SEC v. Denis Georgiyevich Sotnikov; Adaptive Technology LLC; AGQ Business Group LLC; ATL Business Group LLC; BO&SA Corporation; DN Industrial LLC, et al., No. 2:20-cv-02784, District of New Jersey (Mar. 13, 2020) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
__________________________________________
:
UNITED STATES SECURITIES AND      :
EXCHANGE COMMISSION,    :
:
Plaintiff,     :
:
vs.     : Civil No.
:
DENIS GEORGIYEVICH SOTNIKOV, :
ADAPTIVE TECHNOLOGY LLC, :
AGQ BUSINESS GROUP LLC,      :
ATL B USINESS GROUP LLC,  :
BO&SA CORPORATION,  :
DN INDUSTRIAL LLC, and :
EXPERT DIGITAL LLC,    : COMPLAINT
:
De fe ndants ,      :
:
and       :
:
NATALIA ALEKSANDROVNA MAZITOVA,   :
GREAT IMPERIAL LLC,   : JURY TRIAL DEMANDED
HRC CLEARING HOUSE LLC, :
INTEKO CARGO LLC,  :
:
Relief Defendants.      :
__________________________________________:
COMPLAINT
P la intif f   United  States Securities  and Exchange Commission   (the “SEC” or the
“C ommis s io n” )   a lle ge s   a s   f ollow s  against the following  Defendants, whose names and last
known  addresses are set forth  below:
a)Denis  Georgiyevich  Sotnikov  (“Sotnikov”),  706 Diplomat  P arkway, Hallandale
Beach, Florida  33009;
b)Adaptive  Technology  LLC (“Adaptive  Technology”),   801  Three Island
Boulevard,  Apt.  520,  Hallandale  Beach,  Florida  33009;
c)AGQ Business Group  LLC (“AGQ Business  Group”), 1201  S  Ocean  Drive,  Apt.
800,  Hollywood,  Flor ida   33019;

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d) ATL Business Group  LLC (“ATL  Business  Group”),   801  Three  Island  Boulevard,
Apt. 520,  Hallandale  Beach, Florida  33009;
e)  BO&SA Corporation (“BO&SA”), 1201  S. Ocean Drive, #2107S,  Hollywood,
Florida  33019;
f) DN Industrial  LLC (“DN Industrial”), 3180  S  Ocean  Drive,  #230,  H a llandale
Beach, Flor ida   33009;  and
g) Expert  Digital   LLC (“Expert  Digital”),  1201  S. Ocean Drive,  #2107S,
Hollywood,   Florida  33019;
and as to the following Relief  Defendants, whose names and last known addresses are set forth
below:
a) Natalia Aleksandrovna  Mazitova (“Mazitova”),  706  Diplomat  P arkway,
Hallandale  Beach,  Florida  33009;
b) Great Imperial  LLC (“Great Imperial”), 18401  Collins  Ave., Apt. 1173,  Sunny
Isles Beach, Flor ida   33160;
c) HRC Clearing  House LLC (“HRC Clearing”), 801 Three Island  Boulevard,  Apt.
520,  Hallandale  Beach,  Florida  33009;  and
d) Inteko Cargo LLC  (“ Inteko  Cargo”),  706  Diplomat   P arkway,  Hallandale  Beach,
Florida  33009.
SUMMARY
1. This matter concerns an ongoing fraudulent  scheme in  which U.S investors –
many  of  whom  are  older  and  using  their  retirement  savings  – are lured to websites offering
f ic  titious    C e r tif ic a te s   of   D e pos it  (“CDs”) at above-market rates.
1
  Some of the websites “spoof”
actual U.S.-based f ina nc ia l  f ir ms,
2
  while  others  offer CDs from  fake f ina nc ia l  f ir ms.

1
  Like  bonds,  CDs are debt-based,  fixed-income  securities that an investor  holds  until  a fixed
maturity  date.  The CDs offered as part of the scheme described here are fictitious  instruments
not  issued  by  a legitimate  U.S. bank,  and  are therefore not  subject  to protections  offered  by the
federal banking  laws.  These fictitious  CDs did,  however, mimic  real CDs by purporting  to have
a fixed  maturity  and promising   a specific  and  above-market-rate  of  return,  and they  were offered
to the general public  and marketed as legitimate  securities.
2
  “Spoofing”  is the act of disguising  a communication  from an unknown  source as being  from a
known,  trusted source.  See, e.g., https://www.investopedia.com/terms/s/spoofing.asp.

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2. The spoofed  websites  use domain  names similar  to the domain  names of actual
f ina nc ia l  institutions  or that s ound  like   r e a l  f ina nc ia l  f ir ms.   The spoofed websites f a ls e ly  c la im
that the firms  offering  CDs  to  investors  are FDIC, FINRA, SIP C, or New York Stock Exchange
members,  and that the deposits are FDIC-insured.
3. The spoofed websites  are advertised in  search results  provided  by the two  leading
internet  search and advertising  companies.    As a result, unsuspecting  investors  see
advertisements for the spoofed websites at the top of their  search results when conducting
internet  searches for CDs with  attractive  rates.  P ote ntia l  investors who  visit  a spoofed  website
are  directed  to  call  a  telephone  number  on  the website.  Believing  that they are dealing  with a
le gitima te   U . S.-ba s e d f ina nc ia l  f ir m  of f e r ing  le gitima te  CDs,  potential   investors  who  call  the
number  on a spoofed website speak with  an individua l  purporting  to be an “account executive”
of the firm  identified  on the website.  P otential  investors  provide  an email  address, after which
they are contacted via  email  by  the fake account executive,  who  often  impersonates  a real broker
or sales representative of a spoofed  financial   firm.
4. Investors are instructed  by the  fake account executives  to w ire funds to bank
accounts opened on  behalf  of  purported  “clearing  firms” ide ntif ie d   in  the   e ma ils.    Once the funds
are received by the purported “c le a r ing  f ir m,”  they are quickly transferred to different bank
accounts,  both  domestic  and  foreign,   making  it  difficult   or  impossible  for investors  to regain
their  funds.
5. Since November 2014,  the perpetrators of this  scheme have created websites
spoofing  at least 24 actual financial firms and 8 f ic titious   f ina nc ia l  f ir ms,  resulting  in  over $26
million   in  known  investor  losses.    As  described  in  this  Complaint,   Sotnikov   and  the entity
defendants – Adaptive  Technology,  AGQ Business Group,  ATL Business Group,  BO&SA, DN

