UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO.: 

SECURITIES AND EXCHANGE COMMISSION, ) 

 ) 

 Plaintiff, ) 

 ) 

v. ) 

 ) 

PAVEL RUIZ, ) 

 ) 

 Defendant. ) 

_____________________________________________________ ) 

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF AND 

DEMAND FOR JURY TRIAL 

Plaintiff Securities and Exchange Commission (the “Commission”) alleges: 

I. INTRODUCTION 

1. From at least June 2020 until August 2021, Defendant Pavel Ruiz (“Ruiz”) 

personally, and through his team of sales agents, raised at least $46 million from over 5,100 

investors on behalf of MJ Capital Funding, LLC (“MJ Capital”) and its affiliate MJ Taxes and 

More, Inc. (“MJ Taxes”) (collectively, the “MJ Companies”). 

2. The MJ Companies and their owner, chief executive offer, and president, Johanna 

M. Garcia (“Garcia”), operated the MJ Companies as a Ponzi scheme, which, from at least June 

2020 until August 2021, raised over $196 million from more than 15,400 investors nationwide 

through an unregistered fraudulent securities offering. Garcia and the MJ Companies tricked 

investors into thinking their investment would be used to fund small business loans called 

Merchant Cash Advances (“MCAs”) in exchange for a percentage of the business’ income over a 

specified period of time. In reality, investors’ outsize annualized “returns” of 120% – 180% were 

funded with money obtained from new investors. 

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3. The Ponzi scheme collapsed once the Commission filed its emergency action to 

stop this ongoing fraud on August 9, 2021, against Garcia and the MJ Companies (collectively, 

the “MJ Defendants”). SEC v. MJ Capital Funding, LLC, et al., No.: 21-61644-CIV-AHS (S.D. 

Fla.). On August 11, 2021, the Court granted the Commission’s motions for an asset freeze and 

injunctive relief against the MJ Defendants and the appointment of a receiver over the MJ 

Companies. 

4. Ruiz played a significant role in perpetrating the Ponzi scheme. At all relevant 

times, he was involved in high-level decision-making for MJ Capital, served as an MJ Capital 

“board member” responsible for “Treasury/Accounting”, and had access to MJ Capital’s bank 

accounts. 

5. Ruiz told investors that their money would be used to fund the MJ Companies’ 

purported MCA business and, in exchange, they would receive returns of 10% to 15% per month 

along with the return of their principal investment upon maturity. 

6. But only a small fraction of investor funds was used to make MCAs. Instead, most 

of the investor funds were used to pay fictitious returns to existing investors, undisclosed 

commissions to sales agents who promoted investments in the MJ Companies, and personal 

expenses for insiders of the MJ Companies, including Ruiz. As such, investors’ ability to receive 

the promised returns and repayment of principal was dependent on a rising stream of funds from 

new investors, and by convincing existing investors to renew their existing investments, thus 

deferring the MJ Companies’ need to repay investors their principal investment. 

7. Furthermore, at all relevant times, Pavel held no securities licenses, was not 

registered with the Commission, and was not associated with a registered broker-dealer. The MJ 

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Companies’ securities were not registered with the Commission, nor did they qualify for an 

exemption from registration. Ruiz thus was not permitted to sell the MJ Companies’ securities. 

8. By engaging in this conduct, Ruiz violated Sections 5(a), 5(c), and 17(a) of the 

Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§ 77e(a), 77e(c), and 77q(a); Section 10(b) 

of the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78j(b), and Exchange Act 

Rule 10b-5, 17 C.F.R. § 240.10b-5; and Section 15(a)(1) of the Exchange Act, 15 U.S.C. § 

78o(a)(1). 

II. DEFENDANT 

9. Ruiz is a resident of Ft. Lauderdale, Florida. Ruiz was a lead sales agent and “board 

member” of MJ Capital. He also is the owner and managing member of Pavel Ruiz MJCF LLC 

(“Ruiz LLC”) and UDM Remodeling LLC (“UDM”). On October 14, 2021, upon motion of the 

Receiver, the Court expanded the receivership to include Ruiz LLC and UDM. 

III. OTHER RELEVANT ENTITIES AND INDIVIDUAL 

10. MJ Capital is a Florida limited liability company located in Pompano Beach, Florida. 

Garcia formed MJ Capital in June 2020 and is its Manager, an Authorized Member, and President. 

