2026-02-04 sec-litreleases complaint 188 KB 18,847 chars

SEC v. Ejiro Ode Okuma, No. 1:26-cv-00561-MHC, Northern District of Georgia (Feb. 4, 2026) — Complaint

raw: Securities and Exchange Commission v Ejiro Ode Okuma

Securities and Exchange Commission v Ejiro Ode Okuma, No. 1:26-cv-00561-MHC (Feb. 4, 2026)

Caption
Securities and Exchange Commission v. Ejiro Ode Okuma

Enriched metadata

Scheme
investment-adviser-fraud (97%)
Court
Northern District of Georgia
Case No.
1:26-cv-00561-MHC
Victim loss
$10,600,000
Entity
Ejiro Ode Okuma
Classified investment-adviser-fraud(confidence 97%). EDGAR detection: forms ADV/ADV-E/ADV-W/Form D· recall 33% / precision 13%. detection rule →
Statutes
15 U.S.C. § 77a(a)15 U.S.C. § 78j(b)15 U.S.C. § 80b-615 U.S.C. § 77v15 U.S.C. § 80b-1428 U.S.C. § 133115 U.S.C. § 78aa28 U.S.C. § 139115 U.S.C. § 77q(a)15 U.S.C. § 80b-6(1)15 U.S.C. § 80b-6(2)15 U.S.C. § 80b15 U.S.C. § 77t(d)15 U.S.C. § 78u(d)15 U.S.C. § 80b-9(e)17 C.F.R. § 240.10b-5Section 17(a)(1) of the Securities ActSection 17(a)(1) of the Securities ActSection 10(b) of the Securities Exchange ActSections 206(1) and 206(2) of the Investment Advisers ActSections 206(1) and 206(2) of the Investment Advisers ActSections 20 and 22 of the Securities ActSections 20 and 22 of the Securities ActSection 22(a) of the Securities ActSection 20(d) of the Securities ActRule 10b-5
Parties
Securities and Exchange CommissionEjiro Ode Okuma
Keywords
okumaclientaccountsecuritiesdocument pageinvestment adviserfundsexchangesecurities exchangebrokerage accountcv-mhcdocumentpageinvestment

Extracted insights

Dollar amounts 14
  • $10.60M $10.6 million $10M–$100M
  • $10.00M $10 million $10M–$100M
  • $9.80M $9.8 million $1M–$10M
  • $9.00M $9 million $1M–$10M
  • $8.94M $8.94 million $1M–$10M
  • $6.74M $6,743,000 $1M–$10M
  • $2.50M $2.5 million $1M–$10M
  • $1.40M $1.4 million $1M–$10M
  • $900K $900,000 $100K–$1M
  • $800K $800,000 $100K–$1M
  • $517K $517,000 $100K–$1M
  • $500K $500,000 $100K–$1M
Entities 10
  • person civil action
  • person civil penalties
  • person Ejiro Ode Okuma
  • person misappropriated funds
  • company securities
  • organization Securities Act Of 1933
  • agency Securities and Exchange Commission
  • organization Securities and Exchange Commission
  • court united states district court
  • organization United States District Court
Triples 10
  • Ejiro Ode Okuma misappropriated $9.8 million
  • Ejiro Ode Okuma stole $900,000
  • Ejiro Ode Okuma transferred securities
  • Ejiro Ode Okuma used misappropriated funds
  • Ejiro Ode Okuma violated Securities Act of 1933
  • Ejiro Ode Okuma violated Securities Exchange Act of 1934
  • Ejiro Ode Okuma violated Investment Advisers Act of 1940
  • Securities And Exchange Commission brings civil action
  • Securities And Exchange Commission seeks civil penalties
  • United States District Court has jurisdiction action
Text layers
Extracted body text (18,847c)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA

(ATLANTA DIVISION)

UNITED STATES SECURITIES
AND EXCHANGE COMMISSION,

               Plaintiff,

               v. Civil Action No. 1:26-cv-_____

EJIRO ODE OKUMA,

              Defendant.

COMPLAINT

 Plaintiff United States Securities and Exchange Commission (“SEC” or

“Commission”) alleges as follows:

NATURE OF ACTION

1. Between March 2022 and March 2025, Defendant Ejiro Ode Okuma,

a Georgia-based investment adviser, misappropriated more than $9.8 million from

an elderly client.

2. Okuma began his fraudulent scheme in 2022 by stealing

approximately $900,000 from the client, who relied almost exclusively on Okuma

for financial matters, and the estate of the client’s recently deceased sister.

3. In 2023, Okuma began transferring securities from various brokerage

accounts held by the client that Okuma managed to a new and unauthorized

2

brokerage account. Okuma had created the new account purportedly for the benefit

of a trust in the client’s name.  In reality, Okuma sold securities held in the account

and used most of the sales proceeds to support his own expensive lifestyle.

