Microcap Fraud Investigations

When something looks off in a microcap stock, the answer is in the records. Joe finds what happened, what it means, and where that leaves you.

Engagements

Joe investigates microcap fraud for the people deciding what to do about it, whether that’s a law firm, a company, a brokerage, or an individual.

  • Suspected manipulation, dilution, or promotion in a stock you hold or trade
  • Pre-suit workups for private investor lawsuits, testing whether the records support the claims before a complaint is drafted
  • Whistleblower complaints, building the documented record behind a submission to the SEC or another regulator
  • Diligence on an issuer, financier, or counterparty before money moves
  • Reconstruction after a loss: what happened, who was involved, where the money went, and what can still be traced

What to expect

No two matters run the same. This is the general track, scaled to the matter, and the work only goes deeper where it can change the answer.

Scope
A confidential read of the matter and a conflicts check. Depending on what you are facing and where things stand, the engagement can be a higher-level assessment, a full reconstruction, or anywhere in between.
Records
Figuring out what records exist and where they live, from trading and brokerage data to bank records, transfer agent files, EDGAR and OTC Markets disclosures, and the promotion itself. When records have to be requested, Joe drafts the requests or helps counsel draft them.
Reconstruction
Trading reconstruction, bank analysis and fund tracing, ownership analysis, and promotion timelines, at whatever depth the question requires.
Findings
A written chronology and a findings memo that set out what happened, how it worked, and what the records do and do not show, with each point tied back to the exhibit behind it.
Next steps
The record is built to be used, whether for a whistleblower submission, a complaint, a negotiation, or the litigation that follows.

Qualifications

For nine years Joe was the principal investigator for the SEC’s Microcap Fraud Task Force, where he worked microcap fraud investigations from the first lead to the fully documented record. He knows which records exist, which questions decide these matters, and where they usually stall or go off track. He is a Certified Fraud Examiner with a background in finance and accountancy.

Starting an engagement

Every engagement starts with a conflicts check, covering current engagements and the matters Joe worked on at the SEC, and a confidential read of your matter. Share a short description, and Joe will respond within 1-2 business days. If it is a fit, the next step is a complimentary consultation to scope the work.

Selected matters

Three of the investigations Joe worked on.

SEC v. Bandfield

E.D.N.Y. · 2014

An offshore incorporation firm in Belize built shell and nominee structures so clients could hide microcap stock ownership and stay under reporting thresholds. The civil case ran alongside a major criminal prosecution built on an undercover operation.

SEC v. Ciapala

S.D.N.Y. · 2020

A Geneva brokerage supplied offshore nominee entities and coordinated trading for hidden control persons in EMS Find and other microcaps. It was filed the same day as related actions against the scheme’s foreign infrastructure.

SEC v. Gallagher

S.D.N.Y. · 2021

A trader promoted more than 60 penny stocks to 70,000 Twitter followers while selling into the demand his alerts created. The investigation lined up two years of posts against order-level trading data.

Ready to discuss your matter?

Share a few details about your matter, and Joe will be in touch within 1-2 business days. If it might make sense to work together, the next step is a complimentary consultation.

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