SEC v. Charles T. Lawrence, Jr.; Landes Prive, LLC; Landes and Compagnie Trust Prive aka Landes & Compagnie Trst Prive KB; HekYeaH, LLC; Justin D. Smith; and Brenda M. Bisner, No. 2:23-cv-550-pp, Eastern District of Wisconsin (Feb. 25, 2026) — Complaint

UNITED ST A TES DISTRICT COURT
EASTERN DISTRICT OF WISCONSIN

MILWAUKEE DIVISION

·-, ----~ ,- .-~- ,--
,.;,'\

UNITED STATES SECURITIES AND
EXCHANGE COMMISSION,

Plaintiff,

V.

CHARLES T. LA WREN CE, JR. ,

Case No.

-
... ,.,. .... . ·- .

23-C-055 0
--------

JURY TRIAL DEMANDED
CASE FILED UNDER SEAL

Defendant,

and

LANDES PRIVE, LLC, LANDES AND
COMP AGNIE TRUST PRIVE aka LANDES
AND COMP AGNIE TRST PRIVE KB,
HEKYEAH, LLC, JUSTIN D. SMITH, and
BRENDA M. BISNER,

Relief Defendants.

CASE FILED UNDER SEAL

COMPLAINT

Plaintiff United States Securities and Exchange Commission ("SEC") alleges as follows:

NATURE OF THE CASE

1. From at least February 2022 through the present, Defendant Charles T. Lawrence,

Jr. ("Lawrence") engaged in a fraudulent scheme involving Landes and Compagnie Trust Prive

KB ("Swedish Landes KB"), a purported Swedish financial services company with United

States-based subsidiaries. Lawrence represented to investors that he was the Managing Director

of Swedish Landes KB.

2. Lawrence raised approximately $4.9 million through the fraudulent offer and sale

of investment contracts to at least 11 investors, 7 of whom reside in 6 states in the United States

and 4 of whom reside abroad. At least 2 of the 7 United States-based investors reside in this

District. At least 5 of the 11 investors signed a contract called "Agreement for Financial and

Trade Services" (the "Agreement") with Swedish Landes KB, with Lawrence signing as the

entity's Managing Director.

3. Lawrence told prospective investors that the investment contracts he offered were

expected to provide weekly returns of 25% to 100% during the investment period, which he said

would last between 8 and 20 weeks. Lawrence also told prospective investors that their invested

funds would be "blocked" during the trading period and not be at risk. Lawrence further claimed

that investor funds would be placed in unique Swedish Landes KB non-depletion accounts and

would be visible to the investor for the duration of the investment.

4. Lawrence made additional oral representations to prospective investors. For

example, he said that he intended to use investor funds to obtain a standby letter of credit or

other collateral to facilitate Lawrence's trading in securities and other assets on behalf of the

investors. He also told prospective investors that the returns on the investment would be shared

pro rata among investors.

5. After they agreed to invest, Lawrence instructed investors to wire funds to a

United States-based bank account at Financial Institution 1 in the name of Relief Defendant

Land,es Prive, LLC ("Landes Prive"), over which Lawrence had sole control. Contrary to

Lawrence's representations about the safety and use of investor funds, from at least February

2022 to the present, Lawrence diverted and misappropriated at least $4.89 million of the $4.9

million raised from 11 investors. Lawrence regularly misappropriated investor funds shortly after

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the investors sent their funds to the Landes Prive bank account. He never used investor money to

procure a standby letter of credit or other collateral to facilitate securities trades or otherwise

invest on behalf of the investors.

6. Instead, Lawrence spent investor funds on personal expenses, including at least

$1.7 million at high-end jewelers and on chartered flight companies. Lawrence also_.spent

investor funds by using the Landes Prive debit card to make thousands of purchases totaling

more than $1 million. He used investor money to compensate individuals who connected

Lawrence with the investors, to pay early investors in furtherance of the scheme, and to pay other

entities and individuals affiliated with Lawrence. Those individuals and entities include Relief

Defendants Justin D. Smith ("Smith"), Smith's entity Landes and Compagnie Trust Prive aka

Landes & Compagnie Trst [sic] Prive KB ("Landes Trust KB"), Brenda M. Bisner ("Bisner"),

and Bisner' s entity HekY eah, LLC ("HekY eah") ( collectively with Landes Privf, "Relief

Defendants").

7. To convince investors that their investments were profitable and safe, Lawrence

sent weekly emails falsely reporting investors' purported weekly returns. Lawrence also

provided investors with access to an online portal that he claimed showed investors that their

money was secure in the agreed-upon non-depletion accounts. To lull investors who had

requested a return of their purported profits or capital investment, Lawrence fabricated various

reasons for months-long delays in returning the funds.

8. At least 5 of the 11 investors have not received a return of their principal or any

supposed investment profits despite weeks or months having passed after the conclusion of the

purported trading programs in which they invested. Two investors have received some payments

that Lawrence claimed represented a return of their principal investment, but these payments

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were funded at least in part by deposits from later investors in the scheme.

9. Lawrence's fraudulent investment scheme is ongoing. As recently as March 23,

2023, Lawrence obtained $100,000 from a new investor. On that same day, Lawrence spent

approximately $91,000 at a luxury vehicle dealership in Connecticut. At a minimum, $87,641 of

the $91,000 came from the new investor's funds.

10. . Lawrence knowingly and/or recklessly made representations and omissions of

material fact regarding the investments at issue. Lawrence's conduct involved fraud and deceit

and resulted in substantial investor losses.

11. Accordingly, Lawrence violated the federal securities laws, including Section

17(a) of the Securities Act of 1933 ("Securities Act") and Section lO(b) of the Securities

Exchange Act of 1934 ("Exchange Act") and Rule 1 0b-5 thereunder.

12. The SEC brings this action and seeks relief on an emergency basis to secure and

preserve whatever investor funds and other collectible assets remain, to prevent future unjust

enrichment of Lawrence and the Relief Defendants, and to hold Lawrence liable for his

violations of the federal securities laws.

13. The SEC seeks expedited reliefincluding, among other things, (a) temporary and

preliminary injunctive relief and (b) the entry of an asset freeze to secure and preserve investor

funds, as well as related ancillary relief.

14. Ultimately, Lawrence should be permanently enjoined from future violations of

the anti-fraud provisions of the Securities Act and the Exchange Act. Lawrence and the Relief

Defendants should be ordered to disgorge all of their ill-gotten gains, with prejudgment interest.

The Court should also require Lawrence to pay a significant civil penalty, and preclude

Lawrence from serving as an officer or director of a public company.

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JURISDICTION AND VENUE

15. The SEC brings this action pursuant to Sections 20(b) and 20(d) of the Securities

Act of 1933 [15 U.S.C. §77t(b), (d); §77v(a)], and Section 2l(d) of the Securities Exchange Act

of 1934 [15 U.S.C. §§78u(d) and 78aa(a)].

16. This Court has jurisdiction over this action pursuant to Section 22( a) of the

Securities Act [15 U.S.C. § 77v(a)], and Section 27(a) of the Exchange Act [15 U.S.C.

§ 78aa(a)].