4. At around the same time that Okuma opened the unauthorized

brokerage account, he obtained signatory authority on the client’s primary bank

account.  Using his access to and control over the brokerage and bank accounts,

Okuma ultimately misappropriated an additional $8.94 million from the client.

5. Okuma facilitated the fraud by, among other means, electronically

impersonating the client to access the brokerage account, forging the client’s

signature on checks, and transferring funds from the client’s accounts to Okuma’s

own bank account and other accounts over which he had control.

6. Okuma used the misappropriated funds for his own benefit, including

to build a multi-million-dollar residence, purchase vehicles, and buy vacation

homes.

7. By engaging in the conduct alleged in this Complaint, Defendant

violated Section 17(a)(1) of the Securities Act of 1933 (“Securities Act”) [15

U.S.C. § 77a(a)]; Section 10(b) of the Securities Exchange Act of 1934

(“Exchange Act”) and Rules 10b-5(a) and (c) thereunder [15 U.S.C. § 78j(b) and

17 C.F.R. § 240.10b-5]; and Sections 206(1) and 206(2) of the Investment

Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6].

3

JURISDICTION AND VENUE

8. The Commission brings this action pursuant to Sections 20 and 22 of

the Securities Act [15 U.S.C. §§ 77t and 77v], Sections 21(d) and 21(e) of the

Exchange Act [15 U.S.C. §§ 78u(d) and 78u(e)], and Sections 209 and 214 of the

Advisers Act [15 U.S.C. §§ 80b-9 and 80b-14] to enjoin Defendant from engaging in

the transactions, acts, practices, and courses of business alleged in this complaint, and

transactions, acts, practices, and courses of business of similar purport and object, for

civil penalties, disgorgement plus prejudgment interest, and for other equitable relief.

9. This Court has jurisdiction over this action pursuant to Section 22 of the

Securities Act [15 U.S.C. § 77v], Sections 21(d), 21(e), and 27 of the Exchange Act

[15 U.S.C. §§ 78u(d), 78u(e), and 78aa], Section 214 of the Advisers Act [15 U.S.C.

§ 80b-14], and 28 U.S.C. § 1331.

10. Venue is proper in this Court pursuant to Section 22(a) of the Securities

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

Section 214 of the Advisers Act [15 U.S.C. § 80b-14], and 28 U.S.C. § 1391.

11. Defendant, directly and indirectly, made use of the mails, and the means

and instrumentalities of interstate commerce in connection with the transactions, acts,

practices, and courses of business alleged in this complaint.

12. Certain of the transactions, acts, practices, and courses of business

constituting violations of the Securities Act, the Exchange Act, and the Advisers Act

4

occurred within the jurisdiction of the United States District Court for the Northern

District of Georgia.  Specifically, Defendant engaged in fraudulent conduct in this

judicial district; he misappropriated investor funds in this judicial district; and the

defrauded client resides in this judicial district.  In addition, Defendant resides in this

judicial district as well.

13. Defendant, unless restrained and enjoined by this Court, will continue to

engage in the transactions, acts, practices, and courses of business alleged in this

complaint, and in transactions, acts, practices, and courses of business of similar

purport and object.

DEFENDANT

14. Ejiro Ode Okuma, age 43, is a resident of Smyrna, Georgia.  From

2010 until May 4, 2023, Okuma was a registered representative and investment

adviser representative with a firm that is registered with the Commission as a

broker-dealer and investment adviser.  From May 5, 2023 until his resignation in

June 2025, Okuma was a registered representative and investment adviser

representative of another firm that is also registered with the Commission as a

broker-dealer and investment adviser.  Okuma holds Series 7, 63, 65, and 66

securities licenses.

15. Okuma asserted his Fifth Amendment right against self-incrimination

in response to questions regarding his use of client funds.

5

OTHER RELEVANT ENTITIES AND INDIVIDUALS

16. Advisory Client (“Client”) is an 81-year-old man who resides in this

judicial district.  Client relied almost exclusively on Okuma for financial matters.

Client was an advisory client and brokerage customer of Okuma.

STATEMENT OF FACTS

A. Background

17. In 2016, Okuma began providing financial services to Client.  At that

time, Okuma was associated with a firm as an investment adviser representative

and registered representative.  The firm was registered with the Commission as a

broker-dealer and investment adviser.

18. Okuma also provided financial services to certain trusts that Client

had established to hold assets for his benefit.

19. Over time, Client, who has certain health issues, grew increasingly

reliant on Okuma to manage all aspects of his finances, including by facilitating

payments of bills and other expenses, arranging for a caretaker, purchasing

groceries and other household items, and even handling his mail.

20. In August 2021, Client’s sister and only living relative passed away

intestate.  Client was the sole heir of her estate (the “Estate”) and requested the

probate court appoint Okuma as administrator of the Estate.  The court finalized

Okuma’s appointment in February 2022.

