EFTA00083492.pdf
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Extracted Text (OCR)
From: Chris Dilorio
To:
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR &
Appendix
Date: Mon, 30 Nov 2020 14:13:32 +0000
Attachments: KCG_Appendix_3-20_13_penultimate.docx; KCG_TCR_3-20-13-penultimate_draft.pdf;
KCG_TCR_3-20-13-penultimate_draft.docx; KCG_Appendix_3-20_13_penultimate.pdf;
Cifu.jpg; Blosteinjpg; KCGMarch2017.jpg
FBI DC agents,
Please let me know if I'm going to fast for you. Full Disclosure: FBI agents recently searched me up on Linked In.
Do phones at the FBI dial out? Pick 1 up and call me. I'll talk slowly.
More derivatives 1.0 for these FBI agents:
The Fraud eco system template. To continue on our Net Element (also AQR) example
"Payment processing": transaction laundering. Like WireCard: AlliedWallet: NY Office: Rovt.
FCC???? IT'S MONEY LAUNDERING STUPID!!
EFTA00083492
Still MORE record Janey:
Bravatek: also Fife and NITE trading billions of shares: MY F'N INFORMATION!!!!
LG Capital Funding:prolific Bag Men
EDGAR Search Results (sec.gov)
EDGAR Filing Documents for 0001078782-16-003519 (sec.gov)
EDGAR Filing Documents for 0001078782-16-003519
Bravatek Solutions, Inc. (Subject) CIK: 0001449574 (see all company filings) IRS No.: 320201472 I State of
Incorp.:CO I Fiscal Year End: 0331 Type: SC 13G I Ad: 34 ...
vo.vw sec cloy
LG: Boruch Greenberg, Joe Lerman, Dan Gellman
same guys. Same f'n address:
1218 Union St Brooklyn
as 2 "payment processors":
Benchmark Merchant
Benchmark Merchant Solutions — Beyond the Point of Sale
Benchmark Merchant Solutions — Beyond the Point of Sale
Experts predict that we will soon be a completely cashless society. In fact, a recent Reuters survey showed
that 20% of customers already rely solely on credit cards and other forms of online payment for their
purchases.
benchmarkmerchantsolutions.com
and
Payrix
Payrix Holdings, LLC - Who is raising money? i SEC filings of fundraisings and investments in hedge funds,
startups and private equity companies
Payrix Holdings, LLC - Who is raising money? I SEC filings of fundraisings
and investments in hedge funds, startups and private equity companies
Payrix Holdings, LLC Funding details. Payrix Holdings, LLC raised $19,250,000 from 8 investors on 2018-12-
18.
www.whoisraisingmoney.com
Payments Infrastructure i Payrix Payments Technology I United States
EFTA00083493
Payments Infrastructure I Payrix Payments Technology I United States
Payrix Payments Technology works with SaaS companies and marketplaces to provide complete payment
servicing management and monetization, allowing your platform to generate revenue quickly and create a
seamlessly embedded user experience.
www.piyrix.com
BOTH Benchmark and Payrix are Deutsche Bank ISO partners.
Remember Deutsche Bank? WireCard? Ring any bells?
Same DB that passed on buying the fraud WireCard but had no problem hiring their CTO
Deutsche Bank snags Wirecard exec Kilian Thalhammer - FinTech Futures
Deutsche Bank snags Wirecard exec Kilian Thalhammer
- FinTech Futures
Deutsche Bank has appointed Kilian Thalhammer, a former Wirecard exec, to
oversee its Merchant Solutions pillar. He will be joining the bank in October.
www.fintechfutures.com
In November 2020, the criminal bank DB is EXPANDING into Russia. Yes, I said that correctly: Deutsche Bank:
mirror trader serial money launderer is EXPANDING in Russia.
Outside Monitors Urge Deutsche Bank to Quit Russia - WSJ
Outside Monitors Urge Deutsche Bank to Quit
Russia - WSJ
Deutsche Bank AG executives want to expand in Russia despite a
legacy of missteps and massive fines. Outside monitors who
watch over the bank's money-laundering controls said it should
shut the ...
vo.,,w.wsj.com
Will DB buy Net Element/Pay Online as part of their EU/Russia expansion in "payment processing"???
Why would DB Buy Net Element as part of its expansion into Russia and the EU WHEN according to SEC filings
90%+ of NETE BILLIONS in transactions processed are in the United States????
Again: sorry if I typed too fast for the FBI DC agents. Pick up a phone that dials out and give me a call instead of
searching for me on Linked In. Happy to walk you through it.
EFTA00083494
BTW grossly corrupt SEC/SONY: How's that WireCard investigation coming along? WireCard trades OTCM Pinks.
That's New York isn't it?
Finally: the grossly corrupt SEC wants to exempt 90% of the 13F filers today. HOW does that benefit the
investing public the SEC is mandated to protect?
SEC.gov i SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers• Amend
Reporting Threshold to Reflect Today's Equities Markets
SEC.gov I SEC Proposes Amendments to Update Form 13F for Institutional
Investment Managers; Amend Reporting Threshold to Reflect Today's
Equities Markets
The Securities and Exchange Commission today announced that it has proposed to amend Form 13F to
update the reporting threshold for institutional investment managers and make other targeted changes.
www. sec .g ov
The SEC is a grossly corrupt, criminal enterprise ACTIVELY facilitating criminal activity while screwing
whistleblowers like me and people like Dan Kamensky and Neil Cole and countless others not on the SEC/SDNY
"Do not investigate list"
Cheers!
Christopher.' Dilorio
Whistleblower Extraordinaire
From: Chris Dilorio
Sent: Wednesday, November 25, 2020 6:29 AM
EFTA00083495
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
FBI DC agents: do they teach derivatives at the FBI?
Otkritie majority holder of SEC fully reporting/NASDAQ traded QIWI
20-F (sec.gov)
HOW QIWI ever went public in the US is a story unto itself. "HQ" in Cyprus with ZERO US presence.
Otkritie: largest QIWI holder
Report: Otkritie ups stake in payment services provider QIWI i S&P Global Market Intelligence
Report: Otkritie ups stake in payment services
provider QIWI
Otkritie Holding increased its stake in the capital of Cyprus-based
QIWI to 15.66% after its unit Otkritie Financial Corp. Bank
acquired 12.2% of the company in three private transactions,
Kommersant reported.
www.spglobal.com
Net Element: QIWI/Pay Online
PayOnline Introduces a New Payment Interface (netelement.com)
PayOnline Introduces a New Payment Interface
www.netelement.com
As I have repeatedly asked the grossly corrupt SEC: NETE has "IT" in both Miami and Moscow. Miami
address(es) are office buildings. WHERE are NETE US servers hosted????
EFTA00083496
In SEC reviewed filings: North American "payment processing" accounts for 90% of NETE transactions
processed. Yet, no disclosures as to WHERE these servers are hosted.
Are NETE servers hosted/located in Russia? Seems like a material disclosure. IF of course the SEC was actually
interested in that shit.
Happy Thanksgiving!
Christopher.' Dilorio
Whistleblower Extraordinaire
From: Chris Dilorio
Sent: Tuesday, November 24, 2020 6:47 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Janey,
EVERY day the RECORD becomes clearer and clearer: My information is overwhelmingly and irrefutably
ACCURATE. The GROSSLY corrupt SEC has been protecting the criminal enterprise Knight/KCG/VIRT: NITE for
quite some time. A longstanding and corrupt relationship.
Greifeld: NASDAQ: Friedman: Sungard: Brut:Otkritie:Knight real time rubles to dollars
No sh!t, really?
1 1/2 years prior to the SEC/BX/JEF/Handler/Stifel/JPM/GS/Sandler et al "glitch"
Russia's Otkritie lures team from Knight Capital I Reuters
Otkritie wins $150m fraud judgment I Financial Times (ft.com)
EFTA00083497
Otkritie wins $150m fraud judgment I
Financial Times
One of Russia's largest independent financial groups has won
$150m in damages after a UK High Court judge found it was the
victim of a "cunning and well-orchestrated fraud" committed by ...
yoArw.ft.corn
My TCR: March 2013: 4 months prior to the post "glitch" Knight/Getco:KCG.
July 2017: VIRT/KCG
ONLY explanation: a GROSSLY corrupt SEC facilitating a massive, ongoing fraud on the public while screwing
whistleblowers like me.
But it gets better. More "RECORD" Laney:
Blink Charging: BLNK
The Jaclin $$ laundering shell kept up and running by the GROSSLY corrupt SEC: Michael Farkas: ilncubator and
Skyway: money laundering shells. Farkas conspicuously absent from SEC complaints. Controlled both.
Governor Richardson. Drexel Alum. Jonathan New: NETE CFO also BLNK. Prolific Bag Man JMJ/Keener: my TCR.
In 2017, BLNK claimed to have 23,000 charging stations installed
IKEA to Install 3 Electric Vehicle Charging Stations at Future Columbus Store Opening Summer 2017 : Blink
Charging
IKEA to Install 3 Electric Vehicle Charging Stations at
Future Columbus Store Opening Summer 2017 : Blink
Charging
Click here to read our must recent news, IKEA to Install 3 Electric Vehicle
Charging Stations at Future Columbus Store Opening Summer 2017. Blink
Charging provides high-quality and easy to use EV Charging Stations and
Networks for homes and businesses.
www.blinkcharging.com
In several SEC reviewed filings as of today: 15.7 million installed charging stations. The case of the missing EV
charging stations.
