UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933

Release No. 11154 / February 8, 2023

SECURITIES EXCHANGE ACT OF 1934

Release No. 96843 / February8, 2023

ADMINISTRATIVE PROCEEDING

File No. 3-21297

In the Matter of

OLGA KUPRINA

Respondent.

ORDER INSTITUTING CEASE-ANDDESIST PROCEEDINGS PURSUANT TO 

SECTION 8A OF THE SECURITIES ACT 

OF 1933 AND SECTION 21C OF THE 

SECURITIES EXCHANGE ACT OF 1934, 

MAKING FINDINGS, AND IMPOSING A 

CEASE-AND-DESIST ORDER

I.

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

public interest that cease-and-desist proceedings be, and hereby are, instituted pursuant to Section 

8A of the Securities Act of 1933 (“Securities Act”) and Section 21C of the Securities Exchange 

Act of 1934 (“Exchange Act”), against Olga Kuprina (“Respondent”). 

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, Respondent admits the Commission’s 

jurisdiction over her and the subject matter of these proceedings, and consents to the entry of this

Order Instituting Cease-and-Desist Proceedings, Pursuant to 8A of the Securities Act of 1933 and 

Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing A Ceaseand-Desist Order (“Order”), as set forth below.

III.

On the basis of this Order and Respondent’s Offer, the Commission finds1that:

 

1 The findings herein are made pursuant to Respondent's Offer of Settlement and are not 

binding on any other person or entity in this or any other proceeding. 
2

Respondent

1. Respondent, age 38, is a Ukrainian citizen presently residing in the United States. 

Other Relevant Persons and Entities

2. Oleksandr Ieremenko (a.k.a. Eremenko, Alex Boesky, Lamarez, Sergey Komarov, 

Anton Petrov, and Uladzimir Aleiniau) (“Ieremenko”), age 28, is a computer hacker who, on 

information and belief, resides in Kiev, Ukraine. He was previously charged by the Commission 

with alleged securities fraud in SEC v. Dubovoy, et al., District of New Jersey Case No. 15-cv06076 and SEC v. Ieremenko, et al., District of New Jersey Case No. 19-cv-00505. 

Facts

3. These proceedings arise out of the alleged scheme to hack into the Commission’s 

Electronic Data Gathering, Analysis, and Retrieval (“EDGAR”) system described by the 

Commission in its complaint against Ieremenko and others in SEC v. Ieremenko, et al. This Order 

concerns the hacking activity that was allaged in paragraph 119 of the Commission’s Complaint 

(ECF 1) in SEC v. Ieremenko et al:

Efforts to compromise EDGAR continued into early 2017. For example, at 

approximately the same time that Ieremenko lost access to EDGAR test filings in 

October 2016, he returned to his previous efforts to compromise SEC computer 

workstations through malware, which he had delivered through phishing emails, 

spoofed to appear to have been sent by SEC security personnel. Other efforts also 

continued, including by other people, though none of the post-October 2016 efforts 

appear to have led to access to test filings containing material nonpublic information 

or to trading.

4. Specifically, from approximately October 2016 to approximately March 2017, while 

operating in Ukraine, Respondent worked with associates of Ieremenko to hack the EDGAR system 

and exfiltrate material, nonpublic information. Respondent utilized numerous hacking techniques in 

attempting to retrieve nonpublic information from EDGAR, which included introducing malicious, 

executable code. 

5. Through these efforts, Respondent was able to retrieve at least two nonpublic test 

filings from EDGAR. However, no trading appears to have occurred as a result of the exfiltration of 

these filings.

Violations

6. As a result of the conduct described above, Respondent violated Regulation S-T 

Rule 106 [17 CFR § 232.106]. Regulation S-T, promulgated under both the Securities Act and the 

 
3

Exchange Act, governs the electronic submission of documents to the Commission. Regulation S-T 

Rule 106(a) prohibits sending an electronic submission to EDGAR that contains “executable code.”

An “electronic submission” includes “any document, such as a filing, correspondence, or modular 

submission, or any discrete set of documents, transmitted or delivered to the Commission in 

electronic format.” 17 C.F.R. § 232.11. 

7. Regulation S-T defines “executable code” to mean “instructions to a computer to 

carry out operations that use features beyond the viewer’s, reader’s, or Internet browser’s native 

ability to interpret and display HTML, PDF, and static graphic files. Such code may be in binary 

(machine language) or in script form. Executable code includes disruptive code.” Regulation S-T 

further defines disruptive code to include “any active content or other executable code, or any 

program or set of electronic computer instructions inserted into a computer, operating system, or 

program that replicates itself or that actually or potentially modifies or in any way alters, damages, 

destroys or disrupts the file content or the operation of any computer, computer file, computer 

database, computer system, computer network or software, and as otherwise set forth in the 

EDGAR Filer Manual.”

8. Respondent introduced both executable and disruptive code designed to disrupt the 

normal functioning of EDGAR, namely the exfiltration of at least two nonpublic test filings. 

IV.

In view of the foregoing, the Commission deems it appropriate to impose the sanctions 

agreed to in Respondent Kuprina’s Offer.

Accordingly, pursuant to Section 8A of the Securities Act and Section 21C of the Exchange 

Act, it is hereby ORDERED that:

A. Respondent Kuprina cease and desist from committing or causing any violations and 

any future violations of Regulation S-T Rule 106.

B. In light of Respondent’s entry of a guilty plea in a parallel criminal action based, in 

part, on the conduct described above, the Commission is not imposing a civil penalty against 

Respondent. 

By the Commission.

Vanessa A. Countryman

Secretary