6

21. At that time, Client’s assets, including those held by trusts established

for his benefit, exceeded $10 million in the form of mutual funds, equities, bonds,

and annuities.

B. Okuma Begins Misappropriating Client’s Funds

22. In March 2022, Okuma, through his access to and control over

Client’s brokerage accounts, sold more than $517,000 in securities and transferred

$500,000 of the proceeds to Client’s bank account.

23. Okuma then instructed Client to write a $500,000 check in favor of

the Estate.  As the Estate administrator, Okuma deposited the check in an Estate

account and then transferred all $500,000 to an account that he controlled that was

held by an entity affiliated with one of Okuma’s family members (“Affiliated

Account”).

24. In June 2022, Okuma transferred an additional $100,000 of Client’s

funds from a brokerage account to Client’s bank account.

25. After depositing the funds, Okuma transferred the money, along with

the bulk of the Estate’s other funds, to the Affiliated Account using a $400,000

check.

7

C. Okuma Continues Misappropriating Client’s Funds

26. Okuma continued to misappropriate Client’s funds in 2023.

27. In February 2023, Okuma, using information obtained as Client’s

investment adviser, opened an account at a broker-dealer for one of Client’s trusts.

28. Okuma funded the brokerage account by transferring more than

$9 million in securities held in Client’s other accounts, effectively leaving those

accounts empty.

29. While establishing the new brokerage account, Okuma took several

steps to conceal his continued misappropriation from Client.

30. For example, Okuma: (i) authorized the use of check writing from the

account; (ii) set up the log-in credentials for the account so that he could access

and control the account; and (iii) created an e-mail account to electronically

impersonate Client and used the e-mail account as part of the account opening

process.

31. Okuma took these steps without the knowledge or consent of Client,

who did not understand that the new brokerage account was being established.

32. In addition, Okuma caused Client to add Okuma to Client’s personal

bank account as a joint account holder with right of survivorship.  Okuma then

created his own accounts with the same bank.

8

33. In May 2023, Okuma left the advisory firm at which he had been

working to become an investment adviser representative and registered

representative associated with another firm.  At the new firm, Okuma periodically

reviewed securities portfolios, made securities trading recommendations, and

exercised discretionary authority in client accounts.

34. Okuma told Client that their advisory relationship would continue at

the new firm.  Client also believed that their advisory relationship remained the

same as it had been at the old firm.

35. In fact, however, Okuma did not transfer any of Client’s assets to the

new firm or establish accounts for Client with the new firm.

36. This meant that even though Client was still an advisory client of

Okuma, the new firm did not have a record of Client being a client of the firm or

the ability to monitor and detect Okuma’s conduct with Client’s funds.

37. Beginning in August 2023, Okuma began drafting checks from the

new brokerage account by, it appears, forging Client’s signature.

38. Specifically, between August 2023 and March 2025, Okuma drafted

checks from the account totaling $6,743,000 in favor of the firm associated with

the Affiliated Account and $500,000 in favor of another firm that was owned and

managed by Okuma.

9

39. Additionally, between October 2023 and February 2025, Okuma

transferred nearly $2.5 million from the new brokerage account to Client’s bank

account, and then Okuma transferred the funds to his personal bank accounts.

40. Okuma funded these checks and transfers by selling securities in

Client’s brokerage account.

D. Okuma Uses Misappropriated Funds to Support his Lifestyle

41. In total, Okuma transferred more than $10.6 million from Client’s

accounts to accounts held and/or controlled by Okuma.

42. Okuma used approximately $800,000 of these funds on Client,

including for the purchase of a new home for Client.

43. Okuma misappropriated the remaining funds, totaling approximately

$9.8 million, for himself.

44. Okuma spent the bulk of the misappropriated funds—more than $5.6

million—toward the purchase of real property located at

, and the design and partial construction of a multi-million-

dollar home on the property.

45. Okuma used the rest of Client’s money to fund his family’s lifestyle,

including purchasing luxury cars, making a downpayment on a $1.4 million beach

house, and acquiring a fractional share of a second vacation home.

46. After learning of the SEC’s investigation, Okuma returned some funds

10

to Client.  At this time, Okuma still owes client approximately $9 million.

COUNT I – FRAUD

Violations of Section 17(a)(1) of the Securities Act
[15 U.S.C. § 77q(a)(1)]
(Against Okuma)

47. Paragraphs 1 through 46 are realleged and incorporated herein by

reference.

48. Defendant, acting with scienter, in the offer or sale of securities and by

the use of means or instruments of transportation or communication in interstate

commerce or by the use of the mails, directly or indirectly, employed a device,

scheme, or artifice to defraud.

49. By reason of the foregoing, Defendant, directly and indirectly, has

violated and, unless enjoined, will continue to violate Section 17(a)(1) of the

Securities Act [15 U.S.C. § 77q(a)(1)].