17. Venue is proper in this District pursuant to Section 22(a) of the Securities Act [15

U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)]. Acts, practices,

and courses of business constituting violations alleged herein have occurred within the

jurisdiction of the United States District Court for the Eastern District of Wisconsin and

elsewhere. Moreover, at least two victims of Defendant's alleged securities violations reside in

this District.

18. Lawrence directly and indirectly made use of the means or instruments of

transportation or communication in, aµd the means and instruments of, interstate commerce or of

the mails, in connection with the acts, practices, and courses of business alleged in this

Complaint.

19. There is a reasonable likelihood th~t Lawrence will, unless temporarily,

preliminarily, and permanently enjoined, continu~ to engage in the transactions, acts, practices

and courses of business set forth in this Complaint, and transactions, acts, practices and courses

I

of business of similar purport and object.

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DEFENDANT

20. Charles T. Lawrence, Jr., age 49, is currently a resident of Connecticut, but

resided in both New York, New York, and Dallas, Texas, during the relevant time period.

Lawrence formerly worked as a trader at several SEC-registered entities, but has not been

associated with an SEC-registered entity since 2012.

RELIEF DEFENDANTS

21. Landes Prive, LLC is a Delaware limited liability company formed in April

2019 with its principal place of business in New York. Landes Prive is not registered with the

SEC in any capacity. Lawrence opened the Landes Prive bank account referenced in this

Complaint in March 2020. Lawrence is the sole signatory of the Landes Prive bank account.

22. Landes and Compagnie Trust Prive a/k/a Landes and Compagnie Trst [sic]

Prive KB is a Wyoming entity formed in February 2017 and is in good standing. Smith formed

Landes KB and controls accounts in the name of Landes KB. Landes KB received ill-gotten

investor funds from Lawrence.

23. HekYeah, LLC, is a Delaware limited liability company formed in October 2022

with its principal place of business in Texas. Bisner controls accounts in the name ofHekYeah,

and it received ill-gotten investor funds from Lawrence.

24. Justin D. Smith, age 42, is a resident of Ohio. Smith has formed several entities

that include Landes in their names. Smith, as well as certain Landes entities under his control,

was issued a cease and desist order with a consent agreement on October 1, 2020 by the State of

Ohio, Department of Commerce, Division of Securities. The order found that Smith acted as a

securities salesperson and as an investment adviser representative while Landes KB was

operating as an unlicensed securities dealer and/or investment adviser through its website,

6

~.landestrust.se. Smith, through an account in the name of Landes KB, received investor

funds from Lawrence.

25. Brenda M. Bisner, age 42, is a resident of Connecticut. Bisner has resided with

Lawrence from time to time. Bisner received investor funds from Lawrence.

RELATED ENTITY

26. Landes and Compagnie Trust Prive KB was incorporated by Smith in

Stockholm, Sweden in November 2016. Lawrence represented to investors that Swedish Landes

KB was a financial services company. As of January 2023, the company was not active and had

never been active, and had no physical employees in Sweden. Since at least February 2022,

Swedish Landes KB entered into the Agreements with at least 5 of the 11 investors who sent

money to the Landes Prive bank account at Financial Institution 1. Lawrence signed the

I

Agreements as the Managing Director of Swedish Landes KB.

FACTS

A. Lawrence Solicited Investments in Private Placements

27. Starting in at least February 2022 and continuing through the present, Lawrence

solicited prospective investors through a fraudulent offering consisting of the offer and sale of

investment contracts purportedly issued by Swedish Landes KB. Lawrence described the

investments as "private placement opportunities" where investors, without risk to their principal,

could earn weekly returns ranging from 25% to 100% on their investments during varying 8 to ·

20 week investment periods.

28. Investors in these private placement opportunities entered into the Agreements.

Lawrence signed the Agreements as Swedish Landes KB's Managing Director. Investors thought

7

they were investing with Swedish Landes KB, but that entity was apparently defunct by at least

February 2022.

29. In reality, Lawrence controlled the investors' funds because he directed investors

to deposit their funds into the United States-based bank account of Landes Prive, over which

Lawrence had sole signature authority.

30. Since February 2022, Lawrence has raised at least $4,901,652 in investor funds

from at least 11 investors. Seven of the investors reside in the United States, in six different

states, with two investors residing in this District. Four ofthe_investors reside abroad.

31. Lawrence solicited investors through representations made by email and

telephone calls, and also by using promoters. Lawrence compensated certain promoters with

investor funds.

B. Lawrence's False Representations about the Investments

32. Before they invested, Lawrence had prospective investors sign the Agreement. In

the Agreement, Lawrence made several false representations.

(
33. First, Lawrence represented in the Agreement that investor's funds ''will be in the

client's Landes account and visible at all times," with at least one investor's Agreement further

stating that the funds in the account will "be under the sole control of the client at all times."

However, Lawrence orally represented to prospective investors that he would obtain a standby

letter of credit or other collateral based on the amount of investor funds he raised. Lawrence

explained to several investors that the letter of credit or collateral would facilitate his trading in

securities, with the trading profits flowing pro rata back to investors.
J .

34. Next, Lawrence represented in the Agreement that an investor's "principal

investment will be blocked but not at risk" and further, even "[i]fthe trade is unsuccessful and

8

(

there are losses, the client's Principal fun~s are never depleted." Lawrence further represented in

the Agreement that "[i]fthe trade is unsuccessful and there are losses ... there will be no delay in

releasing the client's principal funds after [length of trading period] weeks."

35. In addition, the Agreement presents the scope of the investment contract services

as follows: "Client wishes to place [investment amount] into an acceler~ted trade program.

Landes responsibilities shall be limited to Custody of initial capital and trade profits; trade

management and allocation; Liaison between trade platform and client; maintenance and

I

settlement of all securities and cash funds; establishing a brokerage account on behalf of the

client."

36. Lastly, the Agreement did not contain a representation that any party was entitled

to compensation or to use investor funds for personal or business expenses. Rather, Lawrence

orally represented to certain investors that Lawrence and/or Swedish Landes KB would ·be

compensated from the trading profits prior to investors receiving their return on investment.

3 7. During the sam~ period, Lawrence also made a variety of additional false oral

representations to investors about how his trading would make a profit. For example, on or about

March 1, 2022, Lawrence claimed on a telephone call to at least one prospective investor­

Investor B-that he was the brains behind an investment opportunity with, and had access to, the

Abu Dhabi Investment Authority. He further claimed that this connection explained how he

would be able to generate investment profits without risk to the investor's principal investment.

On or about April 20, 2022, Lawrence told another prospective investor-Investor E-by

telephone that the Swedish Landes KB platform allowed Lawrence to trade in futures, hedge

funds, and crypto currency.

9

38. Lawrence maintained the scheme by providing investors with a Landes login that

purported to show their initial investment placed in a non-depletion account as promised. For

example, on August 1 7, 2022, Lawrence caused an email to be sent from the email address

[email protected] to Investor G containing a username and password.

39. Investors who logged into the portal saw a webpage that purported to show their

unique account number, current balance, account type, account status ( e.g., "Active"), the

currency in which the account was denominated ( e.g., "USD"), and recent debits -and credits to

the account.

40. Lawrence also sent investors weekly emails showing a fictitious weekly return on

inves~ent. For example, on or about March 19, 2022, Lawrence sent Investor Ban email

stating: "Trading this week was successful and we managed a return of 118%." On or about

March 26, 2022, Lawrence sent Investor B another email claiming that the investment had

resulted in an 83% return that week. In reality, Lawrence began to misappropriate Investor B's

funds the same day they were deposited.

