaware corporation headquartered in 

Pittsburgh, Pennsylvania. Evoqua describes itself as a provider of water treatment solutions. In 

October 2017, Evoqua registered its common stock with the Commission pursuant to Section 

12(b) of the Securities Exchange Act of 1934 (“Exchange Act”), and its stock traded on the New 

York Stock Exchange under the symbol AQUA. 

3. On July 10, 2023, a judgment was entered against Parekh, permanently enjoining 

him from future violations of Section 17(a) of the Securities Act of 1933, Sections 10(b) and 

13(b)(5) of the Exchange Act and Rules 10b-5 and 13b2-1 thereunder, and aiding and abetting 

violations of Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act and Rules 12b-20, 

13a-1, 13a-11, and 13a-13 thereunder, in the civil action entitled Securities and Exchange 

Commission v. Evoqua Water Technologies Corp. et al., Civil Action No. 1:23-cv-00105-MSMPAS, in the United States District Court for the District of Rhode Island (“Civil Action”). On 

March 15, 2024, a final judgment was entered against Parekh in the Civil Action, ordering him to 

pay $5,489 in disgorgement, $1,342 in prejudgment interest, and a $40,000 civil money penalty, 

and barring him for a period of ten years from serving as an officer or director of a public 

company. 

4. The Commission’s complaint alleged, among other things, that from at least the 

fourth quarter of 2016 through August 2018, Parekh, as the Finance Director of one of Evoqua’s 

divisions, knowingly or recklessly engaged in accounting practices that operated as a fraud and 

resulted in Evoqua improperly recognizing revenue and reporting materially false revenue 

amounts in its financial statements filed with the Commission. The Complaint alleged that 

Parekh knowingly or recklessly inflated the revenue Evoqua reported quarterly and at year-end 

by improperly accounting for “bill-and-hold” transactions, for which Evoqua recognized revenue 

from the sale of filtration products without meeting recognized bill-and-hold criteria or following 

relevant accounting principles. As a result, Evoqua recognized revenue earlier than accounting 

principles permitted.
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IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest 

to impose the sanction agreed to in Respondent Parekh’s Offer.

Accordingly, it is hereby ORDERED, effective immediately, that:

A. Parekh is suspended from appearing or practicing before the Commission as an 

accountant. 

B. After ten years from the date of the Order, Parekh may request that the 

Commission consider Parekh’s reinstatement by submitting an application to the attention of the 

Office of the Chief Accountant.

C. In support of any application for reinstatement to appear and practice before the 

Commission as a preparer or reviewer, or a person responsible for the preparation or review, of 

financial statements of a public company to be filed with the Commission, other than as a 

member of an audit committee, as that term is defined in Section 3(a)(58) of the Exchange Act, 

Respondent shall submit a written statement attesting to an undertaking to have Respondent’s

work reviewed by the independent audit committee of any public company for which Respondent

works or in some other manner acceptable to the Commission, as long as Respondent practices 

before the Commission in this capacity and will comply with any Commission or other 

requirements related to the appearance and practice before the Commission as an accountant.

D. In support of any application for reinstatement to appear and practice before the

Commission as a member of an audit committee, as that term is defined in Section 3(a)(58) of the 

Exchange Act, as a preparer or reviewer, or as a person responsible for the preparation or review, 

of any public company’s financial statements that are filed with the Commission, Respondent 

shall submit a statement prepared by the audit committee(s) with which Respondent will be 

associated, including the following information:

1. A summary of the responsibilities and duties of the specific audit committee(s) 

with which Respondent will be associated;

2. A description of Respondent’s role on the specific audit committee(s) with 

which Respondent will be associated;

3. A description of any policies, procedures, or controls designed to mitigate any 

potential risk to the Commission by such service; 

4. A description relating to the necessity of Respondent’s service on the specific 

audit committee; and

5. A statement noting whether Respondent will be able to act unilaterally on 

behalf of the Audit Committee as a whole. 
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E. In support of any application for reinstatement to appear and practice before the 

Commission as an independent accountant (auditor) before the Commission, Respondent must be 

associated with a public accounting firm registered with the Public Company Accounting 

Oversight Board (the “PCAOB”) and Respondent shall submit the following additional 

information: 

1. A statement from the public accounting firm (the “Firm”) with which 

Respondent is associated, stating that the firm is registered with the PCAOB in 

accordance with the Sarbanes-Oxley Act of 2002; 

2. A statement from the Firm with which the Respondent is associated that the 

Firm has been inspected by the PCAOB and that the PCAOB did not identify 

any criticisms of or potential defects in the Firm’s quality control system that 

would indicate that Respondent will not receive appropriate supervision; and

3. A statement from Respondent indicating that the PCAOB has taken no 

disciplinary actions against Respondent since seven (7) years prior to the date 

of the Order other than for the conduct that was the basis for the Order. 