COUNT II – FRAUD

Violations of Section 10(b) of the Exchange Act
and Rules 10b-5(a) and (c) thereunder

[15 U.S.C. § 78j(b)(5), 17 C.F.R. § 240.10b-5]
(Against Okuma)

50. Paragraphs 1 through 46 are realleged and incorporated by reference

herein.

51. Defendant, acting with scienter and in connection with the purchase or

sale of securities and by the use of any means or instrumentality of interstate

11

commerce or by use of the mails or any facility of any national securities exchange,

directly or indirectly (i) employed a device, scheme, and artifice to defraud, and

(ii) engaged in acts, practices, or a course of business which operated or would have

operated as a fraud or deceit upon sellers, purchasers, or prospective purchasers of

securities.

52. By engaging in the conduct described above, Defendant violated, and

unless enjoined will continue to violate, Section 10(b) of the Exchange Act and Rules

10b-5(a) and (c) thereunder [15 U.S.C. § 78j(b)(5), 17 C.F.R. § 240.10b-5].

COUNT III – FRAUD

Violations of Section 206(1) of the Advisers Act
[15 U.S.C. § 80b-6(1)]

(Against Okuma)

53. Paragraphs 1 through 46 are realleged and incorporated by reference

herein.

54. At all relevant times, Defendant Okuma acted as an investment adviser

for the investor in this matter.  In exchange for compensation, Okuma engaged in the

business of advising the investor as to the value of securities or as to advisability of

investing in, purchasing, or selling securities.

55. Okuma, with scienter and while acting as an investment adviser, by use

of the mails or any means or instrumentality of interstate commerce, directly or

indirectly, employed a device, scheme, or artifice to defraud the client/investor.

12

56. By engaging in the conduct described herein, Okuma violated, and

unless enjoined will continue to violate, Section 206(1) of the Advisers Act [15

U.S.C. § 80b-6(1)].

COUNT IV – FRAUD

Violations of Section 206(2) of the Advisers Act
[15 U.S.C. § 80b-6(2)]

(Against Okuma)

57. Paragraphs 1 through 46 are realleged and incorporated herein by

reference.

58. At all relevant times, Defendant Okuma acted as an investment adviser

to the investor in this matter.  In exchange for compensation, Okuma engaged in the

business of advising the investor as to the value of securities or as to advisability of

investing in, purchasing, or selling securities.

59. Okuma, with knowledge, recklessness, or negligence, and while acting

as an investment adviser, by use of the mails or any means or instrumentality of

interstate commerce, directly or indirectly, engaged in transactions, practices, or a

course of business which operated as a fraud or deceit upon the investor in this

matter.

60. By engaging in the conduct described above, Okuma violated, and

unless enjoined will continue to violate, Section 206(2) of the Advisers Act [15

U.S.C. § 80b-6(2)].

13

PRAYER FOR RELIEF

 The Commission respectfully requests that this Court:

1. Find that Defendant committed the violations alleged;

2. Permanently enjoin Defendant and each of his agents, employees, and

attorneys, and any other person in active concert or participation with him who

receives actual notice of the injunction by personal service or otherwise, from

directly or indirectly engaging in conduct in violation of the following provisions:

Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; Section 10(b) of the

Exchange Act and Rule 10b-5 thereunder [15 U.S.C. § 78j(b) and 17 C.F.R. §

240.10b-5]; and Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. § 80b-

6(1)-(2)] by committing or engaging in specified actions or activities relevant to

such violations;

3. Order Defendant to disgorge all ill-gotten gains in the form of any

benefits of any kind derived from the illegal conduct alleged in this Complaint,

plus pay prejudgment interest, pursuant to Sections 21(d)(3)(A)(ii), 21(d)(5), and

21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];

4. Order Defendant to pay civil penalties pursuant to Section 20(d) of the

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

§ 78u(d)], and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)] in an

amount to be determined by the Court;

14

5. Enter a conduct-based injunction that permanently restrains and

enjoins Defendant from, directly or indirectly, including through any entity owned

or controlled by Defendant, participating in the issuance, purchase, offer, or sale of

any security; provided, however, that such injunction shall not prevent Defendant

from purchasing or selling securities listed on a national securities exchange for his

own personal accounts;

6. Order Defendant to relinquish all rights, title, and interest in the

property located at ;

7. Order, upon motion by the Commission, the appointment of a

liquidation agent to preserve and/or dispose of the property located at

, with the net proceeds of any disposition

being used to offset the disgorgement and prejudgment interest ordered against

Defendant;

8. Order Defendant to relinquish all rights, title, and interest in the

Affiliated Account (Bank of America bank account ending in x9316) and require

Bank of America to transfer the funds held in the Affiliated Account to the

Commission, with the net proceeds of any disposition being used to offset the

disgorgement and prejudgment interest ordered against Defendant;

9. 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

15

out the terms of all orders and decrees that may be entered, or to entertain any

suitable application or motion by the Commission for additional relief within the

jurisdiction of this Court; and

10. Order such other and further relief as this Court may deem just,

equitable, and appropriate in connection with the enforcement of the federal

securities laws and for the protection of investors.

