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Defense of Enforcement Actions


Enforcement News: SEC Cracks Down on Misuse of Investor Funds in Investment Pools
On June 5, 2026, the SEC charged an investment adviser and related entities with a multi-year fraud involving a pooled investment fund that raised about $4 million from 28 investors. The SEC alleged the defendant misappropriated and commingled funds, concealed losses exceeding $3.6 million, and diverted assets for personal use.

Jeffrey Haber
Jun 158 min read


Enforcement News: Financial Elder Abuse, Vulnerability, and the SEC’s Enforcement Response
Financial abuse of seniors and other vulnerable adults is among the most damaging and the least visible forms of investor harm. It arises when age, illness, cognitive decline, or dependence on trusted professionals erodes an individual’s ability to evaluate advice or resist coercion, even while legal capacity nominally remains intact.

Jeffrey Haber
Apr 63 min read


Enforcement News: Former Chief Operating Officer and Former Managing Partner Charged with Participating in An Alleged $300 Million Ponzi Scheme
By: Jeffrey M. Haber This Blog has written about Ponzi schemes on numerous occasions. A Ponzi scheme is a type of investment fraud where returns to earlier investors are paid using investment capital from new or existing investors, rather than from legitimate profits earned through the enterprise’s business activities. Ponzi schemes persist by exploiting trust, promising high returns with little risk, and using money from new or existing investors to pay “profits” to earlier

Jeffrey Haber
Jan 74 min read


Enforcement News: SEC Charges Founders and Their Two Companies with Fraud in $237 Million Preferred Equity Offering
By: Jeffrey M. Haber On November 18, 2025, the Securities and Exchange Commission (“SEC” or “Commission”) announced that, on October 16, 2025, it charged Joshua Wander (“Defendant A”), Steven Pasko (“Defendant B”), and two companies that they founded, co-managed, and controlled—777 Partners LLC and 600 Partners LLC—with defrauding investors while raising approximately $237 million. The Commission also charged Damien Alfalla (“Defendant C”), the companies’ former Chief Financi

Jeffrey Haber
Nov 26, 20254 min read


Enforcement News: SEC Charges Wisconsin Resident and The LLCs That He Owns and Controls with Perpetrating a Real Estate Affinity Fraud
On August 1, 2025, the Securities and Exchange Commission (“SEC”) announced (here) that it charged a Wisconsin resident and three limited liability companies that he owns and controls – Investors Capital LLC, Global Investors Capital LLC, and High Income Performance Partners LLC (collectively, the “Entity Defendants”) – with perpetrating a real estate-related offering fraud.

Jeffrey Haber
Aug 11, 20255 min read


Enforcement News: The Custody Rule
The Custody Rule provides that “it is a fraudulent, deceptive, or manipulative act, practice or course of business within the meaning of section 206(4) of the [Advisers] Act … for [a registered investment adviser] to have custody of client funds or securities unless” the adviser implements an enumerated set of requirements to prevent loss, misuse, or misappropriation of those funds and securities.

Jeffrey Haber
Aug 6, 20255 min read


Enforcement News: Former California Financial Advisor Charged With Allegedly Operating Decades-Long Million Ponzi Scheme
This Blog has written about Ponzi schemes on numerous occasions. A Ponzi scheme is a type of investment fraud where returns to earlier investors are paid using investment capital from new or existing investors, rather than from legitimate profits earned through the enterprise’s business activities.

Jeffrey Haber
Jul 30, 20253 min read


Enforcement News: SEC Files Charges Against Georgia-Based Lender For Operating $140 Million Ponzi Scheme
A Ponzi scheme is an investment scam that induces people to invest money in a business or investment vehicle with promises of high returns and minimal risk. Rather than earning profits through actual investments or legitimate business operations, the scheme functions by paying early investors with money contributed by new or repeat participants.

Jeffrey Haber
Jul 14, 20256 min read


Enforcement News: N.H. Real Estate Developer and Coach Charged with Multimillion Dollar Real Estate Investment Fraud
On June 26, 2025, the Securities and Exchange Commission (SEC”) announced (here) that it charged a Manchester, New Hampshire resident, a real estate investment coach and real estate investment coach, with defrauding investors through real estate investment schemes resulting in losses of at least $3 million.

Jeffrey Haber
Jul 2, 20252 min read


Enforcement News: Ponzi-Like Scheme, Elder Financial Exploitation and Affinity Fraud
Today, we examine an enforcement action brought by the SEC involving a Ponzi-like scheme that targeted retired senior citizens that the defendant met through his church community

Jeffrey Haber
May 28, 20255 min read


Enforcement News: Founder of Crypto Asset and Foreign Exchange Trading Company Charged with Orchestrating a Ponzi-Like Fraudulent Scheme and For Misappropriating More Than $57 Million of Investor F...
The allure of guaranteed profits from sophisticated crypto asset and foreign exchange trading served as the underlying predicate for the claims asserted by the Securities and Exchange Commission (“SEC”) against Ramil Palafox (“Defendant”), the founder of Praetorian Group International Corporation (“PGI Global”), a now-defunct entity he controlled, in S.E.C. v. Palafox, Case 1:25-cv-00681 (E.D. Va. 2025). The case marks the first crypto enforcement action under the new Chairma

Jeffrey Haber
May 14, 20254 min read


Enforcement News: SEC Commences Enforcement Action Against Promoters of a Ponzi Scheme Involving Unregistered Securities
A Ponzi scheme is intended to give investors the false impression that their investment is profitable. In a Ponzi scheme, the fraudster/promoter pays early investors with money that the investor believes is the return on his/her/its investment. In actuality, the money used to pay the investor comes from the investor’s own principal investment dollars or the pooled investment dollars of subsequent investors.

Jeffrey Haber
May 12, 20255 min read
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