MJ Capital purports to be in the business of providing merchant cash advances to businesses 

located in Florida and throughout the United States. MJ Capital claimed to fund millions of dollars 

in merchant capital loans to small business owners in exchange for a percentage of the business’ 

income over a specified period of time, with the amount of such funding having steadily increased 

every month since its inception in 2020. The total amount to be repaid is supposedly calculated by 

a factor rate, a multiplier generally based on a business’ financial status. The Court appointed the 

Receiver over MJ Capital on August 11, 2021, and entered a Judgment for Permanent Injunctive 

Relief against MJ Capital on October 1, 2021. 

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11. MJ Taxes is a Florida corporation located in the same office as MJ Capital in 

Pompano Beach. Garcia incorporated MJ Taxes in December 2016 as MJ Tax Services & More 

Inc. and is its President. In March 2020, Garcia changed the company’s name to MJ Taxes and 

More Inc. The Court appointed the Receiver over MJ Taxes on August 11, 2021, and entered a 

Judgment for Permanent Injunctive Relief against MJ Taxes on October 1, 2021. 

12. Garcia is a resident of North Lauderdale, Florida. Garcia controlled the MJ Companies 

prior to their going into receivership. On September 8, 2021, the Court, by consent, entered a 

preliminary injunction against Garcia. 

IV. JURISDICTION AND VENUE 

13. The Court has jurisdiction over this action pursuant to Sections 20(b) and 22(a) of 

the Securities Act, 15 U.S.C. §§ 77t(b) and 77v(a); and Sections 21(d), 21(e), and 27 of the 

Exchange Act, 15 U.S.C. §§ 78u(d), 78u(e), and 78aa. 

14. This Court has personal jurisdiction over Ruiz, and venue is proper in the Southern 

District of Florida, because many of Ruiz’s acts and transactions constituting violations of the 

Securities Act and the Exchange Act occurred in the Southern District of Florida, where Ruiz 

resides and conducts business. 

15. In connection with the conduct alleged in this Complaint, Ruiz, directly and 

indirectly, made use of the means or instrumentalities of interstate commerce, the means or 

instruments of transportation and communication in interstate commerce, and the mails. 

V. FACTS 

A. The MJ Defendants’ Securities and Solicitation of Investor Funds 

16. Since at least June 2020, MJ Taxes began soliciting investments, agreeing to pay 

annual returns of varying amounts, typically 120%, for six-month investments. Between June 2020 

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and September 2020, MJ Taxes and investors entered into written agreements, signed by Garcia 

on behalf of MJ Taxes, called a Loan Agreement. These agreements refer to the investor as 

“Investor” or “Lender” and MJ Taxes as the “Facilitator” or “Borrower.” 

17. Beginning at least as early as October 2020, MJ Capital became the primary 

investment vehicle for raising funds from investors. From October 2020 until the Ponzi scheme 

collapsed in August 2021, MJ Capital entered into written agreements with investors called a 

Merchant Cash Advance Agreement. These agreements refer to the investor as the “Purchaser,” 

and MJ Capital agrees that it will use the investor’s money to fund an MCA. MJ Capital promises 

an annual return of varying amounts, typically 120%, with MJ Capital guaranteeing repayment of 

principal if the merchant defaults. The term of the investment is either six months, 9 months, 12 

months or six months with an option by the investor to extend the term for an additional six months. 

18. In addition to the written agreement, MJ Capital required investors to sign: a NonDisclosure Agreement, where the investor would agree not to disclose confidential information 

about MJ Capital; a Purchaser Non-Compete Agreement, where the investor would agree not to 

engage in any business that would compete with MJ Capital for two years; an IRS W-9 form; and 

a Referral Program Agreement, which allowed an investor to receive a one-time referral bonus of 

an unspecified amount for each referred person who invests with MJ Capital. 

19. The MJ Companies solicited investors through its own employees, external sales 

agents, and word-of-mouth. 

20. MJ Capital employed a multi-tiered sales team to solicit investors and a complex 

payment system to pay these agents. The sales team hierarchy was as follows: Board Member, 

Manager, Team Leader, and Account Representative. Multiple undisclosed commission payments, 

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which came out of the offering proceeds, were paid to each agent in this hierarchy based on each 

investment. 

21. MJ Capital also solicited investors through its website and social media. MJ 

Capital’s then website, www.mjcapitalfunds.com (the “Website”), whose domain name was 

registered on July 29, 2020, represented that MJ Capital was in the business of funding MCAs and 

that investor money would be used for this purpose. The Website provided background 

information on how MJ Capital can assist small businesses with merchant cash advances and 

further invited business owners to fill out an online application for funding. For example, the 

Website stated that MJ Capital could provide “an alternative option to satisfy a business’s financial 

needs”, and that it had a “pipeline of investors” from whom the business could expect “cash of up 

to $200,000 to fulfill [its] needs . . . .” 