C. Lawrence Engaged in a Scheme to Misappropriate Investor Funds

41. The statements and other representations Lawrence made to investors, as set forth

above in paragraphs 32-40, were false. After investors sent their funds to the same Landes Prive .

bank account, the funds were never allocated to a unique Swedish Landes KB account, used to

obtain a standby letter of credit or other collateral, used to trade securities, or otherwise used to

make investments.

42. Instead, the investor funds sat commingled in Lawrence's Landes Prive bank

account, and Lawrence used the money for a variety of impr?per purposes, including payments

for: personal expenses, to individuals who promoted the investments, to early investors, and to

the Relief Defendants, among others.

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43. Lawrence's misappropriation began almost immediately in February 2022 and has

continued since. For example:

a. on February 16, 2022, Investor H sent three wires totaling approximately

$250,000 to the Landes Prive bank account. Shortly before the investment,

the Landes Prive bank account was overdrawn and had a balance of

negative $558.96. In the two days following receipt of the $250,000

investment, Lawrence spent over $40,000 at Cartier, wired more than

$27,000 to Bisner, wired $93,000 to a Landes Trust KB account in the

control of Smith, and wired an apparent promoter $25,000 with a memo

line including "commission";·

b. on March 7, 2022, Investor B wired approximately $536,500 to Landes

Prive. That same day, among other uses, Lawrence sent $53,650 to the

person who had introduced Investor B to Lawrence with the description

"[Investor B] Commission," sent $25,000 to Bisner, and withdrew
/

$35,600 in cash. At a minimum, $100,831 of the March 7, 2022 transfers

1. came from Investor B's funds, which was the only deposit in Landes

Prive's.account from March 7, 2022 to March 16, 2022;

c. On June 10, 2022, Investor F (a resident of this District) wired. $500,000 to

the Landes Prive checking account, leaving the account with a balance of

approximately $1,175,000. Over the next two months, Lawrence used at

least $428,984 of Investor F's money to pay other investors, on chartered

private flights, to pay commissions to an individual who introduced

Investor F to Lawrence, and/or for hundreds of debit card transactions. By

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August 17, 2022, the balance in the Landes Prive account was down to

$147,290.

d. more recently, on March 23, 2023, Lawrence obtained $100,000 from new

Investor J and immediately spent $91,000 at a luxury car dealership, and

based on Lawrence's bank account balance prior to the $100,000 deposit,

at a minimum, $87,641 of the $91,000 came from Investor J's funds.

44. In total, Lawrence misappropriated at least $4,890,798 from at least 11 investors.

45. Although Lawrence told investors that their funds were secure, in actuality, the

funds were at direct and immediate risk because Lawrence misappropriated almost all of the

investor funds.

46. Lawrence's spending for personal expenses included spending at least $1,260,000

at luxury jeweler Cartier and its parent company, paying at least $522,000 to chartered flight

companies, and withdrawing approximately $159,000 in cash. For example, on June 7, 2022,

Lawrence sent a wire in the amount of$958,204.55 from the Landes Prive account to the parent

company of Cartier. The wire memo for this transaction reads, in its entirety, "KA TE." None of

the investors are named Kate.

47. Lawrence also paid for an additional $1,021,934 of personal expenses using the

Landes Prive debit card. Examples of these personal expenses include:

a. $97,433 to a luxury resort in St. Barthelemy ("St. Barts");

b. $67,519 to the Carlyle luxury hotel in New York City; and

c. $49,177 to Chanel.

48. Lawrence did make some payments to certain investors, but the money he used

was actually funds misappropriated from other investors. These Ponzi-like payments were made

12

to further Lawrence's scheme. For example, on September 27, 2022, Investor D (a resident of

this District) wired $500,000 to the Landes Prive account. The next day, Lawrence wired

$400,000 from the Landes Prive account to Investor B, who had sought the return of his principal

investment after the purported investment period had ended. Based on the beginning balance and

other deposits in the Landes Prive account, Lawrence misappropriated at least $268,146 of the

$500,000 wire from Investor D to pay Investor B. In total, it appears that Lawrence spent

approximately $871,000 on Ponzi-like payments to investors.

49. Additionally, Lawrence transferred more than $689,000 of investor funds to the

Relief Defendants, and received approximately $233,300 back from the Relief Defendants,

resulting in net transfers of approximately $455,700 to the Relief Defendants. Specifically,

Lawrence transferred:

a. $472,700 to a Smith-controlled account in the name of Landes KB, and

Smith paid $175,000 from the Landes KB bank account to the Landes

Prive checking account, for a net transfer to Landes KB of approximately

$298,700;

b. $144,451 to Bisner's personal accounts; and

c. $72,000 to a Bisner-controlled account in the name ofHekYeah, and

Bisner paid $58,200 from the HekYeah bank account to the Lanes Prive

checking account, for a net transfer to HekYeah of approximately

$13,800.

50. As a result, based on records available to the SEC to date, Lawrence

misappropriated all but approximately $10,854 of the currently identified $4.9 million of investor

funds.

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D. Lawrence Lulled Investors and Lied about the Status of the Investments

51. When certain investors asked for a return of their funds, Lawrence lied to them.

For example:

a. On or about June 17, 2022, Lawrence emailed Investor B, stating that the

return of funds had been initiated at the "traders bank" but had been held

up by compliance;

b. In July 2022, Lawrence told Investor B by text message or telephone that

someone in Abu Dhabi wanted their "palms greased" before funding could

be disbursed;

c. Lawrence told Investor E in approximately August 2022, and Investor B in

approximately September 2022, by telephone, that investors needed to

keep their principal in the Landes Prive account or risk missing out on

their purported profits;

d. In approximately October 2022, Lawrence told lpvestor B by telephone

that Landes Prive had an investment committee that had to decide on

whether to disburse funds; and

e. In emails dated February 2, 2023, February 14, 2023, and February 22,

2023, Lawrence gave Investor Ga variety of excuses for the delay in

returning his funds from a supposedly completed investment, including

that the trading platform was "awaiting a delayed settlement of a traded

instrument," that the funds "should [be] released later tomorrow or

Thursday morning," and"[ w ]e are on it."

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52. At least 5 investors are now well beyond the conclusion of their purported trading

program but have not received the return of either their principal or purported profit, other than

the two investors who received Ponzi-like payments. Contrary to the Agreement's representation

that ''there will be no delay in releasing the client's principal after [the end of the investment

period]," no investors have received full repayment of their principal. Nor have_they received the

extraordinary returns Lawrence said they should expect and, in some cases, supposedly obtained

for them.

53. Lawrence's misappropriation, which began in February 2022 and persisted

through at least March 2023, will likely continue barring emergency action by the Court.

54. Furthermore, Lawrence is a significant flight risk. Lawrence has spent hundreds

of thousands of dollars of investor funds on international travel, including chartered flights and

luxurious resorts. If Lawrence learns about any action against him, he may attempt to flee with

the assets purchased with ill-gotten investor funds.