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Industrial,  and Expert Digital  (collectively,  the “Defendant LLCs”) – are directly  linked  to 7 of
the  spoofed  websites,  through   which  investors  have  lost  over  $1.8  million.
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6. Sotnikov’s participation is   essential to the fraudulent  scheme.  He organized
and/or  controls  the Defendant LLCs,  each  of  which  has been represented to investors  as
“clearing” or  “offering” the  CDs  of  a  spoofed  or  fictitious  f ina nc ia l  f ir m  and received investor
funds.   In fact, the Defendant LLCs are not  clearing  firms,  and they do  not  offer  or   s e ll   le gitima te
CDs or  other securities.  Instead, the Defendant LLCs were created by Sotnikov to serve as
conduits  to receive wire transfers from duped investors  in furtherance of the fraudulent  scheme
alleged  in  this  Complaint.
7. After investor funds are wired  into  a bank account nominally  owned by one of the
Defendant  LLCs,  but  in  fact  controlled   by  Sotnikov,   he  either transfers the funds to  other  LLC-
owned bank accounts that he or his w if e ,  Relief Defendant Mazitova, control,  including   accounts
nominally   owned by the Relief  Defendant LLCs, transfers the funds to other foreign bank
accounts,  transfers  the  funds  to  one  of  his  personal  bank  accounts,  or dir e c tly  pays  for  his  and/or
his wife’s personal  expenses out of the accounts.
NATURE OF PROCEEDING AND RELIEF SOUGHT
8. The SEC brings  this action against Sotnikov,  the Defendant LLCs, Mazitova  and
the Relief Defendant LLCs pursuant  to  Section  21A  [15  U.S.C.  §  78u-l]  of  the  Exchange  Act  and
Section  20(b) of the Securities  Act [15 U.S.C. § 77t(b)]  seeking  a judgment  from the  Court:
(a) enjoining Sotnikov and the Defendant LLCs from  engaging   in  future  violations   of  the federal
securities laws; (b) ordering the Defendants and the Relief  Defendants to disgorge  an amount

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  In addition  to $1.8 million  in  investor  losses identified  thus far, over $4 million  of investor
funds have been frozen by the banks at which  the Defendant LLCs and Relief  Defendant LLCs
held  or hold  accounts.

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equal  to  the  profits  gained  and  losses  avoided   as  a  result  of  the  actions  described  herein,  with
prejudgment  interest;  and (c) ordering Sotnikov and the Defendant LLCs to pay civil  monetary
penaltie s.
JURISDICTION AND VENUE
9. This  Court  has  jurisdiction   over  this  action  pursuant  to  Sections  21(d),  21(e),  21A
and  27(a)  of  the  Exchange  Act  [15  U.S.C.  §§  78u(d),   78u(e),  78u-l,  and 78aa(a)] and Sections
20(b) and 22(a) of the Securities  Act [15 U.S.C. §§ 77t(b)  and 77v(a)].
10. Sotnikov and the Defendant LLCs, directly  or indirectly,  used the means of
interstate commerce and/or the facilities  of a national  securities exchange,  in  connection   with  the
transactions,  acts, practices,  and courses of business  alleged  in this  Complaint.
11. Venue  in  this  district  is  proper  pursuant  to  Section  27  of  the  Exchange  Act  [15
U.S.C. § 78aa] because certain of the offers and sales of securities and certain of the acts,
practices, transactions,  and courses of business  constituting  the viola tions    a lle ge d   in  this
C ompla int   oc c ur r e d  w ithin   this    D is tr ic t.     Spe c if ic a lly,  the  spoofed  websites  described  herein
were available  to investors  throughout  this  District, at least one  investor  residing  in this   D is tr ic t
wired funds to one of the Sotnikov-contr olled  Defendant LLCs as a result  of the fraudulent
scheme,
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 and many of the investor wire transfers for fake CDs alleged  in  this  Complaint   were
cleared through  bank f a c ilitie s  in     Mount  Laurel,  New Jersey.
DEFENDANTS
12. De nis  Ge orgiye vich Sotnikov, age 36, is a Russian national  who resides in
Hallandale  Beach, Florida.    Sotnikov  organized  and/or  controls  or controlled  each of  the
Defendant LLCs and Relief Defendant LLCs HRC Clearing  and Inteko  Cargo,  and  opened  and

4
  Upon  information   and  belief,  that  investor  is a resident of Voorhees, New Jersey.

6

controls  or controlled  bank accounts nominally  owned by the Defendant LLCs and Relief
Defendant LLCs HRC Clearing  and Inteko  Cargo.
13. Adaptive  Te chnology LLC is a Wyoming  limited  liability  corporation (“LLC”),
w ith  a Hallandale  Beach, Florida a ddr e s s  listed   in  its  incorporation   papers.  Sotnikov organized
Adaptive  Technology   and  he  is  listed  in  its   incorporation  papers as its “manager.”  Adaptive
Technology  is the nominal  owner of bank accounts controlled  by Sotnikov  that directly  received
investor  funds.    Sotnikov  has  sole  signatory  authority  over the Adaptive  Technology bank
accounts used in  the scheme alleged  in  this  Complaint.
14. AGQ B us ine ss Group LLC is   a   Flor ida   LLC,  w ith  a Hallandale  Beach, Florida
address  listed  in  its  incorporation   papers.  Sotnikov organized AGQ Business Group  and he is
listed  in  its  incorporation  papers as its  “manager.”  AGQ Business Group  is the nominal  owner
of a bank account controlled  by Sotnikov  that directly   received  investor  funds.  Sotnikov  has sole
signatory  authority  over the AGQ Business Group bank account  used in     the scheme alleged  in
this  Complaint.
15. ATL B us ine ss Group LLC is  a  Wyoming  limited  liability  corporation,  with  a
Hallandale  Beach, Florida address listed  on its incorporation  papers – the same address used by
Adaptive  Technology.    Sotnikov  organized  ATL Business  Group and he is listed  in its
incorporation  papers as its “manager.”  ATL Business Group is the nominal  owner of a bank
account controlled  by Sotnikov  that directly  received investor  funds.    Sotnikov  has sole  signatory
authority  over the ATL Business  Group  bank account used in the scheme alleged  in  this
Complaint.
16. BO&SA Corporation is  a Florida  corporation,  with a Hollywood,   Florida
address  listed  in  its  incorporation   papers  – the same address used by AGQ Business Group.

7

Sotnikov was a founding  member of BO&SA and was an officer of BO&SA at various  times
throughout   its  history,   including   from  its  creation  on  December 10,  2018  through  March 13,
2019,  and from May 21,  2019 through August  2,  2019.  BO&SA is the nominal  owner of bank
accounts that dir  ectly   received  investor  funds  and  that  were accessed at various  times  by
Sotnikov.
17. DN Industrial  LLC w a s   a   Flor ida   limite d  lia bility  c or por a tion,  w ith  a Hallandale
Beach, Florida  address  listed  in  its  incorporation   papers – the same address used by AGQ
Business  Group,   Expert  Digital,   and  BO&SA.  Sotnikov  organized  DN  Industrial  and  was lis te d
as its  “manager” in     its  incorporation   papers  until  it  was dissolved on  October  3,  2019.
5
    DN
Industrial   is  the  nominal   owner  of  bank  accounts  controlled   by  Sotnikov   that directly  received
investor  funds.
18. Expe rt Digital LLC was a New York  limited  liabilit y  corporation,  with a
Hollywood,   Florida  address – the same address used by AGQ Business Group  and BO&SA.
Sotnikov  organized  Expert  Digital  and  was  listed  in  its    incorporation   papers as its  “manager”
until  it  was voluntarily   dissolved   on  September  13,  2019.  Expert Digital  was the nominal  owner
of bank accounts controlled  by Sotnikov  that directly  received investor  funds.
RELIEF DEFENDANTS
19. Natalia  Ale k s androvna M azitova, age  37,  is  a  Russian  national   who  resides  in
Hallandale  Beach, Florida.
20. Gre at Impe rial LLC is   a   Flor ida   limite d  lia bilit y  c or por a tion,  w ith  a La ude r hill,
Flor ida  address.  Relief  Defendant  Mazitova organized  Great Imperial  and she is listed  in its

5
  Where  an  LLC  is  described  in  this  Complaint   as  “dissolved,”   it  means  that,  upon  information
and  belief,  the  entity  failed  to  file  required  annual  paperwork  with  the  government  of  the  state  in
which the entity  was organized.