JURY TRIAL DEMAND

The SEC demands a trial by jury as to all issues that may be so tried.

Dated: January 30, 2026  Respectfully submitted,

     /s/ Harry B. Roback
     M. Graham Loomis (GA Bar No. 457868)
     Harry B. Roback (GA Bar No. 706790)
     U.S. Securities and Exchange Commission
     950 East Paces Ferry Road, NE, Suite 900
     Atlanta, GA 30326
     Tel:(404) 942-0690
     Facsimile:  (404) 842-7679
     [email protected]

     Attorneys for Plaintiff

CERTIFICATION OF COMPLIANCE

This is to certify that the foregoing was prepared using Times New Roman

14 point font in accordance with Local Rule 5.1 (B).

/s/ Harry B. Roback
Harry B. Roback
OCR text (20,491c · textlayer · 95% conf)
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF GEORGIA 

(ATLANTA DIVISION) 
 
UNITED STATES SECURITIES 
AND EXCHANGE COMMISSION, 

 

  
               Plaintiff,  
  
               v. Civil Action No. 1:26-cv-_____ 

 
 

EJIRO ODE OKUMA, 
 
              Defendant. 

 
 

  
 

COMPLAINT 

 Plaintiff United States Securities and Exchange Commission (“SEC” or 

“Commission”) alleges as follows: 

NATURE OF ACTION 

1. Between March 2022 and March 2025, Defendant Ejiro Ode Okuma, 

a Georgia-based investment adviser, misappropriated more than $9.8 million from 

an elderly client. 

2. Okuma began his fraudulent scheme in 2022 by stealing 

approximately $900,000 from the client, who relied almost exclusively on Okuma 

for financial matters, and the estate of the client’s recently deceased sister. 

3. In 2023, Okuma began transferring securities from various brokerage 

accounts held by the client that Okuma managed to a new and unauthorized 

Case 1:26-cv-00561-MHC     Document 1     Filed 01/30/26     Page 1 of 16



2 
 

brokerage account. Okuma had created the new account purportedly for the benefit 

of a trust in the client’s name.  In reality, Okuma sold securities held in the account 

and used most of the sales proceeds to support his own expensive lifestyle. 

4. At around the same time that Okuma opened the unauthorized 

brokerage account, he obtained signatory authority on the client’s primary bank 

account.  Using his access to and control over the brokerage and bank accounts, 

Okuma ultimately misappropriated an additional $8.94 million from the client. 

5. Okuma facilitated the fraud by, among other means, electronically 

impersonating the client to access the brokerage account, forging the client’s 

signature on checks, and transferring funds from the client’s accounts to Okuma’s 

own bank account and other accounts over which he had control. 

6. Okuma used the misappropriated funds for his own benefit, including 

to build a multi-million-dollar residence, purchase vehicles, and buy vacation 

homes. 

7. By engaging in the conduct alleged in this Complaint, Defendant 

violated Section 17(a)(1) of the Securities Act of 1933 (“Securities Act”) [15 

U.S.C. § 77a(a)]; Section 10(b) of the Securities Exchange Act of 1934 

(“Exchange Act”) and Rules 10b-5(a) and (c) thereunder [15 U.S.C. § 78j(b) and 

17 C.F.R. § 240.10b-5]; and Sections 206(1) and 206(2) of the Investment 

Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. § 80b-6]. 

Case 1:26-cv-00561-MHC     Document 1     Filed 01/30/26     Page 2 of 16



3 
 

JURISDICTION AND VENUE 

8. The Commission brings this action pursuant to Sections 20 and 22 of 

the Securities Act [15 U.S.C. §§ 77t and 77v], Sections 21(d) and 21(e) of the 

Exchange Act [15 U.S.C. §§ 78u(d) and 78u(e)], and Sections 209 and 214 of the 

Advisers Act [15 U.S.C. §§ 80b-9 and 80b-14] to enjoin Defendant from engaging in 

the transactions, acts, practices, and courses of business alleged in this complaint, and 

transactions, acts, practices, and courses of business of similar purport and object, for 

civil penalties, disgorgement plus prejudgment interest, and for other equitable relief. 

9. This Court has jurisdiction over this action pursuant to Section 22 of the 

Securities Act [15 U.S.C. § 77v], Sections 21(d), 21(e), and 27 of the Exchange Act 

[15 U.S.C. §§ 78u(d), 78u(e), and 78aa], Section 214 of the Advisers Act [15 U.S.C. 

§ 80b-14], and 28 U.S.C. § 1331. 