F. If Respondent is licensed as a certified public accountant (“CPA”), then in support 

of any application for reinstatement, Respondent shall provide documentation showing that 

Respondent’s license is current and that Respondent has resolved all other disciplinary issues with 

any applicable state boards of accountancy. If Respondent’s CPA licensure is dependent upon 

reinstatement by the Commission, then Respondent shall provide documents reflecting this 

requirement. If Respondent has never been licensed as a CPA, then Respondent shall submit a 

signed affidavit truthfully stating under penalty of perjury that Respondent has never been licensed 

as a CPA.

G. In support of any application for reinstatement, Respondent shall also submit a 

signed affidavit truthfully stating, under penalty of perjury: 

1. That Respondent has complied with the Commission suspension Order, 

and with any related orders and undertakings, including any orders in 

Securities and Exchange Commission v. Evoqua Water Technologies 

Corp. et al., or any related Commission proceedings, including any orders 

requiring payment of disgorgement or penalties;

2. That Respondent undertakes to notify the Commission immediately in 

writing if any information submitted in support of the application for 

reinstatement becomes materially false or misleading or otherwise changes 

in any material way while the application is pending; 

3. That Respondent, since the entry of the Order, has not been convicted of a 

felony or a misdemeanor involving moral turpitude that would constitute a 

basis for a forthwith suspension from appearing or practicing before the 

Commission pursuant to Rule 102(e)(2); 
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4. That Respondent, since the entry of the Order:

a. has not been charged with a felony or a misdemeanor involving moral 

turpitude as set forth in Rule 102(e)(2) of the Commission’s Rules of 

Practice, except for any charge concerning the conduct that was the 

basis for the Order;

b. has not been found by the Commission or a court of the United States 

to have committed a violation of the federal securities laws, and has 

not been enjoined from violating the federal securities laws, except for 

any finding or injunction concerning the conduct that was the basis for 

the Order; 

c. has not been charged by the Commission or the United States with a 

violation of the federal securities laws, except for any charge 

concerning the conduct that was the basis for the Order;

d. has not been found by a court of the United States (or any agency of 

the United States) or any state, territory, district, commonwealth, or 

possession, or any bar thereof to have committed an offense (civil or 

criminal) involving moral turpitude, except for any finding concerning 

the conduct that was the basis for the Order; and

e. has not been charged by the United States (or any agency of the United 

States) or any state, territory, district, commonwealth, or possession, 

civilly or criminally, with having committed an act of moral turpitude, 

except for any charge concerning the conduct that was the basis for the 

Order.

5. That Respondent’s conduct is not at issue in any pending investigation of

the Commission’s Division of Enforcement, the PCAOB’s Division of 

Enforcement and Investigations, any criminal law enforcement 

investigation, or any pending proceeding of a State Board of Accountancy, 

except to the extent that such conduct concerns that which was the basis 

for the Order.

6. That Respondent has complied with any and all orders, undertakings, or 

other remedial, disciplinary, or punitive sanctions resulting from any 

action taken by any State Board of Accountancy, or other regulatory body.

H. Respondent shall also provide a detailed description of:

1. Respondent’s professional history since the imposition of the Order, including

a. all job titles, responsibilities and role at any employer;
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b. the identification and description of any work performed for entities 

regulated by the Commission, and the persons to whom Respondent 

reported for such work; and

2. Respondent’s plans for any future appearance or practice before the 

Commission.

I. The Commission may conduct its own investigation to determine if the foregoing 

attestations are accurate.

J. If Respondent provides the documentation and attestations required in this Order

and the Commission (1) discovers no contrary information therein, and (2) determines that 

Respondent truthfully and accurately attested to each of the items required in Respondent’s

affidavit, and the Commission discovers no information, including under Paragraph I, indicating 

that Respondent has violated a federal securities law, rule or regulation or rule of professional 

conduct applicable to Respondent since entry of the Order (other than by conduct underlying 

Respondent’s original Rule 102(e) suspension), then, unless the Commission determines that 

reinstatement would not be in the public interest, the Commission shall reinstate the respondent 

for cause shown.

K. If Respondent is not able to provide the documentation and truthful and accurate 

attestations required in this Order or if the Commission has discovered contrary information, 

including under Paragraph I, the burden shall be on the Respondent to provide an explanation as 

to the facts and circumstances pertaining to the matter setting forth why Respondent believes 

cause for reinstatement nonetheless exists and reinstatement would not be contrary to the public 

interest. The Commission may then, in its discretion, reinstate the Respondent for cause shown. 

L. If the Commission declines to reinstate Respondent pursuant to Paragraphs J and 

K, it may, at Respondent’s request, hold a hearing to determine whether cause has been shown to 

permit Respondent to resume appearing and practicing before the Commission as an accountant.

By the Commission.

Vanessa A. Countryman

Secretary