Gets better:
"Investing" in BLNK along side Keener: Horton Capital Partners: Philly.
EDGAR Filing Documents for 0001193125-18-050585 (sec.gov)
EFTA00083498
EDGAR Filing Documents for 0001193125-18-050585
Horton Capital Partners, LLC (Filed by) CIK: 0001575443 (see all company filings) IRS No.: 461613207 I State
of Incorp.:DE I Fiscal Year End: 1231 Type: SC 13G/ASC 13G/A
Joey Manko Jr
Swiss Private Bank. Deutsche Bank. Horton. Blink
Team I The Horton Fund
Team I The Horton Fund
Joe Manko, Jr. has over 20 years of investment experience,
predominately in the asset management, investment banking,
private equity and corporate securities markets.From 2005-2010
Mr. Manko was a Partner and Chief Executive Officer of
Switzerland-based BZ Fund Management Limited, where he was
thehortonfund.com
Joey Manko is BUISSSSYYYYY
Joseph M. Manko - Mufson Howe Hunter (mhhco.com)
Joseph M. Manko - Mufson Howe Hunter
Joe Manko is a Managing Director at Mufson Howe Hunter and has over 20 years of transaction experience
as an investment banker, principal investor and corporate finance lawyer
mhhco.com
Thanks to the grossly corrupt SEC, a MASSIVE pump and dump in BLNK the last 2 weeks as the money
laundering shell is up 200% on massive volume. The SEC CONTINUALLY places the investing public it is
MANDATED to protect at risk while facilitating criminal activity. The record is clear Janey: NITE: Russian/Swiss
Banks: money laundering/tax evasion. Keener: Bag Man. BLNK: money laundering shell. ALL in my TCR. ALL
kept up and running by the GROSSLY CORRUPT SEC et al.
Cheers!
Christopher J Dilorio
Whistleblower Extraordinaire
EFTA00083499
From: Chris Dilorio
Sent: Thursday, November 19, 2020 7:29 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Janey,
You are a pathological and very bad liar.
More "record":
Stephen Guyer's other money laundering shell:
Telecom Wireless/TComm
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001098923&owner=exclude&count=40&hidefilings=0
Revoked by the grossly corrupt SEC 10 years after its last financial disclosure filing.
Dozens of fraud transactions. MILLIONS of worthless certs dumped on the public and facilitated by those damn
"penny stock trading fairies".
Guyer moved seamlessly onto his next massive fraud: Colorado Goldfields thanks to the SEC.
Colorado Goldfields: massive NITE/UBSS/Sason et al money laundering fraud thanks to MORE SEC facilitation.
My claims: OpCo: Norberg/SEC admits to Congress that the OWB is the primary contact between
whistleblowers and the Commission. Then Norberg invokes yet to be enacted summary disposition language in
her fraud Denial of my Award application: "SEC investigators never saw my information": after FIVE years. Gross
negligence? NOPE: Blatant LIES.
I suspect my information is some of the most widely disseminated within the SEC leading to dozens of actions.
Call me Janey. I'll walk you through it.
EFTA00083500
Then today: November 19, 2020 NASDAQ/Friedman announce the $2.8 BILLION acquisition of Verafin. A
financial crimes/money laundering detection/prevention firm. Wait, I didn't think NASDAQ had a money
laundering problem?!?! That's $2.8 BILLION. Must be a MASSIVE problem in fact. I've read that somewhere
before: see the record including below Janey. NETE and other AQR blank check shells: NASDAQ. Sungard DMA:
real time rubles to dollars: NASDAQ:. BRUT: NASDAQ. The record clearly shows my extensive correspondence to
NASDAQ as well.
https://verafin.com/verafin-story]
Crickets out of OTCM and #1 OTCM money laundering shell trader: Greifeld Chairman: N Island top shareholder:
Hutchins: David Urban: created by the mob:Sull Crom client: NITE/VIRT.
Cheers!
Christopher J Dilorio
Whistleblower Extraordinaire
From: Chris Dilorio
Sent: Friday, November 13, 2020 9:10 AM
>
EFTA00083501
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Janey,
Because I take great pride in my overwhelmingly and irrefutably accurate information exposing the grossly
corrupt, criminal SEC et al: please see the below typo correction:
"when creditors can/do negotiate with creditors"
changed to
"when creditors can/do negotiate with ISSUERS"
Cheers!
Christopher Dilorio
Whistleblower Extraordinaire
From: Chris Dilorio e
>
Sent: Friday. November 13 2020 8:13 AM
EFTA00083502
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Greetings grossly corrupt SEC et al. Time for the "SEC criminal Obstruction/corruption" Friday edition.
The record Janey. Well, the SEC hasn't limited its massive fraud on JUST the SONY courts. Good to know. The DC
Courts are also victim of this massive fraud as well.
The OpCo Complaint/Denial: My claims. Here AGAIN the SEC has done nothing to shut down a massive fraud on
the public. Per my TCR: NITE/UBSS (aka "penny stock trading fairies) traded billions of shares and were also
cited by me in extensive correspondence with FINRA and the OWB PRIOR to my March 2013 Berger TCR
submission.
AppTech is very much up and running in November 2020 thanks to the grossly corrupt SEC and is again/still
being used as a money laundering vehicle.
https://www.sec.gov/cgi-bin/browse-edgar?
company=Apptech&match=&CIK=&filenum=&State=&Country=&SIC=&owner=exclude&Find=Find+Companies
&action=getcompany
In October 2020, AppTech announced this YUGE deal with NEC Payments. WOW NEC and AppTech!?!?
https://www.globenewswire.com/news-release/2020/10/05/2103341/0/en/AppTech-Announces-Digital-
Banking-and-Payment-Technology-Partnership-with-NEC-Payments.html
AppTech Announces Digital Banking and
Payment Technology Partnership with NEC
Payments OTC Markets:APCX
GlobeNewswire is one of the world's largest newswire distribution
networks, specializing in the delivery of corporate press releases
financial disclosures and multimedia content to the media ...
www.globenewswire.com
Wrong NEC Payments bruh.
This NEC Payments (NECP) is an entity domiciled in the Kingdom of Bahrain
HUH?
ALL in SEC reviewed filings of course
https://www.sec.gov/Archives/edgar/data/1070050/0001575705200002 I 4/apcx 8k.htm
https://www.sec.gov/Archives/edgar/data/1070050/000157570520000214/ex10 2.htm
EFTA00083503
And, HOW do you suppose a Bahraini entity searched out and found little of Wyoming money laundering shell
AppTech?
The New Bag man involved is Bahraini business man Ebrahim Daoud Nonoo
https://en.wikipedia.org/wiki/Ebrahim Daoud Nonoo
Ebrahim Daoud Nonoo - Wikipedia
Ebrahim Daoud Nonoo (Arabic "is.; ).9.9 6 4
) 4 , Hebrew: ornax
1313 'Tr , also known as Abraham David Nonoo) is a Bahraini
businessman. He sat in the appointed upper house of the
Bahraini Parliaments Shura Council, the only Jewish member of
the Council. He is the current CEO of the Basma Company.. The
en.wikipedia.org
But alas, none of this illegal activity should have happened. See, the SEC OWB: McKessy/Norberg were in
possession of my information when a fraud on the courts was being perpetrated by AppTech/Ottens (see my
TCR)
https://www.leagle.com/decision/infdco20141103a26
FARRIS v. D'ANGELO I Case No. C14-560 MJP.
I 20141103a26 I Leagle.com
ORDER GRANTING DEFENDANTS MOTION TO DISMISS MARSHA
J. PECHMAN District Judge. THIS MATTER comes before the Court
on Defendant...20141103a26
www.leagle.com
In fact, AppTech should have been shut down immediately based on my information. However: NITE/UBSS
(penny stock trading fairies) were in the process of trading their billions of worthless certs WHILE this case was
pending. Questions for Judge Pechman: Did the SEC ever intervene in this case?
per my extensive 2013 TCR: Assignments: No legitimate economic rationale for a creditor to assign a
note/obligation to a third party when creditors can/do negotiate directly with ISSUERS. Derivatives: further
assignments to other third parties are simply a distribution mechanism. As the SEC has discovered using my
information (Sason,JMJ, Crede, etc etc): not a legitimate note/obligation to begin with. FREE MONEY. Converted
into worthless certs. Converted into real money by criminal Broker Dealers/MM's like NITE,UBSS etc.
Who is Ms Farris anyway? Ottens girlfriend? Because assigning $25,000 worth of fraud notes for $10,000
happens all the time in the real world of legitimate financial transactions. Yes, as with ALL of my information:
OVERWHELMINGLY and IRREFUTABLY accurate. AppTech is a money laundering shell. ACTIVELY facilitated and
EFTA00083504
never shut down by a grossly corrupt and criminal SEC while screwing whistleblowers like me. This massive, SEC
et al facilitated fraud is very much ONGOING.
Cheers!
Christopher Dilorio
Whistleblower Extraordinaire
PS: I'm sure everyone on this email is acutely aware of the BLATANT and EGREGIOUS SEC facilitated trading
activity in ANOTHER "payment processor": AQR/Oleg Firer WireCard etc now Bankrupt Coda/China Qiantu EV
massive SEC/Clayton/Sull Crom fraud known as Net Element :NETE
Massive volume. No PUBLISHED PR's. No SEC filings. Just up 20% in 2 days.