8

incorporation  papers as its “manager.”  Great Imperial  is the nominal  owner of bank accounts
controlled  by Mazitova  that indirectly  received investor  funds.
21. HRC Cle aring House  LLC is  a  Flor ida   limite d  lia bility   c or por a tion,  w ith a
Hallandale  Beach, Florida address – the same address used by Adaptive  Technology  and ATL
Business  Group.   Sotnikov  organized  HRC Clearing  and  he  is  listed  in  its  incorporation  papers as
its “manager.”  HRC Clearing  is the nominal  owner of at least seven bank accounts controlled  by
Sotnikov,  some of which indirectly   received  investor  funds.  Sotnikov  has sole signatory
authority  over all  HRC Clearing  bank accounts used in  the scheme.
22. Inte ko Cargo LLC is   a   Flor ida   limite d  lia bilit y   c or por a tion,  w ith  a Sunny  Isles
Beach, Florida  address – the home address of Sotnikov  and Mazitova.    Sotnikov organized
Inteko  Cargo  and  he  is  listed  in  its  incorporation  papers as its “manager.”  Inteko Cargo is the
nominal  owner of at least six bank  accounts  controlled   by  Sotnikov,  some of which  indirectly
received  investor  funds.  Sotnikov   has  sole  signatory  authority   over  all  Inteko  Cargo  bank
accounts used in  the scheme.
FACTUAL ALLEGATIONS
I.    The  Fraudule nt  Sche me  To Se ll Fake  Ce rtificate s  Of De posit To U.S. Inve stors
23. Since at least November 2014 and continuing   through   March 2020,  unidentified
perpetrators have been spoofing  websites of actual broker-dealers,  investment   advisers,  and
banks,  or  creating  websites for fake financial  firms,  to  offer fictitious  CDs to  U.S. investors.
6

These perpetrators have registered numerous domain  names that are similar  to  the  domain  names
of real financial institutions  and  then have used those domain  names to create websites that
purport  to  offer jumbo  CDs at rates slightly  higher  than market rates.  The websites typically  use

6
  All investors  referred to in this  Complaint  resided in the United  States at the time  of their
investments.

9

the actual logos  of the spoofed firms,  and claim  that the firms  are FDIC, FINRA, SIPC, or New
York  Stock  Exchange  members,  and that deposits are FDIC insured.   The websites often use the
spoofed  firms’   actual FINRA and/or  FDIC  member ide ntif ic a tio n  numbers.
24. In furtherance of the scheme, the perpetrators  of the scheme have purchased
internet adve r tis ing  from,  among  others,  the top two providers  of internet  search and advertising
services,  causing advertisements  for the spoofed  websites to appear at the top  of search results
for phrases such as “best  CD rates,” “highest  cd rates,” or other s imila r   phrases.
25. As a result,  unsuspecting  investors,  when  conducting  internet  searches for CDs
with attractive rates, received advertisements  for the spoofed  websites and clicked  on  links   that
directed them to the spoofed  websites operated by the perpetrators of the scheme.  They  then
called  the  telephone  numbers  provided   on  the spoofed websites  and  spoke  to  an individua l
claiming  to be a representative of the spoofed firm,  often impersonating an actual employee of
the spoofed  firm  and  using  the  real employee’s name and FINRA CRD number.
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26. Investors then received an email  from the purported  account executive providing
an  application   to  open  an  “account” to purchase the CDs and wiring  instructions  to  purported
“c le a r ing   f ir ms ”   w ith  either  foreign  or  U.S.-based accounts.  After investors  funded their  CD
accounts by  wiring   in  their  investments,   the  funds  were  quickly  transferred to other bank
accounts,  including   accounts  overseas.
27. In addition  to using  the names of spoofed real or  nonexistent  financial  firms  and
posing   as  actual  employees  of  spoofed  firms,  the perpetrators have gone to significant  lengths  to

7
  FINRA operates the Central Registration  Depository  (“CRD”), the central licensing  and
registration  system used by the U.S. securities  industry   and  its  regulators,  which  contains  the
registration  records of broker-dealer  firms  and  their  associated  individua ls   (e.g., brokers and
investment  advisors).

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hide  their  identities.     For  example,  they have used:   (1) virtual  private  networks  (“VP Ns”)  to
anonymize  their  digital  footprints,  such  as  internet  protocol  (“IP”) addresses;  (2)  prepaid  gift
cards to pay for domain-name  registration  services,  state  incorporation  filings,  internet ads, and
VPN, website, and call-answering  services;  (3) prepaid phones  or encrypted communication
products to  communicate;  and (4) fake invoices  and  websites to  explain  large money  transfers in
response to inquiries  by banks that received large wire transfers of investor  funds.
28. In some cases, the r e a l  f ina nc ia l   f ir ms   being  spoofed  learned  about  the  spoofed
website from victims  or potential victims  of the scheme,  and took steps to shut down the spoofed
websites by contacting the domain-name  registrar  and asserting trademark or copyright
infringement.   Even though  the spoofed websites were typically  up for only  a few weeks before
they were taken down,  the perpetrators raised and wired abroad millions  of dollars  from duped
U.S. investors.    Since November 2014,  the perpetrators have created websites spoofing  at least
24 U.S.-based financial firms or using  at least 8 f ic titious   e ntitie s ,  r e s ulting  in  a t  le a s t  $26  million
in  known  investor  losses  and  $44.9  million   in  attempted  investments.
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    As described  below,
Sotnikov  and the Defendant LLCs are directly linked  to 7 of the spoofed  websites, through  which
investors  have  lost  over  $1.8  million.     Many of the victimized   investors  were e lde r ly  and were
investing their  retirement  savings.
II.  Sotnikov’s  Role In The  Fraudule nt Sche me
29. Beginning  no later than February  2019 and continuing   through   at least February
2020, Defendant Sotnikov   participated  in  a scheme involving spoofs of at least seven different

8
  Investor losses are less than the total amount  sent by investors  to bank accounts controlled  by
the perpetrators of the larger scheme because investors,  banks,  or government  agencies  became
suspicious  or  flagged specific  transactions  and some accounts were frozen before investor  funds
could  be sent to foreign  accounts or otherwise dispersed.

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U.S.-based financial  firms, w ith  each spoofed  website  offering  fictitious   CDs to investors  in  a
manner  consistent with  the scheme outlined  above.
30. Sotnikov  formed  many U . S.    limite d   lia bility   c ompa nie s,  including  the Defendant
LLCs and several of the Relief Defendant LLCs.
31. In forming  the Defendant LLCs and/or in opening  bank accounts for them,
Sotnikov   claimed  that the Defendant LLCs were engaged in  legitimate  businesses unrelated  to
the offer and sale of securities or the clearing  of securities transactions:
a. DN Industrial -  “Industrial  Construction  Business  Equipment”  (Bank account
opening  documents)  and “Kitchen  and  restaurant equipment  sales” (Bank account
opening  documents);
b. BO&SA -  “Development  and sale of software, provision  of virtual  space for sales
representatives, development  of web resources” (Florida  incorporation
documents);
c. Expe r t  D igita l  -  “IT Consulting,  Computer,  Technology  and P rogram Consulting”
business  (Bank 1 account  opening   documents);
d. Adaptive  Technology  -  “Custom  computer  programming   services” (Bank account
opening  documents);
e. ATL Business Group -  “custom  computer  programming   services.”  (Bank account
opening  documents);  and
f. AGQ Business Group -  “Flooring   and  Kitchen  construction”  (Bank account
opening  documents).
Upon information  and belief  based  on  available  bank  records,  however, none of these entities
engaged  in  any  legitimate   business  activity.   Instead,  their  primary  function  was to  serve as a
conduit  for the proceeds of the fraudulent  scheme undertaken by Sotnikov  and other perpetrators.
32. One of the Defendant LLCs, ATL Business Group,  was a ls o  named as the entity
offering the CDs on  two  spoofed  websites  — amrbusinessgroup.com   and   atlbusinessgroup.com.
Each of the Defendant LLCs was based in  a residential  apartment or condominium  in  the Miami
Beach area, including  several at the same address, one of which is Sotnikov’s  personal residence.