COUNTI

Violations of Section 17(a)(l), (2), and (3) of the Securities Act
(Against Defendant Lawrence)

55. The SEC realleges and incorporates by reference the allegations set forth in

paragraphs 1 through 54 as if fully set forth herein.

56. By engaging in the conduct described in this Complaint, Lawrence, directly or

indirectly, in the offer or sale of securities, by the use of any means or instruments of

transportation or communication in interstate commerce or by use of the mails: (a) employed

devices, schemes and artifices to defraud; (b) obtained money or property by means of untrue

statements of material fact or omissions to state material facts necessary in order to make the

statements made, in light of the circumstances under which they were made, not misleading;

15

and/or (c) engaged in transactions, practices, or courses of business which operated or would

operate as a fraud or deceit upon purchasers or prospective purchasers.

57. Lawrence acted intentionally, with severe recklessness and at least negligently in

the fraudulent conduct described above.

58. By reason of the foregoing, Lawrence violated, and unless enjoined will likely

again violate, Sections 17(a)(l), 17(a)(2), ~d 17(a)(3) of the Securities,Act [15 U.S.C.

§§ 77q(a)(l), 77q(a)(2), and 77q(a)(3)].

COUNT II

Violations of Section lO(b) of the Exchange Act and Rule lOb-5 Thereunder
(Against Defendant Lawrence)

59. The SEC realleges and incorporates by reference the allegations set forth in

paragraphs 1 through 54 as if fully set forth herein.

60. By engaging.in the conduct described in this Complaint, Lawrence, directly or

indirectly, in connection with the purchase or sale of securities, by the use of the means or

instrumentalities of interstate commerce, or of the mails: (a) used and employed devices,

schemes or artifices to defraud; (b) made untrue statements of material fact or omitted to state

material facts necessary in order to make the statements made, in light of the circumstances

under which they were made, not misleading; and/or (c) engaged in acts, practices, or courses of

business which operated or would operate as a fraud and deceit upon purchasers and prospective

purchasers of securities.

61. Lawrence acted with scienter in that he knowingly or with severe recklessness

made the material misrepresentations and omissions and engaged in the fraudulent conduct

and/or scheme described above.

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I

62. By reason of the foregoing, Lawrence violated, and unless enjoined will likely

again violate, Section lO(b) of the Exchange Act [15 U.S.C. §78j(b)] and Rule lOb-5 [17 C.F.R.

240.1 0b-5] thereunder.

COUNT III

(Against All Relief Defendants)

63. The SEC realleges and incorporates by reference the allegations set forth in

paragraphs 1 through 54 as if fully set forth herein.

64. Relief Defendants Landes Prive LLC, Landes and Compagnie Trust Prive aka

Landes and Compagnie Trst Prive KB, HekYeah, LLC, Justin D. Smith, and Brenda M. Bisner
J

received improper and illegal transfers of investor money from Lawrence, even though they had

no right to receive any investor funds.

65. By reason of the foregoing, Landes Prive LLC, Landes and Compagnie Trust

Prive aka Landes and Compagnie Trst Prive KB, HekYeah, LLC, Justin D. Smith, and Brenda

M. Bisner have been unjustly enriched and may be compelled to return any investor funds they

still hold, and may be held liable for all of the transfers of investor funds they received.

RELIEF REQUESTED

WHEREFORE, the SEC respectfully requests that this Court:

I.

Issue :findings of fact and conclusions oflaw that Defendant Charles T. Lawrence, Jr.

committed the violations alleged herein.

II.

Issue an Order of Permanent Injunction restraining and enjoining Defendant Charles T.

Lawrence, Jr., and his officers, agents, servants, employees, attorneys, and those persons in

active concert or participation with him who receive actual notice of the injunction, by personal

17

service or otherwise, and each of them from, violating Section 17(a) of the Securities Act [15

U.S.C. § 77q(a)] and Section lO(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule lOb-5 [17

CPR § 240.1 0b-5] thereunder.

III.

Grant other appropriate injunctive emergency interim relief, consistent with Rule 65( d) of

the Federal Rules of Civil Procedure, as well as permanent injunctive relief, to protect investors,

including: (i) a Temporary Restraining Order and Order of Preliminary Injunction against

Defendant Charles T. Lawrence, Jr. restraining and enjoining him as set forth in this Section and

Section II of the Relief Requested; (ii) an Order restraining and enjoining Defendant Charles T.

Lawrence, Jr. and his officers, agents, servants, employees, attorneys, subsidiaries and affiliates,

and those persons in active concert or participation with him who receive actual notice of the

injunction, by personal service and otherwise, and each of them, from directly or indirectly

soliciting, accepting, or depositing any monies obtained from actual or prospective investors

pending resolution of this action; (iii) an Order freezing the assets of Defendant Charles T.

Lawrence, Jr. and the Relief Defendants and providing for other ancillary relief necessary to

effectuate the preservation and recovery of their assets; (iv) an accounting by Defendant Charles

T. Lawrence, Jr.; (v) an order prohibiting the destruction, mutilation, concealment, alteration, or

disposition of books and records; and (vi) other ancillary relief, including expedited discovery

and surrender to the Clerk of Court of Defendant Charles T. Lawrence Jr.'s passport(s).

IV.

Order Defendant Charles T. Lawrence, Jr. to disgorge his ill-gotten gains received as a

result of the violatiqns alleged in this Complaint, together with prejudgment interest thereon,

pursuant to Section 21(d)(3), 21(d)(5), and 21(d)(7) of the Exchange Act [15 U.S.C.

18

§§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)] and order the Relief Defendants to disgorge the amounts

by which they were unjustly enriched, together with prejudgment interest thereon.

V.

Order Defendant Charles T. Lawrence, Jr. to pay a civil monetary penalty pursuant to

Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange

Act [15 U.S.C. § 78u(d)(3)].

VI.

Issue an Order,.pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and

Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] permanently prohibiting

Defendant Charles T. Lawrence, Jr. from acting as an officer or director of any issuer that has a

class of securities registered pursuant to Section 12 of the Exchange Act [ 15 U.S. C. § 781)] or

that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C.

§ 78o(d)].

VII.

Retain jurisdiction of this action in accordance with the principles of equity and the

Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and

decrees that may be entered, or to entertain any suitable application or motion for additional·

relief within the jurisdiction of this Court.

VIII.

Grant such other and further relief as this Court deems to be just and necessary.

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..

JURY DEMAND

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff SEC hereby

requests a trial by jury on all claims so triable.

Respectfully submitted,

UNITED ST A TES SECURITIES AND
EXCHANGE COMMISSION

By: ~
Daniel J. Hayes ([email protected])
BeLinda I. Mathie ([email protected])
Amy S. Cotter ( [email protected])
Matthew T.Wissa([email protected])
U.S. Securities and Exchange Commission
Chicago Regional Office
175 West Jackson Blvd., Suite 1450
Chicago, Illinois 60604
Telephone: (312) 353-7390
Attorneys for Plaintiff

20

UNITED ST A TES DISTRICT COURT 
EASTERN DISTRICT OF WISCONSIN 

MILWAUKEE DIVISION 

·-, ----~ ,- .-~- ,--
,.;,'\ 

UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION, 

Plaintiff, 

V. 

CHARLES T. LA WREN CE, JR. , 

Case No. 

-
... ,.,. .... . ·- . 

