The Securities and Exchange Commission has charged 38 entities, alleging they made material misrepresentations in Forms ADV filed with the Commission between 2025 and 2026 to falsely portray themselves as legitimate advisory firms to U.S. investors.
According to the complaints, a number of the defendants used IP addresses tracked to foreign jurisdictions to connect to the Commission's filing system, and failed to respond to requests from Commission counsel to substantiate information provided in their Forms ADV.
"Our complaints allege large-scale abuse of SEC adviser filings by persons, several of whom are likely located overseas, exploiting interest in emerging technologies," said Laura D'Allaird, Chief of the SEC Enforcement Division's Cyber and Emerging Technologies Unit. "When we find bad actors using fraudulent SEC filings to feign legitimacy with retail investors, we will act decisively to disrupt these operations."
Alleged misrepresentations
- Listing places of business at addresses in Colorado where the defendants had no presence
- Providing phone numbers that are disconnected or belong to unrelated businesses
- Disclosing ownership structures and numerical data identical or nearly identical to those of a multitude of other purported exempt reporting advisers (ERA)
- Claiming private fund financial statements were audited by one of two independent public accounting firms, neither of which appears in any public registry of federal or state accountancy firms
- Marketing on websites that in some cases displayed a fake certificate indicating SEC registration that did not exist