22. At least as early as May 12, 2021, the Website’s “blog” section stated: “[MJ 

Capital] has grown to an extent where there is a team of underwriters who qualify every company 

that seeks funds from MJ Capital. There are no exceptions to this! The process consists of checking 

6 months’ worth of bank statements, last year’s tax returns, and [the merchant’s] profit and loss 

sheet for the last year.” 

23. Additionally, at least as early as May 12, 2021, MJ Capital represented through 

social media that it is in the business of funding MCAs and offers “quick approvals,” “fast 

funding,” “flexible terms” and “help[s] small businesses”. Its then Twitter page touted: “MJ 

Capital specializes in MCA funding for businesses, our goal is to help you and your business thrive 

during uncertain times by working with our team.” 

24. In or around June 2021, an undercover Federal Bureau of Investigation agent 

(“UC”) posing as a prospective investor spoke with MJ Capital’s officer manager at MJ Capital’s 

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office in Pompano Beach. The office manager explained, among other things, that MJ Capital 

would use the UC’s funds to purchase future sales or profits of companies and the UC would make 

a 10% monthly return, an underwriting team determines a merchant’s ability to repay, and MJ 

Capital has liens on a merchant’s projects as further security. 

25. The Loan Agreements and Merchant Cash Advance Agreements (the 

“Agreements”) are investment contracts. Investors looked solely to the MJ Companies to produce 

returns, and the MJ Companies’ ability to do so depended entirely on their ability to either fund 

profitable MCAs or attract new investors to cover payments to existing investors. The Agreements 

are also notes. As investment contracts and/or notes, the Agreements are securities within the 

meaning of the Securities Act and the Exchange Act. These securities have not been registered 

with the Commission. 

B. The MJ Defendants’ Material Misrepresentations to Investors and Misuse and 

Misappropriation of Investor Funds___________________________________ 

26. The representations that the MJ Companies were using investor money to fund 

MCAs and that their money was secure were lies. In fact, the MJ Companies made very few MCAs, 

they did not file liens in connection with the few MCAs they did make, and investors’ ability to 

receive the promised returns and repayment of principal was dependent on the MJ Defendants’ 

ability to continue to raise new investor money and convince existing investors to extend the term 

of their agreements. 

27. From June 1, 2020 through August 31, 2021, the MJ Companies received at least 

$196 million in investor funds from investors in Florida and several other states. However, the MJ 

Companies only made approximately $895,000 in MCAs. During that same time period, the MJ 

Companies received approximately $393,000 in repayment for those MCAs. 

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28. From June 1, 2020 through August 31, 2021, the MJ Companies misused investor 

funds by making payments totaling at least $61.8 million to sales agents for promoting investments 

in the MJ Companies. The MJ Companies also misused investor funds by making payments on 

loans owed by MJ Taxes via transfers to MJ Taxes’ bank account. 

29. From June 1, 2020 through August 31, 2021, Garcia and the MJ Companies also 

misappropriated at least $7.4 million of investor funds on a variety of purchases unrelated to the 

business, including credit card payments, travel, entertainment, restaurants, and luxury goods and 

clothing. 

30. Because the MJ Companies made few MCAs and were diverting substantial 

investor money, the MJ Companies were not earning anywhere near the revenue needed to pay the 

promised returns to investors. 

31. From June 1, 2020 through August 31, 2021, the MJ Companies paid at least $109 

million in purported returns to investors. However, instead of paying investors out of the revenue 

of the business, the MJ Companies used new investor money to pay returns to existing investors. 

32. The investments in the MJ Companies were not secure. To the contrary, the only 

way the MJ Companies could honor their obligations to investors would be by successful 

continuation of their fraudulent scheme. Once the supply of new investors was exhausted, the MJ 

Companies would be unable to pay the promised returns to existing investors. 

C. Ruiz’s Material Misrepresentations to Investors, Misuse and 

Misappropriation of Investor Funds, and Offer and Sale of Securities in 

Unregistered Transactions___________________________________________ 

33. Ruiz played a significant role in the MJ Companies’ Ponzi scheme. 

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34. From at least June 2020 until August 2021, Ruiz personally, and through his team 

of about 70 sales agents, solicited and raised at least $46 million from over 5,100 investors on 

behalf of the MJ Companies. 