12

33. Upon information  and belief  based on review of available  records, Defendant DN
Industrial,  another  of  the Defendant LLCs controlled  by Sotnikov,  made payments  to a leading
provider  of Internet search and advertising  services for advertising  that directed potential
investors  to  at least one of the spoofed websites  described  below  in  this  Complaint.
34. As with  the Defendant LLCs, Sotnikov  and Mazitova  claimed  that the Relief
Defendant LLCs they created and controlled  were engaged in  legitimate  businesses:
a. Great Imperial -  “Marketing  Consulting”   in  the  “P rofessional,  Scientific,  and
Technical  Services” industry   and “prefabricated  wood building  manufacturing”
(Bank account opening  documents);
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b. Inteko  Cargo  – “Transportation   and  warehousing”  (Bank account  opening
documents);  and
c. HRC Clearing – “[C]ustomer computer  programming   services” (Bank  account
opening  documents).
But again,  upon  information  and belief  based on available  bank records, the Relief  Defendant
LLCs created by Sotnikov  and Mazitova  were not  engaged  in  any  legitimate   business  activity.
Instead, they were used by Sotnikov  as conduits  for his  transfer of investor  funds initially
received into  the Defendant LLC bank accounts.  And as with  the Defendant LLCs, each of the
Relief Defendant LLCs was based in a residential  apartment or condominium  in the Miami
Beach area, including  several at the same address, one  of  which  is  Sotnikov’s personal  residence.
35. Sotnikov opened  and  controlled bank accounts on  behalf  of  the  Defendant  LLCs,
other than BO&SA, into  which  investors  were  instructed  to  wire  their  funds,  and  opened  and
controlled  bank accounts on behalf  of the Relief Defendant LLCs, other than Great Imperial,  into
which  investor  funds  were  ultimately   transferred.

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  Relief Defendant Mazitova  is listed  in state incorporation  records as having  organized  Relief
Defendant Great Imperial.   Defendant BO&SA was organized  by Sotnikov  and two other
individua ls.   The other Defendant LLCs and Relief Defendant LLCs were organized  by
Sotnikov.

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36. After investor  funds  were wired into  accounts  nominally   owned  by  the  Defendant
LLCs,  Sotnikov   laundered  the  funds by transferring  money to accounts he or Relief  Defendant
Mazitova  controlled  that were nominally  owned by the Relief  Defendant LLCs, including
accounts in  the names of Great  I mpe r ia l,  HRC Clearing,  and  Inteko  Cargo,  or to other accounts
at   overseas banks.  Some of the investor  funds received into  accounts controlled  by Sotnikov  and
nominally  owned by the Defendant LLCs were ultimately  transferred to overseas accounts, either
directly  or after one or more transfers through  bank accounts controlled  by Sotnikov  and
nominally  owned by the Relief  Defendant LLCs:
37. In addition  to transferring funds between the various  LLC accounts,  and
transferring  funds  overseas, Sotnikov   also  transferred funds to  his  and  Mazitova’s  personal  bank
accounts,  and  used  those  funds to pay for personal  items,  such as doctors’ bills,  jewelry  and
vacations.
38. Sotnikov   also  transferred  funds  from  his  personal  bank  account  and  the  R e lie f
Defendant LLCs’ accounts he controlled  into  Defendant LLC accounts he controlled.
III. Spoofe d B ank 1 – Sotnikov and DN Indus trial
39. Defendants Sotnikov and DN Industrial  were instrumental  in an iteration  of the
spoofing  scheme  targeting Spoofed  Bank 1, a real bank headquartered in  C a lif or nia.
40. Sotnikov  formed Defendant DN  Industrial   in  Florida   on  July  26,  2018,   listing
himself  as the sole manager of the company.
41. On  August  9,  2018,   Sotnikov   opened  an account at a w e ll-known national  bank
(“Bank  1”) in the name of DN Industrial.  In the account opening  documents, Sotnikov  claimed
that DN Industrial  was in the “industria l construction  business  equipment  business.”    On

14

December  6,  2018,   Sotnikov   opened  an account at another major  national  bank (“Bank 2”) in  the
name of DN Industrial.   Sotnikov  had sole signatory  authority over  each of these bank accounts.
42. Upon information  and belief, DN Industrial is  not  a  clearing  firm,   nor  does  it  offer
or   s e ll le gitima te  CDs or other securities.    Bank records demonstrate  that Sotnikov  used DN
Industrial’s  bank  accounts for personal  purposes.  For example,  in  addition   to  transferring  money
from DN Industrial’s bank accounts  into  his  personal  accounts, he also  transferred money from
his  personal  accounts into DN Industrial’s  accounts on several occasions.   And on January 14,
2019, Sotnikov used a check card linked  to DN Industrial’s  Bank 2 account to pay $599  to a
service provider  to fly  an aerial banner over  a South  Florida  beach that r e a d “N a ta lia   w ill  you
marry me Denis.”
43. In February 2019,  the perpetrators of the spoofing  scheme created several
websites spoofing Spoofed  Bank 1,  in  order  to lure investors  into  purchasing  fictitious   CDs.
44. The domain names for these spoofed websites were designed  to  closely
approximate Spoofed  Bank 1’s real domain  name,  using  techniques  such as adding  initials  after
the real domain  name,  and the content of the websites was designed  to  mimic  a real bank
offering  CDs to  investors.
45. Each domain  name  created as part of the scheme to spoof Spoofed  Bank 1 was
registered  in  the  U.S.  by  an individua l using the name of a real registered representative
employed  by  Spoofed  Bank  1 who, upon  information  and belief,  was  not  involved   in  the  scheme
( “A lia s   1” ) .  The  person who registered the domain  name paid the domain  registrar to create an
email  account with an address using  the names of A lia s   1 and Spoofed  Bank 1 (“Email  Address
1”) to communicate  with investors,  and provided  a business address of 601  S. Figueroa  Street,
Los Angeles,  California.