What do you expect from an SEC Chair who compares compliance with US Securities Laws as "good hygiene"?
From: Chris Dilorio
Sent: Tuesday, November 3, 2020 9:01 PM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Mr Kim,
Any representation that doesn't require the SEC to produce exculpatory evidence related to my allegations is
malpractice.
https://casetext.com/case/united-states-v-martoma-3
https://casetext.com/case/united-states-v-gupta
United States v. Gupta, 848 F Supp. 2d 491 I Casetext Search + Citator
Read United States v. Gupta, 848 F. Supp. 2d 491, see flags on bad law, and search Casetext's
comprehensive legal database
casetext.com
Cheers!
Christopher Dilorio
Whistleblower
EFTA00083505
From: Chris Dilorio
Sent: Tuesday, November 3, 2020 3:34 PM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Greetings Judge Caproni,
I hope your colleagues as well as Mr Kim's colleagues have forwarded my information to you. The criminal case
against Mr Kamensky brought by Ms Strauss, Mr Tracer and Mr Cooper is a fraud on your courts. I have
established beyond any shadow of a doubt that the Kamensky/SEC/SDNY actions are a complete fraud and well
orchestrated set up by protected and known criminals including but not limited to Richard Handler/Jefferies.
This corrupt, criminal relationship between the SEC and Handler/Jefferies goes WAY back and at the heart of my
claims: a MASSIVE and ongoing fraud on the public actively facilitated by the SEC/Handler/Jefferies et al (see
attached TCR). Unfortunately, Ms Strauss as well as Mr Kim's former boss at the SDNY Preet Bharara have also
been in possession of my information for quite some time. Mr Kamensky must re assess his representation..
I am always available to discuss my information. Under oath preferably. This massive, ongoing, SEC/Handler et
al fraud on the public must end. It has been my personal mission to see exactly that.
This massive fraud also affects other cases currently before the SDNY Courts and ALSO well known to Ms
Strauss/the SDNY
Regards,
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Wednesday, October 14, 2020 9:32 AM
>
Su •ject: Fw: Forma appea or pre iminary • enia covere• action 2015-016 Knig t Capita TCR : Appen• ix
From: Chris Dilorio <
Sent: Wednesday, October 14, 2020 9:00 AM
EFTA00083506
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
The corrupt, criminal relationship with Handler/Jefferies as I have stated is NOT the only corrupt,criminal
relationship the SEC/SDNY have with members of their respective "do not investigate lists". AQR, Blackstone as
well as Jay Clayton good fried Glenn Hutchins. Hutchins also worked at Blackstone with Schwarzman prior to
founding Silver Lake. Hutchins bought SunGard. Then sold it to FIS. This transaction was the basis of the
formation of North Island with former NASDAQ CEO Greifeld. North Island is a top shareholder of the criminal
enterprise NITE/VIRT. More context: Greifeld was a Director UK/NJ company called Automated Securities
Clearance Ltd
https://find-and-update.company-information.service.gov.uk/company/03385409/officers
AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Officers (free
information from Companies House)
AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Free company information from Companies
House including registered office address, filing history, accounts, annual return, officers, charges, business
activity
find-and-update.company-information.service.gov.uk
Sold to SunGard. Greifeld then became CEO at SunGard. He wasn't at SunGard very long. Then made the jump
to CEO of NASDAQ. Curious to say the least. Shortly after becoming NASDAQ CEO, NASDAQ bought the BRUT
ECN from SunGard. Self dealing? MUCH WORSE
http://innasdaq.comistatic-filest6b1ca278-75f0-4259-9372-5b3351126a8b
ir.nasdaq.com
121 e< 2 h"' 21 e< 16$ 8; l< 76 =23 $ 54 -:;2((1 -&22
irnasciaq.corn
EFTA00083507
As you can see, current NASDAQ CEO Adena Friedman signed off on this transaction.
SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to
dollars in real time.
https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion
Otkritie Capital taps SunGard for automated
Ruble conversion
Otkritie Capital (Otkritie), one of the leading financial services
providers in Russia, has selected SunGard to help launch a new
direct market access (DMA) service allowing for automatic real ...
www.finextra.com
I'll say that again: FROM Russian rubles TO dollars in real time. Providing DMA to WHICH markets????
So, the marriage of Blackstone Alum Hutchins and Greifeld to form N Island and become a top investor in the
criminal enterprise NITE was a natural fit. Money laundering on a MASSIVE scale. Algos and OTCM shells are
very complimentary money laundering vehicles. Not to mention: Russian Mirror trades: RU ADR's trade OTCM
Pinks as well. The KCG 1Q2014 astronomical increase in OTCM volumes. Expunged from SEC reviewed
filings. Attached on previous emails as part of the OWB record. NASDAQ is also the repository of the vast AQR
blank check money laundering shells. FULLY SEC reporting for credibility. As with many OTCM shells. The
only real difference between a NASDAQ/AQR blank check shell and an OTCM shell is the amount of money
being laundered. Clayton should have been investigated and barred from SEC business pending a full and
thorough investigation. So, that precludes the corrupt SEC IG Hoecker from any involvement.
Cheers!
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursday, September 17, 2020 5:56 PM
To:
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Judge Nathan,
I applaud your reproof of the SONY.
Now, I urge you to look at the Dan Kamensky case. I have never met Kamensky. When I saw the joint SEC/SDNY
complaint I became physically ill. I am an SEC whistleblower. The SEC/SDNY have actively and continuously
obstructed a thorough investigation of my extremely serious allegations. In favor of Rich Handler/Jefferies. The
IB in the Kamensky case. Based on my experience with the SEC/SDNY I believe they both are withholding
exculpatory evidence which impeaches the credibility of the SEC/SDNY/Handler/Jefferies. A corrupt relationship
EFTA00083508
exists between the SEC/SDNY and Handler/Jefferies. In addition to others in my claims. I have contacted Judge
Cave as well as Kamensky counsel. Disclosure of this corrupt relationship puts the Neiman Marcus "sting" in a
whole different context. The motives of which should be investigated.
Respectfully,
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Thursda Se.tember 17 2020 9:17 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Please see the new photos attached:
Mr Blostein's Eureka moment and Cifu admission that the NITE/VIRT revenue model is driven by the "retail
participation" rate:
Cifu: "The retail segment of what we do is a SIGNIFICANT portion of our overall American equity segment..."
So, are institutions trading .0001 OTCM money laundering shells? Mr Blostein: what are you modeling for
NITE/VIRT OTCM share volumes when you KNOW and Cifu admits the importance of these share volumes on
the NITE/VIRT revenue model? Does ANY Sell side analyst model this NITE/VIRT revenue driver? WHY doesn't
Cifu disclose these share volumes in SEC filings? He used to. Knight/KCG used to as well. See photo. So why did
he stop? Did NITE exit OTCM trading? ABSOLUTELY NOT. So the Goldman Analist Blostein KNOWS these share
volumes drive revenue at NITE. Blostein doesn't disclose these volumes in his model. Fraud is also an OMISSION
of material fact. Time to ask Cifu WHY he doesn't tell you to model OTCM share volumes fellas. This is WHY the
SEC/Handler/Jefferies/VIRT/KCG acquisition took place. As Cifu admits: Retail:OTCM drives NITE/VIRT earnings.
Cheers!
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Wednesda , Se.tember 16, 20203:01 PM
EFTA00083509
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
First Sell Sider, SEC,DoJ who can get me a current NITE/VIRT tangible book value calculation wins a prize: Mr
Kamensky's freedom. That's BEFORE properly classification of Naked short fails NITE/VIRT KNOWINGLY books as
fraud assets: receivable.
Mr Blostein, I remember a NITE/VIRT earnings call not to long ago where you made a direct correlation
between NITE OTCM share volumes and NITE trading profits. Remember the 1? I have hard copies of that too.
Did Cifu threaten you if you bring it up again? Please forward your model including these share volumes so we
can compare notes. Who else has been threatened with retaliation by Cifu/Handler? Who has been promised
business? Mr Repetto/Fannon? Who has BUY ratings on NITE/VIRT currently?
Cheers!
Christopher J Dilorio
Whistleblower
From: Chris Dilorio ‹
>
Sent: Wednesday, September 16, 2020 9:20 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Judge Cave,
The criminal, corrupt relationship between the SEC/Handler/NITE goes further.
Doesn't it Mr Repetto?
For the Sell Siders on this e mail:
Please tell Judge Cave, The SEC/Dol, Mr Kamensky's counsel the following:
1) how many red flags in NITE 3 CFO's in a year?
2) What you're modeling for NITE OTCM share volumes
3) WHY none of you question the once again ballooning balance sheet on earnings calls
The other questions below can be answered by Mr Repetto and Jefferies Mr Fannon
Cheers!
Christopher J Dilorio
Whistleblower
EFTA00083510
From: Chris Dilorio <
Sent: Monday, September 14, 2020 9:22 AM
To:
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
I look forward to speaking with you
Regards,
Chris
From: Chris Dilorio
Sent: Monday, September 14, 2020 6:02 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Judge Jones, Judge Cave
Straight forward, irrefutable proof of SEC corrupt relationship with Handler Jefferies:
KCG was engaged in abusive naked shorting in months leading up to the SEC/Handler/Jefferies VIRT acquisition
closing 7/31/2017
SEC/Handler/Jefferies KNEW the core business at KCG is and always has been abusive naked shorting OTCM and
other shells to facilitate money laundering.