23-C-055 0 
--------

JURY TRIAL DEMANDED 
CASE FILED UNDER SEAL 

Defendant, 

and 

LANDES PRIVE, LLC, LANDES AND 
COMP AGNIE TRUST PRIVE aka LANDES 
AND COMP AGNIE TRST PRIVE KB, 
HEKYEAH, LLC, JUSTIN D. SMITH, and 
BRENDA M. BISNER, 

Relief Defendants. 

CASE FILED UNDER SEAL 

COMPLAINT 

Plaintiff United States Securities and Exchange Commission ("SEC") alleges as follows: 

NATURE OF THE CASE 

1. From at least February 2022 through the present, Defendant Charles T. Lawrence, 

Jr. ("Lawrence") engaged in a fraudulent scheme involving Landes and Compagnie Trust Prive 

KB ("Swedish Landes KB"), a purported Swedish financial services company with United 

States-based subsidiaries. Lawrence represented to investors that he was the Managing Director 

of Swedish Landes KB. 

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2. Lawrence raised approximately $4.9 million through the fraudulent offer and sale 

of investment contracts to at least 11 investors, 7 of whom reside in 6 states in the United States 

and 4 of whom reside abroad. At least 2 of the 7 United States-based investors reside in this 

District. At least 5 of the 11 investors signed a contract called "Agreement for Financial and 

Trade Services" (the "Agreement") with Swedish Landes KB, with Lawrence signing as the 

entity's Managing Director. 

3. Lawrence told prospective investors that the investment contracts he offered were 

expected to provide weekly returns of 25% to 100% during the investment period, which he said 

would last between 8 and 20 weeks. Lawrence also told prospective investors that their invested 

funds would be "blocked" during the trading period and not be at risk. Lawrence further claimed 

that investor funds would be placed in unique Swedish Landes KB non-depletion accounts and 

would be visible to the investor for the duration of the investment. 

4. Lawrence made additional oral representations to prospective investors. For 

example, he said that he intended to use investor funds to obtain a standby letter of credit or 

other collateral to facilitate Lawrence's trading in securities and other assets on behalf of the 

investors. He also told prospective investors that the returns on the investment would be shared 

pro rata among investors. 

5. After they agreed to invest, Lawrence instructed investors to wire funds to a 

United States-based bank account at Financial Institution 1 in the name of Relief Defendant 

Land,es Prive, LLC ("Landes Prive"), over which Lawrence had sole control. Contrary to 

Lawrence's representations about the safety and use of investor funds, from at least February 

2022 to the present, Lawrence diverted and misappropriated at least $4.89 million of the $4.9 

million raised from 11 investors. Lawrence regularly misappropriated investor funds shortly after 

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the investors sent their funds to the Landes Prive bank account. He never used investor money to 

procure a standby letter of credit or other collateral to facilitate securities trades or otherwise 

invest on behalf of the investors. 

6. Instead, Lawrence spent investor funds on personal expenses, including at least 

$1.7 million at high-end jewelers and on chartered flight companies. Lawrence also_.spent 

investor funds by using the Landes Prive debit card to make thousands of purchases totaling 

more than $1 million. He used investor money to compensate individuals who connected 

Lawrence with the investors, to pay early investors in furtherance of the scheme, and to pay other 

entities and individuals affiliated with Lawrence. Those individuals and entities include Relief 

Defendants Justin D. Smith ("Smith"), Smith's entity Landes and Compagnie Trust Prive aka 

Landes & Compagnie Trst [sic] Prive KB ("Landes Trust KB"), Brenda M. Bisner ("Bisner"), 

and Bisner' s entity HekY eah, LLC ("HekY eah") ( collectively with Landes Privf, "Relief 

Defendants"). 

7. To convince investors that their investments were profitable and safe, Lawrence 

sent weekly emails falsely reporting investors' purported weekly returns. Lawrence also 

provided investors with access to an online portal that he claimed showed investors that their 

money was secure in the agreed-upon non-depletion accounts. To lull investors who had 

requested a return of their purported profits or capital investment, Lawrence fabricated various 

reasons for months-long delays in returning the funds. 

8. At least 5 of the 11 investors have not received a return of their principal or any 

supposed investment profits despite weeks or months having passed after the conclusion of the 

purported trading programs in which they invested. Two investors have received some payments 

that Lawrence claimed represented a return of their principal investment, but these payments 

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were funded at least in part by deposits from later investors in the scheme. 

9. Lawrence's fraudulent investment scheme is ongoing. As recently as March 23, 

2023, Lawrence obtained $100,000 from a new investor. On that same day, Lawrence spent 

approximately $91,000 at a luxury vehicle dealership in Connecticut. At a minimum, $87,641 of 

the $91,000 came from the new investor's funds. 

10. . Lawrence knowingly and/or recklessly made representations and omissions of 

material fact regarding the investments at issue. Lawrence's conduct involved fraud and deceit 

and resulted in substantial investor losses. 

11. Accordingly, Lawrence violated the federal securities laws, including Section 

17(a) of the Securities Act of 1933 ("Securities Act") and Section lO(b) of the Securities 

Exchange Act of 1934 ("Exchange Act") and Rule 1 0b-5 thereunder. 

12. The SEC brings this action and seeks relief on an emergency basis to secure and 

preserve whatever investor funds and other collectible assets remain, to prevent future unjust 

enrichment of Lawrence and the Relief Defendants, and to hold Lawrence liable for his 

violations of the federal securities laws. 

13. The SEC seeks expedited reliefincluding, among other things, (a) temporary and 

preliminary injunctive relief and (b) the entry of an asset freeze to secure and preserve investor 

funds, as well as related ancillary relief. 

14. Ultimately, Lawrence should be permanently enjoined from future violations of 

the anti-fraud provisions of the Securities Act and the Exchange Act. Lawrence and the Relief 

Defendants should be ordered to disgorge all of their ill-gotten gains, with prejudgment interest. 

The Court should also require Lawrence to pay a significant civil penalty, and preclude 

Lawrence from serving as an officer or director of a public company. 

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JURISDICTION AND VENUE 

15. The SEC brings this action pursuant to Sections 20(b) and 20(d) of the Securities 

Act of 1933 [15 U.S.C. §77t(b), (d); §77v(a)], and Section 2l(d) of the Securities Exchange Act 

of 1934 [15 U.S.C. §§78u(d) and 78aa(a)]. 

16. This Court has jurisdiction over this action pursuant to Section 22( a) of the 

Securities Act [15 U.S.C. § 77v(a)], and Section 27(a) of the Exchange Act [15 U.S.C. 

§ 78aa(a)]. 

17. Venue is proper in this District pursuant to Section 22(a) of the Securities Act [15 

U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)]. Acts, practices, 

and courses of business constituting violations alleged herein have occurred within the 

jurisdiction of the United States District Court for the Eastern District of Wisconsin and 

elsewhere. Moreover, at least two victims of Defendant's alleged securities violations reside in 

this District. 

18. Lawrence directly and indirectly made use of the means or instruments of 

transportation or communication in, aµd the means and instruments of, interstate commerce or of 

the mails, in connection with the acts, practices, and courses of business alleged in this 

Complaint. 