10. Venue is proper in this Court pursuant to Section 22(a) of the Securities 

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

Section 214 of the Advisers Act [15 U.S.C. § 80b-14], and 28 U.S.C. § 1391. 

11. Defendant, directly and indirectly, made use of the mails, and the means 

and instrumentalities of interstate commerce in connection with the transactions, acts, 

practices, and courses of business alleged in this complaint. 

12. Certain of the transactions, acts, practices, and courses of business 

constituting violations of the Securities Act, the Exchange Act, and the Advisers Act 

Case 1:26-cv-00561-MHC     Document 1     Filed 01/30/26     Page 3 of 16



4 
 

occurred within the jurisdiction of the United States District Court for the Northern 

District of Georgia.  Specifically, Defendant engaged in fraudulent conduct in this 

judicial district; he misappropriated investor funds in this judicial district; and the 

defrauded client resides in this judicial district.  In addition, Defendant resides in this 

judicial district as well. 

13. Defendant, unless restrained and enjoined by this Court, will continue to 

engage in the transactions, acts, practices, and courses of business alleged in this 

complaint, and in transactions, acts, practices, and courses of business of similar 

purport and object. 

DEFENDANT 

14. Ejiro Ode Okuma, age 43, is a resident of Smyrna, Georgia.  From 

2010 until May 4, 2023, Okuma was a registered representative and investment 

adviser representative with a firm that is registered with the Commission as a 

broker-dealer and investment adviser.  From May 5, 2023 until his resignation in 

June 2025, Okuma was a registered representative and investment adviser 

representative of another firm that is also registered with the Commission as a 

broker-dealer and investment adviser.  Okuma holds Series 7, 63, 65, and 66 

securities licenses. 

15. Okuma asserted his Fifth Amendment right against self-incrimination 

in response to questions regarding his use of client funds. 

Case 1:26-cv-00561-MHC     Document 1     Filed 01/30/26     Page 4 of 16



5 
 

OTHER RELEVANT ENTITIES AND INDIVIDUALS 

16. Advisory Client (“Client”) is an 81-year-old man who resides in this 

judicial district.  Client relied almost exclusively on Okuma for financial matters.  

Client was an advisory client and brokerage customer of Okuma. 

STATEMENT OF FACTS 

A. Background 

17. In 2016, Okuma began providing financial services to Client.  At that 

time, Okuma was associated with a firm as an investment adviser representative 

and registered representative.  The firm was registered with the Commission as a 

broker-dealer and investment adviser. 

18. Okuma also provided financial services to certain trusts that Client 

had established to hold assets for his benefit. 

19. Over time, Client, who has certain health issues, grew increasingly 

reliant on Okuma to manage all aspects of his finances, including by facilitating 

payments of bills and other expenses, arranging for a caretaker, purchasing 

groceries and other household items, and even handling his mail. 

20. In August 2021, Client’s sister and only living relative passed away 

intestate.  Client was the sole heir of her estate (the “Estate”) and requested the 

probate court appoint Okuma as administrator of the Estate.  The court finalized 

Okuma’s appointment in February 2022. 

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21. At that time, Client’s assets, including those held by trusts established 

for his benefit, exceeded $10 million in the form of mutual funds, equities, bonds, 

and annuities. 

B. Okuma Begins Misappropriating Client’s Funds 

22. In March 2022, Okuma, through his access to and control over 

Client’s brokerage accounts, sold more than $517,000 in securities and transferred 

$500,000 of the proceeds to Client’s bank account. 

23. Okuma then instructed Client to write a $500,000 check in favor of 

the Estate.  As the Estate administrator, Okuma deposited the check in an Estate 

account and then transferred all $500,000 to an account that he controlled that was 

held by an entity affiliated with one of Okuma’s family members (“Affiliated 

Account”). 

24. In June 2022, Okuma transferred an additional $100,000 of Client’s 

funds from a brokerage account to Client’s bank account. 

25. After depositing the funds, Okuma transferred the money, along with 

the bulk of the Estate’s other funds, to the Affiliated Account using a $400,000 

check. 

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C. Okuma Continues Misappropriating Client’s Funds 

26. Okuma continued to misappropriate Client’s funds in 2023. 

27. In February 2023, Okuma, using information obtained as Client’s 

investment adviser, opened an account at a broker-dealer for one of Client’s trusts. 

28. Okuma funded the brokerage account by transferring more than 

$9 million in securities held in Client’s other accounts, effectively leaving those 

accounts empty. 

29. While establishing the new brokerage account, Okuma took several 

steps to conceal his continued misappropriation from Client. 

30. For example, Okuma: (i) authorized the use of check writing from the 

account; (ii) set up the log-in credentials for the account so that he could access 

and control the account; and (iii) created an e-mail account to electronically 

impersonate Client and used the e-mail account as part of the account opening 

process. 