SEC/Handler/Jefferies knew KCG was insolvent in 2012 as well as 2017 as a direct result of this illegal activity
Handler/Jefferies were the largest shareholder of KCG in 2017 when the SEC/Handler/Jefferies/Cifu
orchestrated VIRT/KCG merger was consumated
https://www.clearygottlieb.com/news-and-insights/news-listing/14-billion-merger-of-kcg-holdings-and-virtu-
financial
$14 Billion Merger of KCG Holdings and Virtu Financial I Cleary Gottlieb
Cleary Gottlieb is representing Goldman, Sachs & Co., as financial advisor to KCG Holdings in its sale to
Virtu Financial in an all-cash transaction valued at $1.4 billion.
www.clearygottlieb.com
SEC/Handler/Jefferies/Cifu used known fraud "assets" on the KCG balance sheet to determine the grossly
inflated tangible book value calculation used to value the KCG acquisition price.
Immediately prior to the transaction closing on 7/31/2017 the SEC/Cifu wrote down more than $4 billion in
leverage from the KCG balance sheet. INCLUDING fraud assets used to calculate the grossly inflated acquisition
price of KCG.
SEC/Handler/Jefferies KNEW KCG was insolvent in 2012 AND July 2017
EFTA00083511
The SEC has known about the Knight/KCG/VIRT accounting fraud and securities fraud for years. I TOLD THEM.
The SEC has engaged in a massive criminal obstruction scheme that is ongoing to protect NITE/VIRT.
As a direct result of this corrupt, criminal scheme the investing public is put at risk, NITE/VIRT is insolvent
again/always, Handler/Jefferies benefit, my rights as a whistleblower have been egregiously abused,
Kamensky's life is ruined.
The SEC/SDNY is making a mockery of your respective courts. Worse: the SEC and SDNY are committing a
massive and well known FRAUD on your respective courts.
The true character of Handler/ Jefferies as well as the corrupt relationship the SEC has with Handler/Jefferies
must be disclosed to Mr Kamensky. Any verdict without these disclosures is a known miscarriage of justice.
https://www.lexology.com/library/detaiLaspx?g=9e2b4e49-See2-48f6-b8c7-03d39d02b5ca
SEC ordered to produce Brady and Giglio
materials due to joint investigation with U.S.
Attorney's office - Lexology
A district court ordered the SEC to produce material solely in its
possession to a defendant in a parallel criminal prosecution by
the U.S. Attorney...
www.lexology.com
Mr Kamensky WILL have my information. Mr Kamensky WILL have justice. The SEC/Handler/Jefferies/Cifu
corrupt criminal relationship and ongoing frauds on the public will be exposed and ENDED.
Regards,
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Saturday, September 12, 2020 8:23 AM
<
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Judges Cave and Jones,
The SEC corruption goes well beyond just Handler/Jefferies/NITE.
My research: I developed a template. I would search NITE top traded OTCM shells. From there: Derivatives. I
have filed several separate but related TCR's based on that information.
The SEC has brought several actions related to my 2013 Knight TCR with Berger: Hanover/Magna, JMJ,Keener,
Hicks, Fife,UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA
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brought a complaint against Brown Brothers Harriman AFTER the SEC was in possession of my information for
almost a year. That complaint IS also my information. New SEC NY Richard Best brought that FINRA complaint.
ALL of the entities are un named. WHY? Per the complaint: BBH delivered 80%+ of the trades to executing
BD's/MM's. NITE as the #1 trader in the space would most certainly have executed BBH trades converting
worthless certs to real money. The BBH complaint also cites un named Swiss Banks and FFI's. As a result of
exposing these frauds the SEC/FINRA no longer allow searches of OTCM share volume by Market Maker.
Further, Cifu,Handler,the SEC have allowed the post VIRT/KCG: NITE to no longer disclose these share volumes
in any SEC filings NOR SEC reviewed investor presentations. Has NITE exited this business? ABSOLUTELY not. It is
and always has been the DRIVER of NITE trading profits. Virtually riskless albeit illegal. The investing public is
intentionally misled as to the true, core business of NITE.
The August 1 2012 "glitch" proved my allegations that Knight was insolvent. Knight had to raise virtually the
entire "glitch" loss despite claiming to have a "highly liquid balance sheet". The accounting fraud is a result of
the illegal naked shorting. The SEC,Handler,Jefferies et al "glitch" and bailout wasn't JUST a cover up of a
massive SEC failure to protect the investing public however. The 2012 "glitch" was the first of many cover ups so
that this massive fraud on the public can continue. Per previous correspondence and the extensive record with
the SEC: As with the "glitch" ALL participants KNEW exactly the NITE core business and accounting fraud at NITE
in 2017 had not changed. As the record clearly shows: NITE was engaged in abusive naked shorting OTCM (and
other) money laundering shells immediately prior to the VIRT/KCG merger closing. Many of the same players in
the 2017 "glitch" as the 2012 "glitch". JPM,GS,JEF/Handler, and Jay Clayton Sull Crom colleague Jared Fishman.
How did the VIRT/KCG merger get approved in the face of the overwhelming evidence I provided? The same
way the 2013 Knight/Getco reverse merger got approved: SEC criminal obstruction.
In 2017 the SEC,Cifu,Handler wrote down 4 billion+ Naked short fails immediately prior to the VIRT/KCG deal
closing. These fraud "assets" were sitting on the KCG balance sheet and used to calculate the grossly inflated
tangible book value used in the KCG acquisition price. KCG was grossly insolvent. ALL participants and the SEC
knew this. The primary beneficiary of this fraud: Handler/Jefferies.
In 1Q2020 I alerted the SEC that absolutely nothing had changed. NITE reported a receivable of 2.5 BILLION+.
This was up 90% sequentially. HUGE red flags. No investigation. In 2Q2020 the receivable had fallen by just $100
mil from 1Q. Meaning: The 1Q receivable would have zeroed out within days of March 31 2020 as is required:
settlement Then, the receivable at June 30 was within 100 mil of the March 31 balance. Inconceivable. The
March 31 receivable was NEVER zeroed out as is required by law. Further, the fails listed as "assets" are a fraud.
More accurately: liability. AND there is nothing in the receivable that can be converted into cash for company
use. There are prior commitments: settlement. Combine this with the THIRD CFO in a year and you have the
makings of ANOTHER "glitch"
As I've told the SEC: HFT holdings:seconds. No receivable there. DMM? KCG sold theirs in 2016. So that leaves
the VIRT DMM. Even AFTER the massive 2Q2017 Cifu/Handler/SEC write down, the receivable is up more than
6X from the last VIRT stand alone 2Q2017. AGAIN the effects of the core NITE illegal activity.
So, what has changed since August 1 2012? Absolutely nothing. This is an ongoing, massive fraud perpetrated
on the American people. Well orchestrated by the SEC,Handler/Jefferies,Sull Crom et al.
Did Clayton recuse himself from my Award denial? Did Clayton recuse himself from the VIRT/KCG approval? Did
Clayton EVER disclose his Sull Crom NITE conflicts?
The answer can be found in the very carefully structured complaints against several entities in my 2013 and
derivative TCR's: NONE of the activity in these SEC/FINRA complaints takes place without a willing, executing
BD/MM converting worthless certs into real money. Then trader in the space: NITE. Yet, you won't find NITE in
ANY of these complaints. As far as the SEC is concerned: :"penny stock trading fairies". The corrupt, criminal
SEC/Handler/Jefferies relationship explained.
I offer AGAIN to fly to SEC DC HQ or NY Office on my own dime to have the best and brightest at the SEC rip me
apart and refute my extremely serious allegations 1 by 1. Bring the SDNY too. Better yet: RE forward my
information to Handler,Cifu et al. I know they have already seen it from the SEC. I still have yet to be sued by
ANYONE related to my information. The Opco Denial Award is also further evidence of SEC criminal obstruction.
EFTA00083513
A gross mishandling of my information to both bring strategic complaints while protecting the criminal entity
NITE. Ms Norberg has created some of the most extraordinary reasons for denying my award. The best so far:
"SEC investigators never saw my information". An acknowledgement of SEC criminal Obstruction. It is the job of
the OWB exclusively and explicitly to distribute whistleblower information within the SEC. A whistleblower has
no way of knowing WHO at the SEC is working on a case. Further, despite my request for Norberg to produce
the entirety of my extensive record with the SEC, she failed to do so.
What was the denial in Opco based on? The SEC, Clayton, Handler, Jefferies, NITE et al ongoing massive fraud
on the public must continue. So it does.
Mr Kamensky must have my information.
This massive fraud on the public MUST end. ALL of it
Per the extensive record and my derivative TCR's: It isn't just NITE,Cifu,Handler,Jefferies et al the SEC is
protecting. Is it Jane?
Regards,
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Tuesday, July 7, 2020 6:09 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Janey,
MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw
whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of
my award application/denial/appeal AND REQUIRED by the statute I have referenced:
240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on
appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you
failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were
merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for
preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several
hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the
EFTA00083514
record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF
the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed.