19. There is a reasonable likelihood th~t Lawrence will, unless temporarily, 

preliminarily, and permanently enjoined, continu~ to engage in the transactions, acts, practices 

and courses of business set forth in this Complaint, and transactions, acts, practices and courses 

I 

of business of similar purport and object. 

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DEFENDANT 

20. Charles T. Lawrence, Jr., age 49, is currently a resident of Connecticut, but 

resided in both New York, New York, and Dallas, Texas, during the relevant time period. 

Lawrence formerly worked as a trader at several SEC-registered entities, but has not been 

associated with an SEC-registered entity since 2012. 

RELIEF DEFENDANTS 

21. Landes Prive, LLC is a Delaware limited liability company formed in April 

2019 with its principal place of business in New York. Landes Prive is not registered with the 

SEC in any capacity. Lawrence opened the Landes Prive bank account referenced in this 

Complaint in March 2020. Lawrence is the sole signatory of the Landes Prive bank account. 

22. Landes and Compagnie Trust Prive a/k/a Landes and Compagnie Trst [sic] 

Prive KB is a Wyoming entity formed in February 2017 and is in good standing. Smith formed 

Landes KB and controls accounts in the name of Landes KB. Landes KB received ill-gotten 

investor funds from Lawrence. 

23. HekYeah, LLC, is a Delaware limited liability company formed in October 2022 

with its principal place of business in Texas. Bisner controls accounts in the name ofHekYeah, 

and it received ill-gotten investor funds from Lawrence. 

24. Justin D. Smith, age 42, is a resident of Ohio. Smith has formed several entities 

that include Landes in their names. Smith, as well as certain Landes entities under his control, 

was issued a cease and desist order with a consent agreement on October 1, 2020 by the State of 

Ohio, Department of Commerce, Division of Securities. The order found that Smith acted as a 

securities salesperson and as an investment adviser representative while Landes KB was 

operating as an unlicensed securities dealer and/or investment adviser through its website, 

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~.landestrust.se. Smith, through an account in the name of Landes KB, received investor 

funds from Lawrence. 

25. Brenda M. Bisner, age 42, is a resident of Connecticut. Bisner has resided with 

Lawrence from time to time. Bisner received investor funds from Lawrence. 

RELATED ENTITY 

26. Landes and Compagnie Trust Prive KB was incorporated by Smith in 

Stockholm, Sweden in November 2016. Lawrence represented to investors that Swedish Landes 

KB was a financial services company. As of January 2023, the company was not active and had 

never been active, and had no physical employees in Sweden. Since at least February 2022, 

Swedish Landes KB entered into the Agreements with at least 5 of the 11 investors who sent 

money to the Landes Prive bank account at Financial Institution 1. Lawrence signed the 

I 

Agreements as the Managing Director of Swedish Landes KB. 

FACTS 

A. Lawrence Solicited Investments in Private Placements 

27. Starting in at least February 2022 and continuing through the present, Lawrence 

solicited prospective investors through a fraudulent offering consisting of the offer and sale of 

investment contracts purportedly issued by Swedish Landes KB. Lawrence described the 

investments as "private placement opportunities" where investors, without risk to their principal, 

could earn weekly returns ranging from 25% to 100% on their investments during varying 8 to · 

20 week investment periods. 

28. Investors in these private placement opportunities entered into the Agreements. 

Lawrence signed the Agreements as Swedish Landes KB's Managing Director. Investors thought 

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they were investing with Swedish Landes KB, but that entity was apparently defunct by at least 

February 2022. 

29. In reality, Lawrence controlled the investors' funds because he directed investors 

to deposit their funds into the United States-based bank account of Landes Prive, over which 

Lawrence had sole signature authority. 

30. Since February 2022, Lawrence has raised at least $4,901,652 in investor funds 

from at least 11 investors. Seven of the investors reside in the United States, in six different 

states, with two investors residing in this District. Four ofthe_investors reside abroad. 

31. Lawrence solicited investors through representations made by email and 

telephone calls, and also by using promoters. Lawrence compensated certain promoters with 

investor funds. 

B. Lawrence's False Representations about the Investments 

32. Before they invested, Lawrence had prospective investors sign the Agreement. In 

the Agreement, Lawrence made several false representations. 

( 
33. First, Lawrence represented in the Agreement that investor's funds ''will be in the 

client's Landes account and visible at all times," with at least one investor's Agreement further 

stating that the funds in the account will "be under the sole control of the client at all times." 

However, Lawrence orally represented to prospective investors that he would obtain a standby 

letter of credit or other collateral based on the amount of investor funds he raised. Lawrence 

explained to several investors that the letter of credit or collateral would facilitate his trading in 

securities, with the trading profits flowing pro rata back to investors. 
J . 

34. Next, Lawrence represented in the Agreement that an investor's "principal 

investment will be blocked but not at risk" and further, even "[i]fthe trade is unsuccessful and 

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( 

there are losses, the client's Principal fun~s are never depleted." Lawrence further represented in 

the Agreement that "[i]fthe trade is unsuccessful and there are losses ... there will be no delay in 

releasing the client's principal funds after [length of trading period] weeks." 

35. In addition, the Agreement presents the scope of the investment contract services 

as follows: "Client wishes to place [investment amount] into an acceler~ted trade program. 

Landes responsibilities shall be limited to Custody of initial capital and trade profits; trade 

management and allocation; Liaison between trade platform and client; maintenance and 

I 

settlement of all securities and cash funds; establishing a brokerage account on behalf of the 

client." 

36. Lastly, the Agreement did not contain a representation that any party was entitled 

to compensation or to use investor funds for personal or business expenses. Rather, Lawrence 

orally represented to certain investors that Lawrence and/or Swedish Landes KB would ·be 

compensated from the trading profits prior to investors receiving their return on investment. 

3 7. During the sam~ period, Lawrence also made a variety of additional false oral 

representations to investors about how his trading would make a profit. For example, on or about 

March 1, 2022, Lawrence claimed on a telephone call to at least one prospective investor­

Investor B-that he was the brains behind an investment opportunity with, and had access to, the 

Abu Dhabi Investment Authority. He further claimed that this connection explained how he 

would be able to generate investment profits without risk to the investor's principal investment. 

On or about April 20, 2022, Lawrence told another prospective investor-Investor E-by 

telephone that the Swedish Landes KB platform allowed Lawrence to trade in futures, hedge 

funds, and crypto currency. 

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38. Lawrence maintained the scheme by providing investors with a Landes login that 

purported to show their initial investment placed in a non-depletion account as promised. For 

example, on August 1 7, 2022, Lawrence caused an email to be sent from the email address 

[email protected] to Investor G containing a username and password. 

39. Investors who logged into the portal saw a webpage that purported to show their 

unique account number, current balance, account type, account status ( e.g., "Active"), the 

currency in which the account was denominated ( e.g., "USD"), and recent debits -and credits to 

the account. 

40. Lawrence also sent investors weekly emails showing a fictitious weekly return on 

inves~ent. For example, on or about March 19, 2022, Lawrence sent Investor Ban email 

stating: "Trading this week was successful and we managed a return of 118%." On or about 

March 26, 2022, Lawrence sent Investor B another email claiming that the investment had 

resulted in an 83% return that week. In reality, Lawrence began to misappropriate Investor B's 

funds the same day they were deposited. 