15

46. On February 11, 2019, a prospective investor

viewed one of the spoofed websites,
which used a domain  name that was a slight  variation  on Spoofed Bank 2’s real domain  name
(“Spoofed  Website  1”),  and which  offered  no  penalty,  above-market-r a te   C D s  w ith  a  minimum
deposit  of $200,000,  and inquired  about investing  in  a nine-month  jumbo  CD.
47. The investor received  an  introductory  email  from Ema il  Address 1, signed  by  an
individua l using A lia s   1,  and c la iming  to be a “Senior Account Executive” at Spoofed Bank  1.
48. In the email,  the person  using  A lia s   1 provided the potential  investor  with a real
FINRA CRD number belonging   to   the real registered  investment  advisor  a f f ilia te d  w ith  Spoofed
Bank 1 in  New Mexico,  whose name matched Alias  1.
49. The email from  the person using A lia s   1 instructed  the  potential  investor  to
complete  and submit the attached “C D   a pplic a tion,”  which  required  the  potential  investor  to
provide   personally   identifiable   information   (“P II”),  including   a  Social   Security  Number  and  his
mother’s  maiden  name.  The email  also  f a ls e ly  stated that the  entity  offering   the  CDs:
[I]s a Registered FDIC Institution.   Securities offered through [Bank 1] & [Bank
2]. DN Industrial LLC Clearing or CM International – Member FINRA/SIPC.
Investment  Advisory   Services  offered  through  [Spoofed  Bank  Alias  1] Los
Angeles.

(e mphasis  added).
In fact, DN Industrial  was not a clearing  firm,  nor did  it offer or sell  le gitima te    C D s   or   othe r
securities,  and  “Spoofed  Bank  Alias  1,” named in  the email  and  using  a  slight  variation  on
Spoofed  Bank 1’s name,  was not  a real,  FDIC-insured bank.
50. In addition  to the CD application,  the introductory  email  from A lia s   1 a ls o
attached a fictitious  CD Term Sheet, an example of FDIC coverage, a spoofed “Statement  of
Condition,”  which  included  a  spoofed picture  and  statement  from  the  spoofed  bank’s  purported
CEO, and a spoofed summary of the bank’s assets and liabilit ies.   The spoofed “Statement  of

16

Condition”  was  copied  nearly  verbatim   from  the Statement of Condition  of the real Spoofed
Bank 1, but  provided   a  different  picture  and  mis ide ntif ie d  Spoofed  Bank 1’s    CEO.
51. V ia   e ma il,   the potential investor  asked the person using A lia s   1  to  provide  the
FDIC number
10
  of Spoofed  Bank  Alias  1,  as he was unable  to find  the bank on the FDIC’s
website.  The person using A lia s   1  responded by e ma il,  providing the FDIC number for the real
Spoofed  Bank 1,  headquartered  in  California.
52. The suspicious  potentia l  inve s tor   forwarded his communications  with the person
using A lia s   1 to the real Spoofed  Bank 1.  Shortly  thereafter,  on  February  13,  2019,  Spoofed
Website 1 was suspended  by  its  domain-name  registrar.
53. Another potential investor was not  so fortunate.   On  February  12,  2019,   when this
investor  emailed  the person using A lia s   1 to ask why  his  funds  would  not  be  “sent  directly  to”
the  bank  listed  on  the  spoofed website, the person using A lia s   1 responded as follows:
The funds clear through the [Bank 1] clearinghouse (DN Industrial LLC) for the
sole purpose to facilitate  the exchange of payments,  and secure the purchaser . . . .
The clearing  house stands between two parties (also known as member firms  or
participants  of FDIC).  Its purpose is to eliminate  the  risk  of,  and  honor  settlement
obligations   in  larger  transactions.

(emphasis  added).
54. On  February  15,  2019,   based on the assurances provided  by the person using
A lia s   1,  and  believing  that  he was buying  a legitimate  CD based on the information  provided  on
Spoofed  Website  1,  this  investor  wired  his  life  savings  of  $250,000   to  DN  Industrial’s   Bank  2
account – an account opened and controlled  by Sotnikov.

10
  The FDIC assigns  a registration  number  to each bank  or savings  association  it  insures.   The
“BankFind”   tool  on  the  FDIC’s  website  allows  visitors   to  obtain  information   about  all  FDIC-
insured  institutions   based  on  a  bank’s  name and/or FDIC number.

17

55. Within   days  after  the investor’s $250,000 w ir e was received  into  DN Industrial’s
account at Bank 2,  rather than providing  the investor  with the promised  CDs, Sotnikov made a
series of fraudulent transfers that depleted  the investor’s  funds:  (i) on  February  21,  2019,  he
w ir e d  $100,000  to an account at a Hong Kong bank;  ( ii)   on  February  21,  2019  and  February  22,
2019,   he  wired  a  total  of  a lmos t  $40,000  to  his  and Relief Defendant Mazitova’s joint  checking
account at Bank 2;  and ( iii)   on  February  22,  2019,  he  wired  $130,000  to an account at Bank  2 in
Relief Defendant  Inteko  Cargo’s name, an account he opened and  controlled.    Later on  February
22,  2019,  Sotnikov transferred $43,000  from the Inteko  Cargo account into his  and  Mazitova’s
personal  joint  checking  account at Bank 2,  and  then  transferred  $30,200   from  his  and  Mazitova’s
joint  checking  account back into DN Industrial’s  Bank  2 account.
56. With  Spoofed  Website  1 suspended,  the perpetrators turned to the other domain
names related to Spoofed  Bank 1 that they had previously  registered to continue  the scheme.
Like   Spoofed  Website  1, these spoofed websites offered no penalty,  above-market-rate CDs with
a minimum  deposit  of $200,000.   The website also claimed that Spoofed  Bank  Alias  1  was a
“Member FDIC” and had offices located at 601 S. Figueroa  St., Los Angeles,  California.
57. In  late  February  2019,  upon  inquiring   about  the CDs offered on  these websites,  at
least four  elderly  retired  investors  received  the  same introductory   email  from  the person using
A lia s   1,  including   the   following   language:    “Securities offered through [Bank 1] & [Bank 2]. DN
Industrial LLC  Clearing or CM International – Member FINRA/SIPC” (emphasis  added).
These emails attached the same CD application  as that used earlier in the scheme.  On February
25,  2019,  after returning  the completed  applications, each investor  received an e ma il  f r om  the
person  using A lia s   1,  containing  the  Bank 2 logo  and  welcoming   them  to “[Spoofed  Bank Alias
1] . . . Cleared by [Bank 2] DN Industrial LLC” (emphasis  added).

18

58. The emails received by these investors also  stated that their CD accounts were
“now  active  and  ready  for  funding,”   and  attached  wire  instructions  to fund  their  CD accounts
“with  our  clearing  partner  [Bank 2].”  Like the previous  wire instructions,  these instructions
directed  the  investors  to  wire  their  funds  to  DN Industrial’s  Bank 2  account,  and identif ie d   D N
Industrial  as:    “DN Industrial  LLC . . . A [Bank 2]  Company”  and  “Member  FINRA  Member
FDIC.”  In fact, DN Industrial  is not a FINRA or FDIC member,  its bank accounts are controlled
by  Sotnikov,   and  the  only  business  activity   observable  from  its  banking  records is the laundering
by  Sotnikov   of  funds  received  from  duped  investors.    Further,  Bank  2  had  no  knowledge  of  or
involvement   in  the  scheme,  and  DN  Industrial   was  not  a  “[Bank  2]  company,”   but  rather  simply
had an  account  at  Bank  2.
59. On February 25, 2019,  an elderly couple wired $383,000  to the DN Industrial
account at Bank 2  controlled  by  Sotnikov  after receiving  the CD application   and wire
instructions  from  the person using A lia s   1.  Rather than providing  the investor  with  the promised
CDs, Sotnikov  made a series of fraudulent  transfers that rapidly  depleted  the investor’s  funds.
On  February  26,  2019,   the day after the investor’s  wire was received,  Sotnikov   transferred
$382,900  of the investor’s  funds to another account he controlled – R e lie f   Defendant Inteko
Cargo’s account  at Bank 2.  Two days later, Sotnikov  transferred $35,000  from that Inteko Cargo
account to his and Relief  Defendant Mazitova’s  joint  checking account  at Bank  2, some of which
was used to make purchases at a luxury  jewelry reta ile r  and a luxury  clothing and accessories
retailer.
60. On February  28,  2019,  after  being  contacted  by  the  person  using  Alias  1,  another
e lde r ly  investor wired  $200,000   into  the DN Industrial  account  at Bank 2 controlled   by  Sotnikov.
A ga in,  rather than providing  the investor  with the promised  CDs, Sotnikov  made a series of