But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the
RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not
confined to Opco,NITE,UBSS,Sason,Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money
laundering/transaction
laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa
rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's
but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering
up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down
the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a
thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity.
Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is
linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on
my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this
massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money
laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed
fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so
NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill.
ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business
by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite
common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while
screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC
cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by
ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the
brain child of Chair Clayton and his Sull Cromm colleague Jared Fishman who has played a key role in keeping
the criminal entity NITE/VIRT up and running.
NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE?
Only another fraud: Mullen.
Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership.
The K50 EV is manufactured in China by Cdantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in
China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US.
But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR
attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that
facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to
the SEC: the record: known as SeeThroughEquity
https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259.pdf
Seethruequity, LLC, Ajay Tandon, and Amit Tandon
THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in
2011 by brothers Ajay Tandon and Amit Tendon.
www.sec.gov
SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018
https://www.netelement.com/press-releases/release-content/1062906ThXwRXEOWSn IV
EFTA00083515
SeeThruEquity Issues Update on Net Element, Inc.
NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading
independent equity research and corporate access firm focused on smallcap
and microcap public companies, today announced that it has issued an update
on Net Element, Inc. 0. The note is available here: NETE April 2018 Update
Note. Net Element Inc. (NASDAQ: NETE, "Net Element") is a global financial
www.netelement.com
hups://www.netelement.com/press-releases/release-content/10734671/1.XwRXGuWSnIV
SeeThruEquity Issues Update on Net Element, Inc.
NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading
independent equity research and corporate access firm focused on smallcap
and microcap public companies, today announced that it has issued an update
on Net Element, Inc. 0. The note is available here: NETE August 2018 Update
Note. Net Element Inc. (Nasdaq CM: NETE, "Net Element") is a global financial
www.netelement.com
So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This
P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for
the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone?
The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares
Act money.
A summary of the record.
Janey, Hoecker et al,
Please update my Net Element and AQR TCR's
Cheers!
Christopher J Dilorio
Whistleblower
Not just irony but a massive fraud on the
From: Chris Dilorio
Sent: Tuesday, June 30, 2020 1:01 PM
EFTA00083516
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Janey,
the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any
more clear: run the clock out and protect NITE,UBSS,Magna et al while denying me rightful compensation. But,
As I have repeatedly told you, Hoecker, your colleagues: the last overt act of this vast conspiracy has not yet
occurred:
NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and
always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate
money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as
to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally
misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal,
shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can
circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct
result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the
criminal enterprise known as Knight/KCG/VIRT: NITE.
Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY
until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a
monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another
enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the
OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the
investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists
SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY
so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC
who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank
check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut
down IMMEDIATELY.
Certainly not exhaustive BUT a good start
Cheers!
Christopher J Dilorio
Whistleblower
From: Chris Dilorio e
>
Sent: Tuesday, June 30, 2020 7:36 AM
EFTA00083517
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Janey,
please add the following info to my appeal of your preliminary denial of my Opco award.
More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct
complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several
years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence
to support my allegations.
Highlighted in my attached TCR and related to my Opco Award application: Joshie Sason/Hanover/Magna:
CGFIA, IMDS,NewLead,FreeSeas, PRTH etc etc etc. The SEC Sason/NewLead complaint is also my information as
I filed separate but related NewLead, and FreeSeas TCR's with your office. The SEC complaint: Sason
assignments: bogus notes. NO SHIT? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I
detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the
FINRA World Trade Financial complaint.
https://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-anti-
money-laundering
FINRA Fines Three Firms $900,000 for Inadequate Anti-Money Laundering
Programs I FINRA.org
WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined
three firms a total of $900,000 for failing to establish and implement adequate anti-money laundering
(AML) programs and other supervisory systems to detect suspicious transactions.
www.finra.org
Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA
requested information from Keener related to his assignments and acquisition of bogus convertible notes
including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off"
https://www.finra.org/sites/default/files/OHODecision/p182993 0 0.pdf
FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING
OFFICERS
5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On
September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA
EFTA00083518
www.finra.org
FINRA barred Keener/JMJ in 2013 as a "Bad Actor"
The SEC was certainly aware of the FINRA action
https://www.sec.gov/litigation/opinions/2012/34-68014.pdf
As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink
Charging fka New Image Concepts
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0
https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm
EDGAR Filing Documents for 0001144204-19-004046
Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 I State of
Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G/A I Act: 34 ...
WV:Vi.sec.q ov
New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to
Keener involvement.
https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf
Case No. 2:16-cv-03250
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document
1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ...
vo.vvy sec g ov
But Keener not the only 1 involved who knew New Concept was a money laundering shell.
CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days.
The SEC revoked the registration of Farkas/Skyway in 2007
https://www.sec.gov/cgi-bin/browse-edga r?
action=getcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0
The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction
laundering blank check shell: Cazador/Arco: Net Element
A director of Blink is a guy named Donald Engel who worked at Drexel with Milken.
New Concepts was HQ'd in Santa Monica: Milken
But it gets better
the Jaclin shell factory also linked to Honig,Stetson,Alpha Cap, Frost as well
http://www.teribuhl.com/2019/08/06/honigs-shell-factory-attorney-gregg-jaclin-barred-as-sec-lawm1
EFTA00083519
Gt'
Honig's Shell Factory Attorney Gregg Jaclin
Barred as SEC lawyer - TERI BUHL
Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon
off the Board - L.A. Cannabis News on Text messages show
Cannabis investors Defrancesco & Serruya allegedly Colluded
with Clarus Securities' Christodoulis in Multiple Stocks; High
Times Admits SEC Filing is Wrong: Stormy Simon off the Board -
www.teribuhl.com
Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached
TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled
Gruntal int Ladenburg. Gruntal: Icahn,Sater,SAC,Feinberg et al: Milken
The SEC intentionally omitted a Honig/Stetson shell from this complaint:
Millenium Bio/lnergetics
linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran
In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019.
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0
Finally,
SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey,
The SEC is going after Keener/JMJ related to my information AGAIN
17.5 BILLION shares of money laundering penny stocks.
https://www.sec.gov/litigation/litreleases/2020/Ir24779.htm
Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020)
SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and
Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020)
yAvw.secgov
WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering
shells????
What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus
notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND
CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint
AND where NITE and UBSS traded billions of shares of CGFIA
AND where NITE and UBSS traded billions of shares of IMDS also
Now, what are the odds of all of that?
All you have to do is read my attached TCR Janey.
Cheers!
EFTA00083520
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Tuesday, June 23, 2020 4:11 PM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
small typos/corrections:
Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume
data in 1Q2014 and 2Q2014 that were expunged from KCG 10Q SEC filings. Not 2Q2014 and 3Q2014 SEC
reviewed 10Q's as I previously stated
corrected below
Chris
From: Chris Dilorio
Sent: Tuesday, June 23, 2020 9:48 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Ms Norberg,
I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of
my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office
related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR
submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following
detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even
though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating
EFTA00083521
evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to
send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in
notifying me. ALL of my response pertains to the denial appeal at hand.
In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly
implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss
banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I
was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the
extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS
activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply
a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share
equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales
person: analyzing financial statements and making investment recommendations formed the basis of my
expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed
the SEC that NITE was insolvent having reported just $105 mil in working capital at June 30, 2011. AND, for the
resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self
clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations
and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the
public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the
latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well
as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that
the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant
state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive
naked shorting. NITE is still in business TODAY.
The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money
laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and
virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against
NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST
OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed
separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on
NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place
without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is
NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a
template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the
Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton
home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A
transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate
acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic
and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna
also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel
Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO.
Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM
shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca
Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the
FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a
million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver
dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a
rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the
executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes
no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY
EFTA00083522
INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint?
What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the
SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity.
Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020.
The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key
point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge
financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip
change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE
accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance
sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral
based. Rather a 50% discounted convert when the stock had already been crushed to $3 OR $1.50. ALL of the
financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in
pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure
financing is an offer to sell. JPM looked the other way. As did the SEC.
Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny
stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades?
2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG
closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border
activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA
OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border
DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal
activity.
Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC.
Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital
Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC
recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In
IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS
at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of
IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a
NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme
bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated
by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS.
I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on
NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of
Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against
Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on
the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits
by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover.
Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm
Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated
documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money
laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the
tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run
by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me
to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC
through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by
the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ.
AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity
Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved
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the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and
Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell.
Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff:
Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff
also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on
steroids. Cereplast ended in bankruptcy.
NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone
profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami,
Apockinas/Grinshpun/Antonov/RakisheviTrump/Kushner/SBNY/CardWorks/Merrick Bank/ESCt/Cohen etc etc
etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my
NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer
money then announcing it was "unlocking the value in its misunderstood payment processing business" by
doing a reverse merger with a CA electric car company started by a former musician. The payment processing
business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction
and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers
related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and
somehow settled on "mobile app developer" Austin TX: Phunware. PHUN CEO is well known to the SEC with
shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the
"genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional,
Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy:
Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale
campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check
shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings.
Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was
"securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office.
Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction
over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the
PHUN/Trump/Kushner/Parscale mobile app technology.
Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken
family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also
transaction/money laundering like NETE. Also involved: Hanover/Magna.
ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke
CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In
NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity.
SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked
short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease.
This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT.
Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or
CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born.
But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The
SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer.
Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still
"IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly
contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can
circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC
suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger
and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and IM0S. The SEC
response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of
fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In
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1Q2020, the receivable at NITE/VIRT increased $1.2 BILLION sequentially. Up almost 90%. AND the tangible
book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that
NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of
transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency.
Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include:
Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize
its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So
what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech
as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years:
what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg:
Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank ($50 bil Bad Bank to Goldman). Another
Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal:
Feinberg,SAC,Icahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by
Vector/NewValley:Icahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC
risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken
also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear
Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump
and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis,
Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence
that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed
out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black:
HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an
Epstein money laundering vehicle: JUNK IS JUNK.
THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal
obstruction.
SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared
Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his
disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate
this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in
the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and
Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction
NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017.
Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate
Cifu/Coleman/Handler/GS/JPM wrote down more than $4 billion in open naked short fails: "leverage". The SEC
let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT
grossly OVER paid for insolvent KCG.
Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including
OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to
NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well
orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of
the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no
affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other
shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014
10Q was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over
year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not.
This portion of the KCG 1Q2014 10O was expunged as well as 2Q2014 OTCM share volumes. I have detailed this
to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out
monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked
shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG.
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The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including:
management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into
trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an
absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS
trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red
flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked
short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's
either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades
as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision
filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my
TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust:
"worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by
the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies.
Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own
money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff
Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming
Messenger also receiving taxpayer Cares Act money.
Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it
did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG
Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to
the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr)
also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr
John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know
Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint.
OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money
laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this
shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a
very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation
HOW? According to stories: activity peaked in 1H2014. Coinciding with NITE astronomical OTCM 1Q2014 share
volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's.
Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR:
P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of
thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock
trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that.
Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint.
This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells:
$850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the
complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award
application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I
filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki
flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint.
As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them.
That was the last I heard from them although I continued to send them my information.
To the SEC IG Carl Hoecker: In 2015 I parted ways with Berger as I was convinced the SEC was using my
information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file
an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an
award application for the UBS Reg Sho complaint. In my submission and my correspondence with
Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that
would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting
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publicly traded shells and money laundering. My application was denied and there was no investigation into
this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming
admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA
because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to
obstruct.
I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM,CS, and
DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found
nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker
arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had
changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures.
Cifu refused to publish KCG 2O2017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and
running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG
handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by
Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did
not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of
offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 I have never
been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the
OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has
solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have
verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by
SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified
in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading
profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered
my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're
illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes,
there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the
SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious
allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct
complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my
information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for
it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as
further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting
SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre
ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr
Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing Audrey Strauss/Trump/Barr
don't you think? The SEC needs some fixers. Wonder why.
I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated
conspiracy has not occurred yet.
Cheers!
Christopher J Dilorio
Wistleblower
EFTA00083527
From: Chris Dilorio ‹
>
Sent: Wednesday, June 10, 2020 2:30 PM
To:
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Mr Roach,
The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to
BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying
me rightful compensation. This is the latest example
Chris
From: Chris Dilorio ‹
>
Sent: Monda Ma 18, 2020 10:36 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
As straightforward as it gets:
The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice.
The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected
them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna.
The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10O in
2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC
Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint
cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners
proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the
FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my
Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute
Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the
massive fraud taking place continued well into 2020. The 1Q2020 10O proves this.
The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious
matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with
his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin
worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal
obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before
the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT
merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever
happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive
,ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC
MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY.
In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law
enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The
criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal
investigation OR a GAO investigation.
You are incorrect in your analysis.
I Urge the IG Integrity Board to have SEC IG Hoecker refute my claims point by point.
I will be on a plane tomorrow so he can do it in person.
EFTA00083528
Cheers!
Christopher 1 Dilorio
Whistleblower
From: Chris Dilorio <
Sent: Tuesday, May 12, 2020 8:54 AM
To:
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
>
>
Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this
appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring
complaints AND obstruct complaints while denying me compensation. In short: My information exposes an
ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has
chosen to cover up so that the illegal activity can continue. It does in 2020
Chris
From: Chris Dilorio <la
Sent: Monday, May 11, 2020 7:16 PM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
From: Chris Dilorio
Sent: Wednesda A.ril 29 2020 8:03 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
The SMOKING GUN in my allegations:
Naked shorting in CGFIA (My TCR/FINRA complaint) by "un named third party BD" in 2013. Well known to the
SEC. This is why there was no investigation into the ENTIRETY of the FINRA trading activity. The SEC issued
waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and
executing BD's/MM's in the Opco complaint? ALSO well known to the SEC:
MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this
ongoing conspiracy has not yet occurred.
Chris
From: Chris Dilorio
Sent: Wednesday, April 29, 2020 7:56 AM
EFTA00083529
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into
Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used
my information to bring AND obstruct complaints.
The 2 SEC Commissioners dissent in granting Oppenheimer waivers after this egregious activity
https://www.sec.gov/news/statement/dissenting-statement-oppenheimer-inc.html
SEC.gov I Dissenting Statement In the Matter of Oppenheimer & Co., Inc.
Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and
Commissioner Kara M. Stein, February 4, 2015
www.sec.gov
In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer
trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar
complaint. WHO was the SEC protecting with its complaint then waivers?
The smoking gun which I have provided to the SEC on several e mails:
Which came in an SEC reviewed CGFIA 10O
https://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi 10q.htm
cgfi_10q.htm - SEC
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or
15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period
that the registrant was required to file such reports), and (2) has been subject to such filing requirements
for the past 90 days.
www.sec.gov
pg 27
"Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)"
"On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's
Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the
"Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC,
Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are
held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action."
Of Course, I have hard copies if you prefer.
ex clearing: The illegal SEC/DTCC Obligation Warehouse.
EFTA00083530
This is CLEAR,IREEFUTABLE,INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This
activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an
investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the
executing BD's/MM's? WHO were the customers?
The veracity of my information is also irrefutable and incontrovertible.
Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so
that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to
bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME).
The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It
had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary
denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al.
IN FURTHERANCE OF THE CONSPIRACY
Cheers!
Christopher _I Dilorio
Whistleblower
From: Chris Dilorio
Sent: Tuesday, April 28, 2020 7:24 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT
(and AQR) money laundering shells.
The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information
https://www.sec.gov/litigation/complaints/2019/comp24403.pdf
Marc P Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place
200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN
DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL,
3 S. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead
attempted to disguise as an asset sale transaction.
vo.vw.sec cloy
https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773 scl3g.htm
EFTA00083531
www.sec.gov
(i) Sole power to vote or to direct the vote . The information required by Item 4(c)(i) is set forth in Row S of
the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting
Person.
www.sec.gov
MG Partners Ltd: Abitebol
But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol
As with Opco/GIBRALTAR, who is the SEC protecting?
AND, per my extensive correspondence with the SEC re my TCR's: The SEC is ALSO grossly under estimating the
criminal activity in NITE/Magna/NewLead
SEC: Criminals bailing out/actively facilitating criminals/criminal activity.
soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct
complaints/deny whistleblower rightful compensation.
Cheers!
Christopher) Dilorio
Whistleblower
From: Chris Dilorio
Sent: Tuesday, April 28, 2020 6:43 AM
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
More evidence of SEC fraud on the court in Gibraltar.
It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action.
The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where
Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the
FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough
investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint
go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit
MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity?
The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed
a fraud on the court in Gibraltar.
Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011.
https://www.pr.com/press-release/355246
Gibraltar Global Securities Now Offering Offshore Brokerage Accounts -
PR.com
EFTA00083532
Nassau, Bahamas, The, September 22, 2011
Gibraltar Global Securities is now offering offshore
brokerage accounts in addition to their broad array of financial services.Gibraltar Global ...
www.pr.com
https://www.pr.com/press-release/355247
GGSI Bahamas is Now Offering Pink Sheet Clearance
Offshore Broker Adds to Buying and Selling Services
www.prcom
https://www.pr.com/press-release/369649
GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions
and Communication
GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures
designed to protect their client’s personal data, and to secure electronic communication.
www.pr.com
The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well
into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT.
Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS.
2 criminal entities bailed out by the SEC.
Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015-
016: "The investigators never saw the claimants information".
WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on
the OWB itself.
More criminal activity.
Criminals bailing out criminals while denying Whistleblowers due process and compensation.
Cheers!
Christopher J Dilorio
Whistleblower
From: Chris Dilorio
Sent: Sunday, April 26, 2020 9:36 AM
To:
Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix
EFTA00083533
From: Chris Dilorio
Sent: Frida , A ril 24, 2020 8:18 AM
u ject: orma appea or pre iminary enia covere action
1 - 1
Knig t apita
R
Appen ix
I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015-
016
This is my formal appeal of the SEC preliminary determination.
My award application was based on this very simple FACT:
The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action
FINRA
https://www.finra.org/sites/default/files/fda documents/2009018668801 FDA KMX39652.pdf
of - FINRA
which isFINRA a party, to the entry of findings and violations consistent with the allegations of the
(asComplaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth
andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary
andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ...
www.finra.org
The SEC
https://www.sec.gov/litigation/admin/2015/33-9711.pdf
Before the SECURITIES AND EXCHANGE COMMISSION
Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 /
January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 .
ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE
PROCEEDING . File No. 3 -16361 . In the Matter of
www.sec.gov
FINCEN
https://www.fincen.gov/news/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-anti-
money-laundering
FinCEN Fines Oppenheimer & Co. Inc. $20 Million for Continued Anti—
Money Laundering Shortfalls I FinCEN.gov
EFTA00083534
Washington, D.C. — The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S.
Securities and Exchange Commission (SEC), assessed a $20 million civil money penalty today against
Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities
broker-dealer in New York, admitted that it failed to establish and implement an adequate ...
www.fincen.gov
In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also cc'd Sean
McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this
correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted
by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and
UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML
complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In
fact, per the FINRA Opco complaint above, customer "TC" was dumping worthless AppTech (APCX) certificates
well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR
attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share
my information with SEC investigators? Current SEC OWB Chief Norberg was previously an assistant to then
OWB Chief McKessy.
WHO ultimately executed the trades cited in the FINRA Opco complaint?
Further, the SEC Gibraltar Securities complaint raises more questions than answers as well.
https://www.sec.gov/litigation/complaints/2013/comp22683.pdf
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL
SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov
12. David Della Sciucca, Jr., age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or
complaint, the Commission charged Della Sciucca with acting as a nominee
www sec g ov
The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The
complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing
BD/MM.
The SEC Oppenheimer AML cites Gibraltar trading activity also.
The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY?
The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants ill-
gotten gains...."
http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/
EFTA00083535
Bahamian broker in $25m sanction I The Tribune
A former Bahamian broker/dealer and its principal have been hit with a combined $24.484 million in
financial sanctions by a US court, which found that their "ill gotten gains" were likely ...
www.tribune242.com
WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out"
$46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC
protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly
know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While
the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and
UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have
triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its
OMISSION of material information?
The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions
than answers.
My Award application for the Oppenheimer AML SEC complaint was 5 years ago. That's FIVE years ago. So, WHY
NOW am I so blessed by the SEC with a preliminary judgement?
The SEC basis for denying my Award claim for covered action 2015-016:
"Investigative staff responsible for the covered action NEVER RECEIVED ANY INFORMATION FROM THE
CLAIMANT OR had any communication with the claimant"
Let's take this whopper in 2 parts:
First, the SEC OWB denied my Award application because The investigators in the complaint never received my
information. Has the SEC OWB re written the investigative protocol in this denial? How am I or ANY
whistleblower supposed to know WHO the investigators are in a particular case WHEN according to the SEC:
ALL investigations are done in a confidential manner????
WHAT DOES THE SEC DO WITH WHISTLEBLOWER TIPS EXACTLY? Do they share whistleblower information with
ENFORCEMENT as is mandated? HOW would ANY whistleblower know WHO to share information with at the
SEC? Isn't that the job of the SEC OWB?
Second, the fact that no one at the SEC contacted me DOES NOT mean the SEC didn't use my information. This
is a completely bogus argument. It certainly would NOT be the first time the SEC used my information now
would it Jane?
In fact, it is NOT the responsibility of the whistleblower to get his/her information to the right Enforcement
personnel. That responsibility EXPLICITLY falls on the SEC OWB. So, is the SEC OWB admitting gross negligence
in handling my information? After the monumental failure in the Madoff Ponzi/ money laundering SEC
facilitated scam on the public the then SEC IG made specific recommendations to the SEC with regards to the
proper handling/vetting of Tips and Complaints.
https://www.sec.gov/files/468.pdf
Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment
Securities, LLC
EFTA00083536
Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC Executive
Summary Background. On June 25, 2009, the Securities and Exchange Commission's
vx,rw.sec.g ov
AGAIN: The responsibility to properly vet Whistleblower information and get the information into the right
hands at the SEC falls EXPLICITLY and EXCLUSIVELY with the SEC OWB itself and is NOT the responsibility of the
whistleblower. Further, according to the previous SEC IG in the monumental Madoff failure: the responsibility
to contact those supplying Tips and Complaints ALSO falls explicitly and exclusively with the SEC OWB and not
the whistleblower. Using these excuses as the basis of denial of Award is completely contrary to SEC
MANDATED protocols and procedures.
Is the SEC OWB admitting it doesn't comply with those recommendations? Recall: the monumental SEC Madoff
failure was NOT the fault of Whistleblowers either. OR is the SEC OWB scrambling for a 5 years in the waiting
preliminary determination?
So, after 5 years of waiting for a preliminary determination for my award claim, this is what the SEC best and
brightest come up with?
My Denial of Award for covered action 2015-016 was completely made up on the fly.
The SEC OWB has applied completely fabricated "rules" to issue this denial. Further affirmation of ALL of my
allegations.
Also by SEC admission, the SEC allowed these 2 penny stock shells to remain a clear and present risk to the
investing public. Were CGFIA and APCX ONLY money laundering shells for Oppenheimer in 2008-2010 and then
suddenly they were no longer money laundering shells when NITE and UBSS traded billions of shares of both
shells 2010-2013?
WHY did it take until September 2018 before the SEC finally revoked the CGFIA registration?
https://www.sec.gov/cgi-bin/browse-edgar?company=Garpa&owner=exclude&action=getcompany
So, WHY was there no SEC investigation of NITE and UBSS trading activity in money laundering shells APCX and
CGFIA? The SEC et al facilitated NITE "glitch" took place in August 2012. This SEC/Jefferies/JPM/BX/GS/SEC Chair
Clayton Sullivan Cromwell colleague Jared Fishman et al bailout coincides directly with NITE trading activity in 2
SEC/FINRA/FINCEN acknowledged money laundering shells. AND the "bailout" penny stock esque reverse
merger between Getco and Knight didn't close until July 2013. HOW could the SEC conduct a COMPLETE and
thorough investigation into the FINRA Opco AML complaint WITHOUT implicating NITE when NITE was CLEARLY
trading billions of shares of OTCM money laundering shells BEFORE and coinciding with the SEC et al facilitated
"glitch" bailout? For UBSS, the DOJ dropped its cross border AML DPA complaint in 2010. UBSS was trading
money laundering shells well after the Dal claimed UBSS was in compliance with the cross border DPA.
To be clear: BOTH NITE and UBSS knew CGFIA and APCX were money laundering shells when they traded
billions of shares of each 2010-2013. Is that FACT disputed by the SEC? The SEC OBSTRUCTED a thorough
investigation into the ENTIRETY of trading activity of NITE and UBSS in CGFIA and APCX: MY CLAIMS. Josh
Sason/Hanover/ Magna knew CGFIA was a money laundering shell also
https://www.sec.gov/Archives/edgar/data/1344394/000114420413041432/0001144204-13-041432-index.htm
ALSO in my claims: Joshua Sason/Hanover Magna. CGFIA. Also my NewLead TCR1426518350699 and FreeSeas
TCR1440274395191 separate but related TCR's where NITE was a top trader in both and BOTH TCR's were filed
well in advance (years prior) to the Sason/Hanover/Magna February 2019 complaint. Here's one thing the SEC
has been consistent about: The SEC ignores the role of executing BD's and MM's in these scams. WHY? Because
NITE is the #1 OTCM shell trader. As far as the SEC is concerned Penny stock trading fairies convert worthless
certificates into real money. NO! Executing BD's/MM's like NITE do. Did Oppenheimer sell this order flow to
NITE? Who ultimately converted these worthless certificates to real money? As the number 1 OTCM money
laundering shell trader it is statistically improbable the NITE has never been the focus of an SEC AML complaint.
EFTA00083537
Per my TCR: what does the NITE Compliance Department do exactly? How many SAR's has NITE filed in the last
10 years? In a 2015 SIFMA speech then SEC Enforcement Director Ceresney was "SHOCKED" by the number of
BD's filing 1 or ZERO SAR's. That was just 5 years ago. WHEN would NITE file a SAR releted to the billions of
shares of OTCM money laundering shells it trades like CGFIA and APCX: BEFORE or AFTER it trades those
BILLIONS of shares?Does NITE pull markets and alert regulators OR continue to trade billions of shares of OTCM
money laundering shells in the face of GLARING AML red flags? In fact, in December 2019 the top traded
NITE/VIRT OTCM money laundering shell was ELTZ
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0001607281&owner=exclude&count=40&hidefilings=0
The SEC knows the people/entities in ELTZ well
https://www.sec.gov/litigation/admin/34-46993.htm
Strata Coal Company and Terrence A. Tecco: Admin. Proc. Rel. No. 34-
46993 / December 13, 2002
Strata Coal Company ("Strata" or "the company") is a non-reporting Nevada shell corporation based in
Frisco, Texas. Strata's shares are quoted on the Pink Sheets under the symbol SCOC. Until September
2002, the company was known as WesPac Technologies, at which time it changed its name to Strata. 2.