C. Lawrence Engaged in a Scheme to Misappropriate Investor Funds 

41. The statements and other representations Lawrence made to investors, as set forth 

above in paragraphs 32-40, were false. After investors sent their funds to the same Landes Prive . 

bank account, the funds were never allocated to a unique Swedish Landes KB account, used to 

obtain a standby letter of credit or other collateral, used to trade securities, or otherwise used to 

make investments. 

42. Instead, the investor funds sat commingled in Lawrence's Landes Prive bank 

account, and Lawrence used the money for a variety of impr?per purposes, including payments 

for: personal expenses, to individuals who promoted the investments, to early investors, and to 

the Relief Defendants, among others. 

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43. Lawrence's misappropriation began almost immediately in February 2022 and has 

continued since. For example: 

a. on February 16, 2022, Investor H sent three wires totaling approximately 

$250,000 to the Landes Prive bank account. Shortly before the investment, 

the Landes Prive bank account was overdrawn and had a balance of 

negative $558.96. In the two days following receipt of the $250,000 

investment, Lawrence spent over $40,000 at Cartier, wired more than 

$27,000 to Bisner, wired $93,000 to a Landes Trust KB account in the 

control of Smith, and wired an apparent promoter $25,000 with a memo 

line including "commission";· 

b. on March 7, 2022, Investor B wired approximately $536,500 to Landes 

Prive. That same day, among other uses, Lawrence sent $53,650 to the 

person who had introduced Investor B to Lawrence with the description 

"[Investor B] Commission," sent $25,000 to Bisner, and withdrew 
/ 

$35,600 in cash. At a minimum, $100,831 of the March 7, 2022 transfers 

1. came from Investor B's funds, which was the only deposit in Landes 

Prive's.account from March 7, 2022 to March 16, 2022; 

c. On June 10, 2022, Investor F (a resident of this District) wired. $500,000 to 

the Landes Prive checking account, leaving the account with a balance of 

approximately $1,175,000. Over the next two months, Lawrence used at 

least $428,984 of Investor F's money to pay other investors, on chartered 

private flights, to pay commissions to an individual who introduced 

Investor F to Lawrence, and/or for hundreds of debit card transactions. By 

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August 17, 2022, the balance in the Landes Prive account was down to 

$147,290. 

d. more recently, on March 23, 2023, Lawrence obtained $100,000 from new 

Investor J and immediately spent $91,000 at a luxury car dealership, and 

based on Lawrence's bank account balance prior to the $100,000 deposit, 

at a minimum, $87,641 of the $91,000 came from Investor J's funds. 

44. In total, Lawrence misappropriated at least $4,890,798 from at least 11 investors. 

45. Although Lawrence told investors that their funds were secure, in actuality, the 

funds were at direct and immediate risk because Lawrence misappropriated almost all of the 

investor funds. 

46. Lawrence's spending for personal expenses included spending at least $1,260,000 

at luxury jeweler Cartier and its parent company, paying at least $522,000 to chartered flight 

companies, and withdrawing approximately $159,000 in cash. For example, on June 7, 2022, 

Lawrence sent a wire in the amount of$958,204.55 from the Landes Prive account to the parent 

company of Cartier. The wire memo for this transaction reads, in its entirety, "KA TE." None of 

the investors are named Kate. 

47. Lawrence also paid for an additional $1,021,934 of personal expenses using the 

Landes Prive debit card. Examples of these personal expenses include: 

a. $97,433 to a luxury resort in St. Barthelemy ("St. Barts"); 

b. $67,519 to the Carlyle luxury hotel in New York City; and 

c. $49,177 to Chanel. 

48. Lawrence did make some payments to certain investors, but the money he used 

was actually funds misappropriated from other investors. These Ponzi-like payments were made 

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to further Lawrence's scheme. For example, on September 27, 2022, Investor D (a resident of 

this District) wired $500,000 to the Landes Prive account. The next day, Lawrence wired 

$400,000 from the Landes Prive account to Investor B, who had sought the return of his principal 

investment after the purported investment period had ended. Based on the beginning balance and 

other deposits in the Landes Prive account, Lawrence misappropriated at least $268,146 of the 

$500,000 wire from Investor D to pay Investor B. In total, it appears that Lawrence spent 

approximately $871,000 on Ponzi-like payments to investors. 

49. Additionally, Lawrence transferred more than $689,000 of investor funds to the 

Relief Defendants, and received approximately $233,300 back from the Relief Defendants, 

resulting in net transfers of approximately $455,700 to the Relief Defendants. Specifically, 

Lawrence transferred: 

a. $472,700 to a Smith-controlled account in the name of Landes KB, and 

Smith paid $175,000 from the Landes KB bank account to the Landes 

Prive checking account, for a net transfer to Landes KB of approximately 

$298,700; 

b. $144,451 to Bisner's personal accounts; and 

c. $72,000 to a Bisner-controlled account in the name ofHekYeah, and 

Bisner paid $58,200 from the HekYeah bank account to the Lanes Prive 

checking account, for a net transfer to HekYeah of approximately 

$13,800. 

50. As a result, based on records available to the SEC to date, Lawrence 

misappropriated all but approximately $10,854 of the currently identified $4.9 million of investor 

funds. 

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D. Lawrence Lulled Investors and Lied about the Status of the Investments 

51. When certain investors asked for a return of their funds, Lawrence lied to them. 

For example: 

a. On or about June 17, 2022, Lawrence emailed Investor B, stating that the 

return of funds had been initiated at the "traders bank" but had been held 

up by compliance; 

b. In July 2022, Lawrence told Investor B by text message or telephone that 

someone in Abu Dhabi wanted their "palms greased" before funding could 

be disbursed; 

c. Lawrence told Investor E in approximately August 2022, and Investor B in 

approximately September 2022, by telephone, that investors needed to 

keep their principal in the Landes Prive account or risk missing out on 

their purported profits; 

d. In approximately October 2022, Lawrence told lpvestor B by telephone 

that Landes Prive had an investment committee that had to decide on 

whether to disburse funds; and 

e. In emails dated February 2, 2023, February 14, 2023, and February 22, 

2023, Lawrence gave Investor Ga variety of excuses for the delay in 

returning his funds from a supposedly completed investment, including 

that the trading platform was "awaiting a delayed settlement of a traded 

instrument," that the funds "should [be] released later tomorrow or 

Thursday morning," and"[ w ]e are on it." 

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52. At least 5 investors are now well beyond the conclusion of their purported trading 

program but have not received the return of either their principal or purported profit, other than 

the two investors who received Ponzi-like payments. Contrary to the Agreement's representation 

that ''there will be no delay in releasing the client's principal after [the end of the investment 

period]," no investors have received full repayment of their principal. Nor have_they received the 

extraordinary returns Lawrence said they should expect and, in some cases, supposedly obtained 

for them. 

53. Lawrence's misappropriation, which began in February 2022 and persisted 

through at least March 2023, will likely continue barring emergency action by the Court. 

54. Furthermore, Lawrence is a significant flight risk. Lawrence has spent hundreds 

of thousands of dollars of investor funds on international travel, including chartered flights and 

luxurious resorts. If Lawrence learns about any action against him, he may attempt to flee with 

the assets purchased with ill-gotten investor funds. 