19

fraudulent  transfers that rapidly  depleted  the investor’s  funds.  The day after the investor’s  funds
were received,  March 1, 2019,  Sotnikov  wired $171,880 of that investor’s funds  from  DN
Industrial’s  Bank 2 account to  an account  at a Turkish  bank with  the  following   payment  detail:
“PMNT FOR EQUIPMENT INVOICE 37 POPSERVICES.”
61. Shortly  after  each investor’s funds  were  received  into  Sotnikov’s  DN Industrial’s
Bank 2 account controlled  by Sotnikov,   each investor  received  a fictitious  account  statement
from  “[Spoofed  Bank  Alias  1] FDIC,”  via  email  from  the person using A lia s   1.  Although  each
investor’s  funds had in  fact been rapidly  depleted  by Sotnikov,  the fictitious  account statements
reflected each investor’s  purported “opening  balance,”  “interest  earned” and “credits”
reimbursing   them  for  their  wire  transfer  costs.
62. On  February  26,  27  and  28,  2019  Sotnikov   wired  a  total  of  $15,000   to  a  leading
provider  of Internet search and  advertising   services,  using  funds  from the same DN Industrial
Bank 2 account that received the investors’  funds.    Records obtained  from that provider indicate
that these payments were made to purchase advertising that  directed  potential   investors  to  at  least
one of the spoofed websites described below.
IV. Spoofe d B ank 2 – Sotnikov and DN Indus trial
63. Defendants Sotnikov and DN Industrial  were also  instrumental   in  another
iteration  of the spoofing  scheme targeting Spoofed Bank 2, a real bank headquartered in Green
Bay,  Wisconsin.
64. By early March 2019,  the perpetrators began spoofing Spoofed Bank 2,  again
directing  investors  to  wire  money  to  a DN Industrial  bank account controlled  by Sotnikov.
65. On March 4, 2019, a  person  using  Alias  1,  s till   us ing  the   601 S. Figueroa  Street
address in Los Angeles and spoofed Email  Address 1,  registered a domain  name  using  a slight

20

variation  on Spoofed  Bank 2’s name (“Spoofed  Website 2”).  The domain  registration fee was
paid w ith  a prepaid  gift  card purchased a day earlier  at a grocery store in  I r vine ,  C a lif or nia .
66. The new website claimed  to offer above-market-rate CDs from “[Spoofed  Bank
A lia s   2], Member FDIC,” with  no penalties  and a minimum  deposit  of $200,000.   The website
claimed  that  Spoofed  Bank  Alias  2  w a s  a f f ilia te d  w ith another bank w ith  a slightly   different
variation  on Spoofed  Bank 2’s name (“Spoofed  Bank Alias  3”) and claimed  that  Spoofed  Bank
A lia s   3  had offices at 601 S. Figueroa  Street,  Los Angeles,  California.    In fact, neither Spoofed
Bank Alias  2 nor Spoofed  Bank Alias 3 was a real,  FDIC-insured  bank.
67. The documents  and correspondence used for the Spoofed  Bank 2 iteration  of the
scheme were nearly identical  to those used in  the Spoofed Bank 1 iteration  of the scheme.  The
introductory  email  to potential  investors  was again  signed  by the person using A lia s   1.  He stated
that he was a “Senior  Account Executive,”  provided  the  FINRA CRD number  of the real person
with the same name as Alias 1,  and attached a nearly  identical  CD application.   In this iteration
of the scheme, however,  the person using A lia s   1  claimed  to be associated with  “Spoofed  Bank
A lia s   4,”  another  slight   variation   on  Spoofed  Bank  2’s  name,  and provided  the FDIC number  of
the real Spoofed  Bank 2.
68. After completing   and   submitting   the   application,   investors   received a “welcome”
e ma il  f r om  the person using A lia s   1,  stating  that the investor’s CD account was “now  active and
ready for funding,”  and attaching wiring  instructions  “with  our clearing  partner DN Industrial,
LLC and [Bank  1] to fund” the CD.  The wire instructions   directed  investors  to  fund  their  CD
“account with DN Industrial,  LLC” by wiring  money  to DN Industrial’s  Bank 1 account,  an
account controlled  by Sotnikov.   The wire instructions for  DN Industrial’s Bank 1 account used
the real Bank  1 logo  and  ide ntif ie d  D N   I ndus tr ia l  a s   “DN Industrial  LLC . . . Member FINRA

21

Member  FDIC.”  In fact, upon  information  and belief, none of the spoofed bank  alia ses are
associated with  a real,  FDIC-insured bank,  and  DN Industrial is   not  a clearing  firm,  is  not  a
FINRA or FDIC member,  and it does not offer or sell  legitimate  CDs or other securities.  Instead,
DN Industrial’s  bank  accounts  are  controlled   by  Sotnikov,   and  the  only   business activity
observable  from  DN Industrial’s  banking  records is the laundering  by Sotnikov  of  funds  received
from  duped  investors.
69. Between March 22  and March 27,  2019,  at least three additional investors  wired  a
total  of  $990,000   to  DN  Industrial’s   bank  accounts  in  connection   with  the  iteration  of the scheme
related to Spoofed Bank 2.
70. On March 22, 2019,  two married  investors  wired $250,000  to DN Industrial’s
account at another well-known   national   bank  (“Bank  3”),  and  another  investor  wired  $240,000   to
DN Industrial’s Bank  1  account,  an  account  controlled   by  Sotnikov.     And  on  March  27,  2019,   the
same married couple  invested an additional  $500,000  by wiring  the funds to DN Industrial’s
Bank 3 account,  another  account  controlled   by  Sotnikov.
71. Within  days  of receiving  these investor  funds,  rather than providing  the investors
with the promised  CDs, Sotnikov fraudulently transferred a substantial portion  of  the investor
funds  received  into DN Industrial’s Bank  1 account to other accounts that he and his wife
controlled:    On  March 27,  2019,  he transferred $25,000  to an account in  his wife’s name at a
Russian  bank;  on March 28 and 29, 2019, he transferred a total  of $35,000  to the Bank 1 account
of Inteko  Cargo, which  he controlled;  and on April  1, he transferred $8,200  to Expe r t  D igita l’ s
Bank 1 account, another account he controlled.
72. Also  on  April  1,  2019,  Sotnikov  transferred  $16,500  from  Inteko  Cargo’s Bank  1
account to Great Imperial’s  Bank 2 account,  and transferred another  $8,000  from  Expert