31. Okuma took these steps without the knowledge or consent of Client, 

who did not understand that the new brokerage account was being established. 

32. In addition, Okuma caused Client to add Okuma to Client’s personal 

bank account as a joint account holder with right of survivorship.  Okuma then 

created his own accounts with the same bank. 

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33. In May 2023, Okuma left the advisory firm at which he had been 

working to become an investment adviser representative and registered 

representative associated with another firm.  At the new firm, Okuma periodically 

reviewed securities portfolios, made securities trading recommendations, and 

exercised discretionary authority in client accounts. 

34. Okuma told Client that their advisory relationship would continue at 

the new firm.  Client also believed that their advisory relationship remained the 

same as it had been at the old firm. 

35. In fact, however, Okuma did not transfer any of Client’s assets to the 

new firm or establish accounts for Client with the new firm. 

36. This meant that even though Client was still an advisory client of 

Okuma, the new firm did not have a record of Client being a client of the firm or 

the ability to monitor and detect Okuma’s conduct with Client’s funds. 

37. Beginning in August 2023, Okuma began drafting checks from the 

new brokerage account by, it appears, forging Client’s signature. 

38. Specifically, between August 2023 and March 2025, Okuma drafted 

checks from the account totaling $6,743,000 in favor of the firm associated with 

the Affiliated Account and $500,000 in favor of another firm that was owned and 

managed by Okuma. 

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39. Additionally, between October 2023 and February 2025, Okuma 

transferred nearly $2.5 million from the new brokerage account to Client’s bank 

account, and then Okuma transferred the funds to his personal bank accounts. 

40. Okuma funded these checks and transfers by selling securities in 

Client’s brokerage account. 

D. Okuma Uses Misappropriated Funds to Support his Lifestyle 

41. In total, Okuma transferred more than $10.6 million from Client’s 

accounts to accounts held and/or controlled by Okuma. 

42. Okuma used approximately $800,000 of these funds on Client, 

including for the purchase of a new home for Client. 

43. Okuma misappropriated the remaining funds, totaling approximately 

$9.8 million, for himself. 

44. Okuma spent the bulk of the misappropriated funds—more than $5.6 

million—toward the purchase of real property located at  

, and the design and partial construction of a multi-million-

dollar home on the property. 

45. Okuma used the rest of Client’s money to fund his family’s lifestyle, 

including purchasing luxury cars, making a downpayment on a $1.4 million beach 

house, and acquiring a fractional share of a second vacation home. 

46. After learning of the SEC’s investigation, Okuma returned some funds 

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to Client.  At this time, Okuma still owes client approximately $9 million. 

COUNT I – FRAUD 
 

Violations of Section 17(a)(1) of the Securities Act 
[15 U.S.C. § 77q(a)(1)] 
(Against Okuma) 

 
47. Paragraphs 1 through 46 are realleged and incorporated herein by 

reference. 

48. Defendant, acting with scienter, in the offer or sale of securities and by 

the use of means or instruments of transportation or communication in interstate 

commerce or by the use of the mails, directly or indirectly, employed a device, 

scheme, or artifice to defraud. 

49. By reason of the foregoing, Defendant, directly and indirectly, has 

violated and, unless enjoined, will continue to violate Section 17(a)(1) of the 

Securities Act [15 U.S.C. § 77q(a)(1)]. 

COUNT II – FRAUD 
 

Violations of Section 10(b) of the Exchange Act 
and Rules 10b-5(a) and (c) thereunder 

[15 U.S.C. § 78j(b)(5), 17 C.F.R. § 240.10b-5] 
(Against Okuma) 

 
50. Paragraphs 1 through 46 are realleged and incorporated by reference 

herein. 

51. Defendant, acting with scienter and in connection with the purchase or 

sale of securities and by the use of any means or instrumentality of interstate 

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commerce or by use of the mails or any facility of any national securities exchange, 

directly or indirectly (i) employed a device, scheme, and artifice to defraud, and 

(ii) engaged in acts, practices, or a course of business which operated or would have 

operated as a fraud or deceit upon sellers, purchasers, or prospective purchasers of 

securities. 

52. By engaging in the conduct described above, Defendant violated, and 

unless enjoined will continue to violate, Section 10(b) of the Exchange Act and Rules 

10b-5(a) and (c) thereunder [15 U.S.C. § 78j(b)(5), 17 C.F.R. § 240.10b-5]. 

COUNT III – FRAUD 
 

Violations of Section 206(1) of the Advisers Act 
[15 U.S.C. § 80b-6(1)] 

(Against Okuma) 
 

53. Paragraphs 1 through 46 are realleged and incorporated by reference 

herein. 

54. At all relevant times, Defendant Okuma acted as an investment adviser 

for the investor in this matter.  In exchange for compensation, Okuma engaged in the 

business of advising the investor as to the value of securities or as to advisability of 

investing in, purchasing, or selling securities. 