COUNTI 

Violations of Section 17(a)(l), (2), and (3) of the Securities Act 
(Against Defendant Lawrence) 

55. The SEC realleges and incorporates by reference the allegations set forth in 

paragraphs 1 through 54 as if fully set forth herein. 

56. By engaging in the conduct described in this Complaint, Lawrence, directly or 

indirectly, in the offer or sale of securities, by the use of any means or instruments of 

transportation or communication in interstate commerce or by use of the mails: (a) employed 

devices, schemes and artifices to defraud; (b) obtained money or property by means of untrue 

statements of material fact or omissions to state material facts necessary in order to make the 

statements made, in light of the circumstances under which they were made, not misleading; 

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and/or (c) engaged in transactions, practices, or courses of business which operated or would 

operate as a fraud or deceit upon purchasers or prospective purchasers. 

57. Lawrence acted intentionally, with severe recklessness and at least negligently in 

the fraudulent conduct described above. 

58. By reason of the foregoing, Lawrence violated, and unless enjoined will likely 

again violate, Sections 17(a)(l), 17(a)(2), ~d 17(a)(3) of the Securities,Act [15 U.S.C. 

§§ 77q(a)(l), 77q(a)(2), and 77q(a)(3)]. 

COUNT II 

Violations of Section lO(b) of the Exchange Act and Rule lOb-5 Thereunder 
(Against Defendant Lawrence) 

59. The SEC realleges and incorporates by reference the allegations set forth in 

paragraphs 1 through 54 as if fully set forth herein. 

60. By engaging.in the conduct described in this Complaint, Lawrence, directly or 

indirectly, in connection with the purchase or sale of securities, by the use of the means or 

instrumentalities of interstate commerce, or of the mails: (a) used and employed devices, 

schemes or artifices to defraud; (b) made untrue statements of material fact or omitted to state 

material facts necessary in order to make the statements made, in light of the circumstances 

under which they were made, not misleading; and/or (c) engaged in acts, practices, or courses of 

business which operated or would operate as a fraud and deceit upon purchasers and prospective 

purchasers of securities. 

61. Lawrence acted with scienter in that he knowingly or with severe recklessness 

made the material misrepresentations and omissions and engaged in the fraudulent conduct 

and/or scheme described above. 

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I 

62. By reason of the foregoing, Lawrence violated, and unless enjoined will likely 

again violate, Section lO(b) of the Exchange Act [15 U.S.C. §78j(b)] and Rule lOb-5 [17 C.F.R. 

240.1 0b-5] thereunder. 

COUNT III 

(Against All Relief Defendants) 

63. The SEC realleges and incorporates by reference the allegations set forth in 

paragraphs 1 through 54 as if fully set forth herein. 

64. Relief Defendants Landes Prive LLC, Landes and Compagnie Trust Prive aka 

Landes and Compagnie Trst Prive KB, HekYeah, LLC, Justin D. Smith, and Brenda M. Bisner 
J 

received improper and illegal transfers of investor money from Lawrence, even though they had 

no right to receive any investor funds. 

65. By reason of the foregoing, Landes Prive LLC, Landes and Compagnie Trust 

Prive aka Landes and Compagnie Trst Prive KB, HekYeah, LLC, Justin D. Smith, and Brenda 

M. Bisner have been unjustly enriched and may be compelled to return any investor funds they 

still hold, and may be held liable for all of the transfers of investor funds they received. 

RELIEF REQUESTED 

WHEREFORE, the SEC respectfully requests that this Court: 

I. 

Issue :findings of fact and conclusions oflaw that Defendant Charles T. Lawrence, Jr. 

committed the violations alleged herein. 

II. 

Issue an Order of Permanent Injunction restraining and enjoining Defendant Charles T. 

Lawrence, Jr., and his officers, agents, servants, employees, attorneys, and those persons in 

active concert or participation with him who receive actual notice of the injunction, by personal 

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service or otherwise, and each of them from, violating Section 17(a) of the Securities Act [15 

U.S.C. § 77q(a)] and Section lO(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule lOb-5 [17 

CPR § 240.1 0b-5] thereunder. 

III. 

Grant other appropriate injunctive emergency interim relief, consistent with Rule 65( d) of 

the Federal Rules of Civil Procedure, as well as permanent injunctive relief, to protect investors, 

including: (i) a Temporary Restraining Order and Order of Preliminary Injunction against 

Defendant Charles T. Lawrence, Jr. restraining and enjoining him as set forth in this Section and 

Section II of the Relief Requested; (ii) an Order restraining and enjoining Defendant Charles T. 

Lawrence, Jr. and his officers, agents, servants, employees, attorneys, subsidiaries and affiliates, 

and those persons in active concert or participation with him who receive actual notice of the 

injunction, by personal service and otherwise, and each of them, from directly or indirectly 

soliciting, accepting, or depositing any monies obtained from actual or prospective investors 

pending resolution of this action; (iii) an Order freezing the assets of Defendant Charles T. 

Lawrence, Jr. and the Relief Defendants and providing for other ancillary relief necessary to 

effectuate the preservation and recovery of their assets; (iv) an accounting by Defendant Charles 

T. Lawrence, Jr.; (v) an order prohibiting the destruction, mutilation, concealment, alteration, or 

disposition of books and records; and (vi) other ancillary relief, including expedited discovery 

and surrender to the Clerk of Court of Defendant Charles T. Lawrence Jr.'s passport(s). 

IV. 

Order Defendant Charles T. Lawrence, Jr. to disgorge his ill-gotten gains received as a 

result of the violatiqns alleged in this Complaint, together with prejudgment interest thereon, 

pursuant to Section 21(d)(3), 21(d)(5), and 21(d)(7) of the Exchange Act [15 U.S.C. 

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§§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)] and order the Relief Defendants to disgorge the amounts 

by which they were unjustly enriched, together with prejudgment interest thereon. 

V. 

Order Defendant Charles T. Lawrence, Jr. to pay a civil monetary penalty pursuant to 

Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange 

Act [15 U.S.C. § 78u(d)(3)]. 

VI. 

Issue an Order,.pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and 

Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] permanently prohibiting 

Defendant Charles T. Lawrence, Jr. from acting as an officer or director of any issuer that has a 

class of securities registered pursuant to Section 12 of the Exchange Act [ 15 U.S. C. § 781)] or 

that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. 

§ 78o(d)]. 

VII. 

Retain jurisdiction of this action in accordance with the principles of equity and the 

Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and 

decrees that may be entered, or to entertain any suitable application or motion for additional· 

relief within the jurisdiction of this Court. 

VIII. 

Grant such other and further relief as this Court deems to be just and necessary. 

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.. 

JURY DEMAND 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff SEC hereby 

requests a trial by jury on all claims so triable. 

Respectfully submitted, 

UNITED ST A TES SECURITIES AND 
EXCHANGE COMMISSION 

By: ~ 
Daniel J. Hayes ([email protected]) 
BeLinda I. Mathie ([email protected]) 
Amy S. Cotter ( [email protected]) 
Matthew T.Wissa([email protected]) 
U.S. Securities and Exchange Commission 
Chicago Regional Office 
175 West Jackson Blvd., Suite 1450 
Chicago, Illinois 60604 
Telephone: (312) 353-7390 
Attorneys for Plaintiff 

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