35. Ruiz and his agents utilized MJ Capital’s social media, such as Twitter and 

Instagram, and Zoom meetings to solicit investors. Ruiz trained and instructed his sales team on 

what to tell investors, including the sales pitch that they gave to potential investors. Ruiz and his 

team represented to investors and prospective investors that their funds would be used to make 

MCAs, and that they would receive returns of 10% to 15% per month and the return of their 

principal upon maturity. 

36. Ruiz sometimes instructed his team to give investors Cash App, Zelle, and Venmo 

payment instructions, which were linked either to Ruiz’s personal bank accounts or to the bank 

accounts of his two entities, Ruiz LLC and UDM. Other times, Ruiz and his team instructed 

investors to send money directly to MJ Capital. In other instances, investors made their investment 

in cash. 

37. After investing through Ruiz and his team, investors would receive a signed MCA 

Agreement from the MJ Companies, which was signed by either Ruiz or someone on his team as 

authorized representatives of the MJ Companies. 

38. During the relevant time period, Ruiz received at least $292,000, and his team 

received at least $5.3 million, in commission payments directly from MJ Capital. 

39. In addition to the $292,000 in commission payments he received, Ruiz 

misappropriated millions of dollars from investors. Of the $46 million Ruiz and his team raised 

from the MJ Companies’ investors, Ruiz deposited approximately $7.7 million directly into his 

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personal accounts or that of his two entities, Ruiz LLC and UDM. Ruiz only transferred about 

$1.2 million of these investor funds to MJ Capital. 

40. Ruiz misappropriated or misused the rest of this money, approximately $6.5 

million. Among other things, Ruiz spent the money on personal expenses such as to purchase 

crypto assets and a luxury vehicle, payments to his sales team and staff even though they were 

already receiving commission payments directly from MJ Capital’s bank accounts, and to make 

Ponzi-like payments to some investors even though the majority of investors brought in by his 

team received their purported interest payments directly from MJ Capital. 

41. Ruiz’s representations that the MJ Companies would use investor money to fund 

MCAs was false. Investor funds were rarely used to fund MCAs. Instead, Ruiz and the MJ 

Defendants misused and misappropriated investor funds. 

42. Ruiz had online access to MJ Capital’s bank accounts. He also controlled his 

personal and business bank accounts, including Ruiz LLC and UDM. 

43. Ruiz had ultimate authority for the false and misleading statements he and his 

sales team made to investors and prospective investors, and in the documents, such as the 

Agreements, he and sales team provided to investors and prospective investors. 

VI. CLAIMS FOR RELIEF 

COUNT 1 

Violations of Sections 5(a) and (c) of the Securities Act 

44. The Commission adopts by reference paragraphs 1 through 43 of this Complaint 

45. No registration statement was filed or in effect with the Commission pursuant to 

the Securities Act with respect to the securities and transactions issued by the MJ Companies 

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described in this Complaint and no exemption from registration existed with respect to these 

securities and transactions. 

46. From at least as early as June 2020 through August 2021, Defendant directly and 

indirectly: 

(a) made use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to sell securities, through the use or medium 

of a prospectus or otherwise; 

(b) carried or caused to be carried securities through the mails or in interstate 

commerce, by any means or instruments of transportation, for the purpose of sale 

or delivery after sale; or 

(c) made use of any means or instruments of transportation or communication 

in interstate commerce or of the mails to offer to sell or offer to buy through the use 

or medium of any prospectus or otherwise any security, 

without a registration statement having been filed or being in effect with the Commission as to 

such securities. 

47. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Sections 5(a) and 5(c) of the Securities Act, 15 

U.S.C. §§ 77e(a) and 77e(c). 

COUNT 2 

Violations of Section 17(a)(1) of the Securities Act 

48. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

49. From at least as early as June 2020 through August 2021, Defendant, in the offer 

or sale of securities by use of any means or instruments of transportation or communication in 

interstate commerce or by use of the mails, directly or indirectly, knowingly or recklessly 

employed devices, schemes, or artifices to defraud. 

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50. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 17(a)(1) of the Securities Act, 15 

U.S.C. § 77q(a)(1). 

COUNT 3 

Violations of Section 17(a)(2) of the Securities Act

51. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

52. From at least as early as June 2020 through August 2021, Defendant, in the offer 

or sale of securities by use of any means or instruments of transportation or communication in 

interstate commerce or by use of the mails, directly or indirectly, negligently obtained money or 

property by means of untrue statements of material facts and omissions to state material facts 

necessary in order to make the statements made, in the light of the circumstances under which they 

were made, not misleading. 

53. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 17(a)(2) of the Securities Act, 15 

U.S.C. § 77q(a)(2). 

COUNT 4 

Violations of Section 17(a)(3) of the Securities Act 

54. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

55. From at least as early as June 2020 through August 2021, Defendant, in the offer 

or sale of securities by use of any means or instruments of transportation or communication in 

interstate commerce or by use of the mails, directly or indirectly, negligently engaged in 

transactions, practices, or courses of business which operated or would have operated as a fraud 

or deceit upon the purchasers. 

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56. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 17(a)(3) of the Securities Act, 15 

U.S.C. § 77q(a)(3). 

COUNT 5 

Violations of Section 10(b) and Rule 10b-5(a) of the Exchange Act 

57. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

58. From at least as early as June 2020 through August 2021, Defendant, directly or 

indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly employed devices, schemes or artifices to defraud in connection with the 

purchase or sale of securities. 

59. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act, 15 U.S.C. 

§ 78j(b), and Exchange Act Rule 10b-5(a), 17 C.F.R. § 240.10b-5(a). 

COUNT 6 

Violations of Section 10(b) and Rule 10b-5(b) of the Exchange Act

60. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

61. From at least as early as June 2020 through August 2021, Defendant, directly or 

indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly made untrue statements of material facts or omitted to state material facts 

necessary in order to make the statements made, in the light of the circumstances under which they 

were made, not misleading. 

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62. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act, 15 U.S.C. 

§ 78j(b), and Exchange Act Rule 10b-5(b), 17 C.F.R. § 240.10b-5(b). 

COUNT 7 

Violations of Section 10(b) and Rule 10b-5(c) of the Exchange Act 

63. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

64. From at least as early as June 2020 through August 2021, Defendant, directly or 

indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, 

knowingly or recklessly engaged in acts, practices, and courses of business which have operated, 

are now operating and will operate as a fraud upon the purchasers of such securities. 

65. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 10(b) of the Exchange Act, 15 U.S.C. 

§ 78j(b), and Exchange Act Rule 10b-5(c), 17 C.F.R. § 240.10b-5(c). 

COUNT 8 

Violations of Section 15(a)(1) of the Exchange Act 

66. The Commission adopts by reference paragraphs 1 through 43 of this Complaint. 

67. From at least as early as June 2020 through August 2021, Defendant, directly or 

indirectly, by the use of the mails or any means or instrumentality of interstate commerce effected 

transactions in, or induced or attempted to induce the purchase or sale of securities, while he was 

not registered with the Commission as a broker or dealer or not associated with an entity registered 

with the Commission as a broker-dealer. 

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68. By reason of the foregoing, Defendant, directly or indirectly, violated and, unless 

enjoined, is reasonably likely to continue to violate Section 15(a)(1) of the Exchange Act [15 

U.S.C. § 78o(a)(1)]. 

VII. RELIEF REQUESTED 

 WHEREFORE, the Commission respectfully requests that the Court find that Defendant 

committed the violations of the federal securities laws alleged herein and: 

A. Permanent Injunctive Relief 

 Issue a Permanent Injunction enjoining Defendant from violating Sections 5(a), 5(c), and 

17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and 

Section 15(a)(1) of the Exchange Act. 

B. Disgorgement 

 Issue an Order directing Defendant to disgorge all ill-gotten gains, including prejudgment 

interest, resulting from the acts or courses of conduct alleged in this Complaint.

C. Civil Penalty 

Issue an Order directing Defendant to pay civil money penalties pursuant to Section 20(d) 

of the Securities Act, 15 U.S.C. § 77t(d), and Section 21(d) of the Exchange Act, 15 U.S.C. § 

78(d). 

 

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DEMAND FOR JURY TRIAL 

The Commission hereby demands a trial by jury on any and all issues in this action so 

triable. 

August 29, 2022 Respectfully submitted, 

 By: /s/ Stephanie N. Moot 

Stephanie N. Moot 

Senior Trial Counsel 

Fla. Bar No. 30377 

Direct Dial: (305) 982-6313 

 Email: moots@sec.gov

 

Raynette R. Nicoleau 

 Fla. Bar No. 278210 

 Senior Counsel 

 Direct Dial: (305) 982-6308 

 Fax: (305) 536-4154 

Attorneys for Plaintiff 

 SECURITIES AND EXCHANGE 

 COMMISSION 

 801 Brickell Avenue, Suite 1950 

 Miami, Florida 33131 

 Telephone: (305) 982-6300 

 Facsimile: (305) 536-4146 

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