55. Okuma, with scienter and while acting as an investment adviser, by use 

of the mails or any means or instrumentality of interstate commerce, directly or 

indirectly, employed a device, scheme, or artifice to defraud the client/investor. 

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56. By engaging in the conduct described herein, Okuma violated, and 

unless enjoined will continue to violate, Section 206(1) of the Advisers Act [15 

U.S.C. § 80b-6(1)]. 

COUNT IV – FRAUD 
 

Violations of Section 206(2) of the Advisers Act 
[15 U.S.C. § 80b-6(2)] 

(Against Okuma) 
 

57. Paragraphs 1 through 46 are realleged and incorporated herein by 

reference. 

58. At all relevant times, Defendant Okuma acted as an investment adviser 

to the investor in this matter.  In exchange for compensation, Okuma engaged in the 

business of advising the investor as to the value of securities or as to advisability of 

investing in, purchasing, or selling securities. 

59. Okuma, with knowledge, recklessness, or negligence, and while acting 

as an investment adviser, by use of the mails or any means or instrumentality of 

interstate commerce, directly or indirectly, engaged in transactions, practices, or a 

course of business which operated as a fraud or deceit upon the investor in this 

matter. 

60. By engaging in the conduct described above, Okuma violated, and 

unless enjoined will continue to violate, Section 206(2) of the Advisers Act [15 

U.S.C. § 80b-6(2)]. 

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PRAYER FOR RELIEF 

 The Commission respectfully requests that this Court: 

1. Find that Defendant committed the violations alleged; 

2. Permanently enjoin Defendant and each of his agents, employees, and 

attorneys, and any other person in active concert or participation with him who 

receives actual notice of the injunction by personal service or otherwise, from 

directly or indirectly engaging in conduct in violation of the following provisions:  

Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; Section 10(b) of the 

Exchange Act and Rule 10b-5 thereunder [15 U.S.C. § 78j(b) and 17 C.F.R. § 

240.10b-5]; and Sections 206(1) and 206(2) of the Advisers Act [15 U.S.C. § 80b-

6(1)-(2)] by committing or engaging in specified actions or activities relevant to 

such violations; 

3. Order Defendant to disgorge all ill-gotten gains in the form of any 

benefits of any kind derived from the illegal conduct alleged in this Complaint, 

plus pay prejudgment interest, pursuant to Sections 21(d)(3)(A)(ii), 21(d)(5), and 

21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; 

4. Order Defendant to pay civil penalties pursuant to Section 20(d) of the 

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

§ 78u(d)], and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)] in an 

amount to be determined by the Court; 

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5. Enter a conduct-based injunction that permanently restrains and 

enjoins Defendant from, directly or indirectly, including through any entity owned 

or controlled by Defendant, participating in the issuance, purchase, offer, or sale of 

any security; provided, however, that such injunction shall not prevent Defendant 

from purchasing or selling securities listed on a national securities exchange for his 

own personal accounts; 

6. Order Defendant to relinquish all rights, title, and interest in the 

property located at ; 

7. Order, upon motion by the Commission, the appointment of a 

liquidation agent to preserve and/or dispose of the property located at  

, with the net proceeds of any disposition 

being used to offset the disgorgement and prejudgment interest ordered against 

Defendant; 

8. Order Defendant to relinquish all rights, title, and interest in the 

Affiliated Account (Bank of America bank account ending in x9316) and require 

Bank of America to transfer the funds held in the Affiliated Account to the 

Commission, with the net proceeds of any disposition being used to offset the 

disgorgement and prejudgment interest ordered against Defendant; 

9. 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 

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15 
 

out the terms of all orders and decrees that may be entered, or to entertain any 

suitable application or motion by the Commission for additional relief within the 

jurisdiction of this Court; and 

10. Order such other and further relief as this Court may deem just, 

equitable, and appropriate in connection with the enforcement of the federal 

securities laws and for the protection of investors. 

JURY TRIAL DEMAND 

The SEC demands a trial by jury as to all issues that may be so tried. 

Dated: January 30, 2026  Respectfully submitted, 

 
     /s/ Harry B. Roback     
     M. Graham Loomis (GA Bar No. 457868) 
     Harry B. Roback (GA Bar No. 706790) 
     U.S. Securities and Exchange Commission 
     950 East Paces Ferry Road, NE, Suite 900 
     Atlanta, GA 30326 
     Tel:(404) 942-0690 
     Facsimile:  (404) 842-7679 
     [email protected] 
 
     Attorneys for Plaintiff 

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CERTIFICATION OF COMPLIANCE 
 
This is to certify that the foregoing was prepared using Times New Roman 

14 point font in accordance with Local Rule 5.1 (B). 
 

/s/ Harry B. Roback 
Harry B. Roback 

 
 

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