22

D igita l’s Bank 1 account to Great Imperial’s Bank  3 account.  Relief Defendant Mazitova,  who
organized  and  controls  Great Imperial,  proceeded to  transfer a majority  of  those  funds  to her
personal savings  account  over the next several days.
73. On April  3, 2019,  Sotnikov  transferred an additional  $10,500  from DN
Industrial’s Bank 1 account  to  Inteko  Cargo’s  Bank 1 account, and transferred $14,100  from DN
Industrial’s Bank 1 account to Expert Digital’s Bank 1 account.  Shortly  thereafter, Sotnikov
transferred  $13,100   from  Expert  Digital’s  Bank  1 account to Great Imperial’s Bank 3 account,  an
account controlled  by Relief  Defendant Mazitova.
74. Also  on  April  3,  2019,   Mazitova  used  funds  from  Great  Imperial’s  Bank 1
account for purchases at a cell phone provider  and department  store, and  transferred $15,000  to
her  personal  savings  account  at Bank  3.
V. Spoofe d B ank 3 – Sotnikov, Expe rt Digital, and  B O&SA

75. Defendants Sotnikov,  Expert Digital,  and BO&SA were instrumental  in  another
iteration  of the spoofing  scheme targeting  a bank headquartered in  St. Louis,  Missouri  (“Spoofed
Bank 3”).
76. On  September  12,  2018,   Sotnikov   formed  Expert Digital  in  New York.  Two days
later,  Sotnikov   opened  an account for Expert Digital at Bank  1, over which  he had sole signatory
authority.    In  the  account  opening  documents,  Sotnikov  described  Expert  Digital  as  being  in  the
“IT  consulting,   computer,  technology   and  program  consulting”   business.    He  listed   three
companies  based  in  Kazan,  Russia  as  being  Expert  Digital’s   major  suppliers,   and  claimed  that  his
major  customers were primarily   retail-based.    On  December  7,  2018,   Sotnikov   opened  another
account for Expert Digital  at Bank 2, over which  he again had sole signatory  authority.

23

77. On December 6, 2018,  Sotnikov  and two other individua ls  formed Defendant
BO&SA in  Florida.    BO&SA’s business was described  as the “development  and sale of software,
provision  of virtual  space for sales representatives, [and] development  of web resources.”  On
March 28, 2019,  an account was opened in  BO&SA’s name at   another  well-known  national  bank
(“Bank  4”).
78. Although  Sotnikov  was not BO&SA’s sole organizer  or control  person, as he was
with  the  other  Defendant  LLC’s,  he  served  as  either  president  or  vice  president  of  BO&SA  of
from December  10,  2018  through  March  13,  2019,  and  from  May  21,  2019  through  August  2,
2019.
11
    In addition, BO&SA’s address was lis te d  in  corporate records as 1201  S. Ocean Drive,
2107  S, Hollywood,  FL  33019 – the same address as that of three of the other Defendant LLCs
organized   by  Sotnikov  – Expert  Digital,  DN Industrial,   and  AGQ  Business  Group.
12
    In addition,
a significant  portion  of the investor  funds  wired  into  BO&SA’s account  was transferred to  Relief
Defendant HRC Clearing,  an entity  controlled  by Sotnikov.
79. As  noted  above,  on  February  26,  27  and  28,  2019,  Sotnikov  wired  a total  of
$15,000  to a leading  provider  of Internet search and advertising  services.  Records obtained  from
that provider  indicate  that the payments  were for advertising  that directed potential  investors  to at
least one of the spoofed websites related to this iteration  of the scheme.
13

11
  Sotnikov was removed as an officer of BO&SA shortly  before BO&SA opened a bank
account at Bank 4 that received investor  funds,  and was later re-installed  as an officer of
BO&SA.
12
  Account opening  documents  submitted  to Bank 4 listed  a different address for BO&SA –
18401  Collins   Ave., Apt. 1243,  Sunny  Isles Beach, FL 33160 – the same street address as Relief
Defendant Great Imperial,  albeit  with a different  apartment number.
13
  These payments  were made with  funds  from  DN Industrial’s  Bank  2 account,  the same
account that received investor  funds from an earlier  iteration  of the scheme involving  Spoofed
Bank 1.

24

80. Beginning  in  late February 2019,  the  perpetrators began using  websites  spoofing
Spoofed  Bank 3.  In certain instances, they directed  investors  to  wire  money  to  Expert Digital’s
Bank 1 account,  an  account controlled  by Sotnikov.     In  other  instances,  they  directed  investors  to
wire money  to BO&SA’s Bank 4 account.  Although  Sotnikov  was no longer  listed  as an officer
of BO&SA as of late February 2019, corporate records listed  the managing  members of BO&SA
as two individua ls   who were officers of BO&SA at the same time as Sotnikov.
81. Between mid-March 2019 and May 2019, using  four different  domain-name
registration  providers  based in  the U.S., Russia and Israel, the perpetrators registered at least six
domain  names designed  to convince  investors  that they were dealing  with the real Spoofed  Bank
3 by using  slight   variations   on  the  bank’s  name.  The domain  names registered in  the U.S. were
again  registered  by  an individua l using A lia s   1,  and were paid  for  using  two  prepaid  gift  cards
purchased at a grocery store in California.    In registering  the domain  names, the person using
A lia s   1  again ide ntif ie d  his business  address as 601 S. Figueroa  Street, Los Angeles,  C a lif or nia.
82. Like  the  previous   websites,  these new websites offered no penalty,  above-market-
rate CDs with a minimum  deposit  of $200,000,  claimed  that the fictitious  offering  bank was a
“Member  FDIC,”  and  claimed that deposits  were FDIC-insured.   The websites also claimed  to
use real U.S. banks  (Bank  1,  Bank  2,  and  Bank  3) and other entities  as “clearing  partners.”
14

83. Investors who inquired  about the CDs offered on these Spoofed  Bank 3-related
websites received an introductory  email  from an email  address that featured Alias 1 and Spoofed
Bank 3 (“Email  Address 2”).  For  example,  an  investor  and  a  prospective  investor  received
emails  on  May  8,  2019 c la iming  that the person using A lia s   1  was a “Senior  Account Executive”

14
  The websites again used the same business  address – 601 S. Figueroa  Street, Los Angeles,
C a lif or nia   – used previously  by the person  using  Alias  1.

25

at   Spoofed  Bank 3 and again provided  the FINRA CRD number  of the real person  with  the  same
name as A lia s   1’s and Spoofed  Bank 3’s real FDIC number.
15

84. The email  also attached a CD application nearly identical  to that used in the prior
spoofs,  stating  that  the purported  bank “is a Registered FDIC Institution.   Securities offered
through [Bank 1], or [Bank 4], Expert Digital LLC or BO&SA Clearing – Member
FINRA/SIPC.  Investment  Advisory   Services offered through [Spoofed  Bank A lia s   4]” (e mphasis
added).
85. In fact, upon information  and belief, “Spoofed Bank A lia s   4,” named  in  the e ma il
and using  a slight  variation  on  Spoofed  Bank  3’s name,  is not a real, FDIC-insured bank,  neither
Expert  Digital   nor  BO&SA is   a c le a r ing  f ir m,  and neither  LLC offers or   s e lls   le gitima te  CDs or
any other securitie s .
86. After submitting  the completed  application,   investors  again  received a “welcome”
e ma il  f r om  the person using A lia s   1,  explaining   that  their  CD  accounts  were  “now  active  and
ready for funding”  and attaching  wire instructions.
87. An  email  and  wiring  instructions   sent  to  at  least  one  investor  on  May  8,  2019
claimed  that  the bank’s transactions  were “Cleared  by  [Bank  1] through  Expert  Digital   LLC
Clearing”  and instructed  investors  to wire funds to Expert Digital’s Bank 1 account.  As noted
above,  Expert  Digital   is  not  a  clearing  firm.    Its  bank  accounts  are  controlled   by  Sotnikov,   and
the only  business  activity  observable  from its banking  records is the laundering  by Sotnikov  of
funds  received  from  duped  investors.

