SEC Rule 206(1)

The defendants allegedly defrauded investors and client funds in connection with investments in pre-IPO shares while charging millions in undisclosed fees.

The SEC has recently closed three very different but equally brazen fraud cases, each a window into a distinct form of financial misconduct.

Momentum Advisors LLC, along with its former COO and CCO, were charged with violations related to the misuse of portfolio company assets.

Final judgments in this action were against individuals and entities charged with perpetrating a massive $8 billion Ponzi scheme.

The SEC also accused the pair of lying to investors about Rimar’s assets under management.

With SEC and DOJ charges pending, we examine the case and assess the implications of the CCO's characterization as a gatekeeper.