Tecco is the sole officer, director, and ...
www.sec.gov
https://www.sec.govinews/press-release/2019-16
SEC.gov I SEC Charges Broker-Dealer and Transfer Agent in Microcap Shell
Factory Fraud
The Securities and Exchange Commission today announced charges against a broker-dealer, a transfer
agent, and three individuals for their roles in the creation of over a dozen undisclosed "blank check"
companies from 2009 to 2014.
www.sec gov
Doesn't the NITE/VIRT compliance Department have internet service in Jersey City? As a DIRECT result of the
SEC obstructing a complete and thorough investigation into the ENTIRETY of trading activity in APCX and CGFIA,
the top NITE/VIRT traded OTCM money laundering shell in December 2019 was AML red flags galore ELTZ.
Illegal activity ACTIVELY facilitated by the SEC. The examples cited in this e mail are not exhaustive.
And, for it's part AppTech is up and running again/still
https://www.sec.gov/cgi-bin/browse-edgar?company=Apptech&owner=exclude&action=getcompany
Unfortunately, AppTech is still up and running as a direct result of the aforementioned SEC " CLEARLY under
estimating" otherwise known as CLEARLY OBSTRUCTING.
EFTA00083538
In conclusion, The SEC solicits information from whistleblowers like me. The SEC uses whistleblower information
to bring actions and then doesn't compensate whistleblowers for their information.
OR
The SEC uses whistleblower information to protect criminality perpetrated on the investing public so that this
criminal activity can continue. BOTH are gross dereliction of the stated and MANDATED SEC Whistleblower
statutes. To blame a whistleblower for the SEC's EXPLICIT and EXCLUSIVE responsibility to properly vet and
distribute whistleblower information within the SEC as an excuse to deny Awards is also criminal activity. The
SEC: criminals using whistleblower information to protect other criminals AND deny whistleblower rightful
compensation for their information.
I appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG.
Cheers!
Christopher J Dilorio
Janey,
how long have you been in possession of my Knight Capital TCR? Almost 7 years to the day. How many follow up
e mails have I sent the SEC since then?
For 7 fucking years, the SEC has known about JMJ/Keener. I told them
https://www.sec.gov/litigation/complaints/2020/comp-pr2020-72.pdf
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT
OF FLORIDA SECURITIES AND EXCHANGE COMMISSION No. COMPLAINT
SUMMARY - sec.gov
5. Justin W. Keener, age 45, resides in San Juan, Puerto Rico.During the Relevant Period, Keener was a
resident of Miami Beach, Florida. Keener registered the name "JMJ Financial" as a fictitious name in Florida
in 2008 and used it to conduct the business described
veww sec g ov
In February 2019, the SEC brought an action against Joshua Sason/NewLead
I told the SEC about Magna/ Sason ALSO in my 2013 TCR.
https://www.sec.gov/litigation/litreleases/2019/Ir24403.htm
Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019)
Washington, D.C., February 15, 2019 - The Securities and Exchange Commission today announced charges
against four individuals and related businesses for their roles in two microcap frauds and unlawful
securities offerings.
veww. sec .g ov
EFTA00083539
AND, I filed separate but related NewLead and FreeSeas TCR's in 2015
Then there's the UBS AML complaint.
ALSO my claims. For which I sent 10 (TEN) separate Award applications from a commercial fax machine in
April/May 2019. AND I have YET to receive even a preliminary determination from the OWB/Norberg
IG, I see your "investigation" into my very very serious accusations of Obstruction related to my information was
thorough. In short, the SEC has and still is ripping me off.
Janey, be a hun and update my TCR's/Awards cited in this e mail.
And Ms Welshhans, a couple of questions for you:
1) Have you read the FINRA WTFC Keener complaint? Fictitious notes Ring a bell?
Same MO as Sason/Magna/NewLead/FreeSeas etc etc etc
2) WHO executed the Keener OTCM trades in your complaint? Penny stock trading fairies?
YES, NITE was a top trader in BOTH FreeSeas and NewLead
The core business at NITE/VIRT is and ALWAYS has been: abusive naked shorting OTCM (and other) shells to
facilitate money laundering.
In short Ms Welshhans, NITE/VIRT converts these worthless certs into real money. NONE of
JMJ/Sason/IBC/Ironridge/Asher etc etc etc activity takes place without a willing,corrupt, criminal, executing
BD/MM like NITE/VIRT, CDEL etc
Finally, The Keener SEC complaint is FURTHER evidence that FINRA has NO business enforcing US securities
LAWS. When FINRA "invited" Keener to a disciplinary hearing almost 7 years ago, Keener told them to "fuck
off". FINRA bar meant nothing the last 7 years. EXCEPT JMJ/Keener/NITE ripping off more investors.
Obviously the SEC has/is using my information. I expect to be compensated.
Cheers!
Christopher Dilorio
Whistleblower
Mr Peirce,
Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of
accountability. I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the
BSA to FINRA BECAUSE it is not accountable. The SEC has not initiated a single stand alone AML complaint.
The Brown Brothers Harriman AML complaint IS my claim. ALL of the entities in the complaint are un named
WHY? My SEC and IRS Whistleblower complaints explain why.
Hello, My name is Chris Dilorio. I have filed extensive SEC and IRS Whistleblower complaints alleging a direct
link between penny stock money laundering, domestic and foreign entities, Swiss Banks, and executing brokers
like KCG and UBS. I can provide overwhelming evidence of SEC obstruction. Please read the FINRA Brown
Brothers Harriman AML complaint. This is my claim. All of the entities in the complaint are un named. Why?
The SEC is not only obstructing an investigation, they are aiding and abetting the activity. These are not far flung
theories. The UBS Whistleblower Birkenfeld and his attorney sent 52,000 accounts to the SEC and DOJ. The
DOJ at the influence of President Obama and Hillary Clinton entered into the UBS DPA based on just 4400.
What is so egregious is the activity continues un abated today.
Start with the so calledAugust 2012 Knight/KCG trading "glitch". Initial reports say the NYSE was breaking the
trades. WHY did they stop. Former KCG CEO Joyce said he had a very frank discussion with then SEC Chair
Schapiro where the SEC wanted to send a very strong message to market participants. Why not just continue to
EFTA00083540
break the trades and hit KCG with a hefty fine? That would not create the conditions to grant KCG exception
after exception to do their emergency funding which transferred 74% of the company to "glitch" funding
participants and ultimate reverse merger partner GETCO. AND, despite claiming to having a "highly liquid
balance sheet" KCG had to raise the entire amount of the loss.
A very significant and public event was cited in a WSJ article where immediately following the "glitch"KCG
inadvertently sent 4000 worthless securities to JPM in an attempt to secure a tri party financing where JPM
guaranteed the loan. This is discussed in my attached TCR's and also the topic in a March 2014 letter I sent to the
SEC. In the end, the emergency funding was NOT collateral based. The participants knew exactly what a fraud
the KCG balance sheet was. After the stock was decimated to $3, the deal was a convertible with a conversion
price at a 50% discount or $1.50/ share.
There is much more, but this is a good start.
Recently, KCG did a modified Dutch auction where they "sold" an asset (HotSpot) to an entity both KCG and
GETCO were a major shareholder (BATS) KCG CEO Coleman called it a "highly competitive process".
Virtually all of the proceeds went to buy back stock from "glitch" financing participants. The purchase price was
$14/share. The stock had never traded there and hasn't since. Reports say 82 million shares were tendered at or
BELOW $14. But they chose to repurchase 23 million shares AT $1499” 9 I have overwhelming evidence that
supports my allegations that the SEC is engaging in criminal obstruction to protect KCG.
I) Current KCG Dan Coleman ran Equities at UBS during the massive REG Sho violations as well as the cross
border activity detailed by Whistleblower Birkenfeld. White and Ceresney represented UBS prior to joining the
SEC
2) At June 30 2011 KCG/Knight reported just 105 million in working capital with hundreds of millions in
worthless securities sitting on its balance sheet. KCG was insolvent
3) The SEC orchestrated the emergency funding for KCG following the so called Aug 2012 trading "glitch"
4) Read FINRA AML complaints against Brown Brothers Harriman. This is my claim. It links penny stock
money laundering to executing brokers like KCG, domestic and foreign entities, and Swiss banks. ALL of the
entities in the complaint are un named. WHY?
5) The FINRA World Trade Financial AML complaint discusses several entities cited in my claims. The
customer the complaint focuses on is Justin Keener. Still very much in business. The red flags cited by FINRA
were cited in my claims as well. Yet still no investigation.
6) in July 2015 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat the SEC. He had never seen my
information. The IG OCIE Madoff report mandated the OCIE to vet information. McKessy and Ceresney never
sent my info to him
7) I'm sure you are familiar with the Manning v Merrill,KCG,UBS et al litigation. The SEC does not want an
investigation into my claims while the litigation is pending.
8) My claims detail ex clearing trading activity by KCG and UBS. despite the glaring red flags in doing so. Ex
clearing s the Obligation Warehouse. A NON GUARANTEED SERVICE set up by the SEC and DTCC to allow
firms like KCG to circumvent close out requirements of Rule 204. Clearly contrary to the intent of the SEC
authorization in Sec I7a of the 1934 Act to create a system of prompt and timely settlement and to remove
impediments there of.
In short, I told the SEC KCG was insolvent in 2011. Rather than investigate and prosecute, they chose to
obstruct. The activity in my TCR's pre dates the "glitch". An investigation would show the SEC bailed out a
criminal enterprise. Because of the obstruction, the activity continues today unabated in stocks like
STBV,VELA,NEWL,FREE, and dozens more. The investing public remains at risk
More to come
Chris DiIorio
EFTA00083541
EFTA00083542
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