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Enforcement News: What Happens When Form ADV Statements Cannot Be Substantiated
In today’s article, we examine the SEC’s enforcement action against Wisdom Capital Management Group Ltd., an entity that claimed to be an Exempt Reporting Adviser (“ERA”) under the Investment Advisers Act of 1940 (“Advisers Act”). While ERAs are exempt from SEC registration, they remain subject to the SEC’s examination authority and must provide accurate, verifiable disclosures.

Jeffrey Haber
Aug 105 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: 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


SEC Whistleblower Receives More Than $4 Million For Reporting Fraud
By Jeffrey M. Haber On September 20, 2016, the Securities and Exchange Commission (“SEC”) announced that it awarded more than $4 million to a whistleblower who provided original information about a fraud that resulted in the recovery of monetary sanctions. Since 2011, the SEC has awarded more than $111 million to 34 whistleblowers pursuant to the agency’s whistleblower program. The SEC did not identify the whistleblower. By law, the SEC protects the confidentiality of whistl

Jeffrey Haber
Sep 21, 20161 min read


FINRA Issues Regulatory Notice Affirming Arbitration Rights
By Jeffrey M. Haber What is a FINRA arbitration? The Financial Industry Regulatory Authority ("FINRA") issued a Regulatory Notice in July 2016 reminding member firms that customers have a right to request arbitration "at any time." In addition, the self-regulator stated that customers do not forfeit their right to a FINRA arbitration by signing an agreement that calls for another venue. The notice also reiterated that FINRA members cannot require registered representatives an

Jeffrey Haber
Aug 30, 20162 min read


The SEC Makes Good on Its Promise to Crack Down on Agreements and Policies That Impede Whistleblowers From Reporting Securities Fraud
By: Jeffrey Haber In 2010, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act” or the “Act”) to combat illegal and fraudulent conduct on Wall Street and promote compliance with the federal securities. The Dodd-Frank Act contains whistleblower provisions that authorize the Securities and Exchange Commission (“SEC” or the “Commission”) to pay substantial cash rewards to whistleblowers that voluntarily provide the SEC with informa

Jeffrey Haber
Aug 24, 20167 min read


SEC Checking Under Tesla's Hood
Did Tesla violate securities laws by not disclosing a fatal accident? In May, the driver of a Tesla Model S was killed after colliding with a truck while the Autopilot feature, which is designed to assist drivers in steering, braking and avoiding collisions, was engaged. Since October 2014, Tesla Motor Co. has installed autopilot software in all of its cars, even though the feature is still being tested in a public beta. Now, the Securities and Exchange Commission ("SEC") is

Jeffrey Haber
Aug 10, 20162 min read


SEC Proposes Rule Requiring Investment Advisers to Adopt Business Continuity Plans
What are the elements of a sound business succession plan for investment advisory firms facing disruption?

Jeffrey Haber
Jul 22, 20162 min read


Wall Street Pushing Back Against Labor Department's Fiduciary Rule
Wall Street trade groups are suing to block the DOL's new fiduciary rule for retirement advisors, arguing the agency overstepped its authority.

Jeffrey Haber
Jul 18, 20162 min read
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