15
  Upon  information   and  belief,  the  real  registered  representative  impersonated   by  the  person
using  Alias  1 has no business  relationship  with the real Spoofed  Bank 3.

26

88. Wire  instructions   sent  to  two  other  investors  on  May  15,  2019  instructed the
investors  to  wire  their  funds  to  “BO&SA  Corp.  Clearing  through  [Bank 4].”  The wire
instructions  used  Bank 4’s logo,  and stated “BO&SA Corp.  Clearing  through [Bank 4]” and
“Member  FINRA.”  As  noted  above,  BO&SA  is  not  a c le a r ing  f ir m,  nor  is  it  a  member  of
FINRA.  Instead,  BO&SA was organized  by  Sotnikov and two other individua ls,  and the only
business  activity  observable  from  BO&SA’s banking  records is the laundering  of funds received
from  duped  investors.
89.   In May 2019,  three investors  wired a total  of $850,000  to Expert Digital’s Bank
1 account,  an  account  controlled   by  Sotnikov.   One investor  wired $200,000  on May 8,  2019,
and two  investors  (a husband  and wife) wired $650,000  on May 9,  2019.    On May 8, Sotnikov
transferred $70,000   from  Expert  Digital’s   Bank  1  account  to  Inteko Cargo’s Bank 1 account.
Shortly  thereafter, Expert  Digital’s Bank 1 account was frozen.
90. Also  in  May  2019,  three additional  investors  wired  a  total  of  $407,000   to
BO&SA’s Bank  4 account.  One investor  wired  $207,000   on  May  13,  2019,  and two other
investors  (again a husband  and  wife)  wired  $200,000   on  May  16,  2019.   Of the $407,000  in
investor  funds  wired into BO&SA’s Bank  4  account,  $228,000 was sent to an account at another
w e ll-known  national  bank (“Bank 7”) in  the name of Relief  Defendant HRC Clearing,  another
entity  controlled   by  Sotnikov  – $50,000  by wire on May 15,  2019,  and $178,000  by check dated
June 10,  2019.  Sotnikov  used certain of the funds transferred to HRC Clearing  to pay for a trip
to New York  City.   On June 5, $150,000 was transferred from BO&SA’s Bank  4 account to
Sotnikov’s  personal  account  at another  w e ll-known   national   bank  (“Bank  5”).  On June 10,  2019,
$20,000  was transferred from  BO&SA’s Bank  4  account  to  Relief Defendant Great Imperial’s
Bank 5 account, an account controlled  by Relief  Defendant Mazitova.  She subsequently  used

27

funds from  Great Imperial’s  account to pay for personal medical services and a purchase at a
luxury  goods  retailer.
VI. AM R B us ine ss Group/ATL Busine ss Group Spoofs  – Sotnikov, Adaptive
Technology, and ATL B us ine ss Group

91. Defendants   Sotnikov,   Adaptive   Technology,   and   ATL Business Group were
instrumental  in the next iteration  of the spoofing  scheme.
92. On  November  7,  2019,   Sotnikov   formed  Defendant  Adaptive  Technology as a
Wyoming  LLC,  providing   his  Florida   address as the business  address and  naming  himself  as the
manager.  On November 27,  2019,  Sotnikov  opened a bank account for Adaptive  Technology  at
Bank 5.  The account opening  documents claimed  that the company’s  purpose  was to provide
“custom  computer programming  services” and that it “create[d] apps for Apple  and other
companies.”    Sotnikov  had sole signatory  authority  over the account.
93. On  November  25,  2019,  Sotnikov   formed  another  Wyoming   LLC,  Defendant
ATL Business Group,  using  the same Florida  address as Adaptive  Technology,  and again
naming  himself  as manager.  On December 27,  2019,  Sotnikov  opened a bank account for ATL
Business  Group at Bank 5,  c la iming  in  account opening  documents  that ATL Business Group
LLC  also  provided   “customer  computer  programming   services.”  Sotnikov   had  sole  signatory
authority  over the account.
94. Starting  in  January 2020,  the perpetrators modified  their scheme, but continued  to
use websites offering  fictitious  CDs to investors.    Rather than spoofing  real banks and brokerage
firms,  however,  the  perpetrators  created  multiple   websites,  often  using   fictional   financial   firms.
They also created at least one website using  the name of Defendant ATL Business Group,  an
entity  organized  and controlled  by Sotnikov,   and  at least three of the websites in this  iteration  of

28

the scheme employed  Defendant LLCs organized  and controlled  by Sotnikov  to receive investor
funds.
95. Other than moving  away from spoofing  the websites of actual,  legitimate U.S.
financial  institutions ,  the scheme generally  remained unchanged.   After accessing the spoofed
website, the investor received an email from a fake account executive  impersonating   a real
registered investment  adviser.  The email  stated that the “securities  were  being  offered”  by  one
of the Defendant LLCs organized  and controlled  by Sotnikov,  and attached a CD account
application.   After submitting  the completed  application,  the investor  received instructions  to
wire their  funds to an account in  the name of the Sotnikov-contr olled   entity;  and  upon  receipt  of
the funds into  the account, the investor  received a fictitious  account statement reflecting  their
opening  balance.
96. On January 6, 2020,  the perpetrators registered the domain  name
amrbusinessgroup.com  with  a Cyprus-based  domain  registrar and created a website for AMR
Business  Group,  which appears to be a fictitious  entity.  The  website  did  not  spoof  an  actual
financial  institution,   but  mimicked  a website of a   r e a l  f ina nc ia l   ins titution.      The website false ly
claimed  that AMR Business Group  was “an insured  FDIC institution”  and “FDIC Member,” that
offered jumbo  CDs.  The website repeated many of the same specific  phrases the perpetrators
had  used  in  many  of  their  previous  websites,  inc ludin g  offering  no penalty,  above-market-rate
CDs.
97. The following  day, on January 7, 2020,  the perpetrators registered the domain
name — atlbusinessgroup.com — corresponding  with  the Wyoming  LLC Sotnikov  had
organized six weeks earlier.  The domain  was registered with a Russia-based domain  registrar.
The ATL Business Group  website  that subsequently  appeared in this  iteration  of the scheme was

29

practically  identical  to  the  spoofed AMR  Business  Group  website,  using  the  same  business
telephone  number  and address and s imila r   text.
98. On January 8, 2020,  an investor expressed interest in the CDs being  offered by
either AMR Business Group or ATL Business Group  and received an email  with  an attached CD
a pplic a tion  from  an e ma il  address (“Email  Address 3”) that used the name of a real person who
worked  as an investment  adviser  at an affiliate  of Bank 5 who,  upon information  and belief,  had
no  knowledge  of  the  scheme ( “A lia s   2” ).  The person  using  Alias  2  claimed  to  be a “Senior
Account Executive” at “AMR Wealth – [Bank 5] Group,”  and provided   a  Los  Angeles  address
for a Bank 5 branch,  Bank 5’s actual FDIC number,  and the real registered investment  advisor’s
FINRA CRD number.   In  fact, the spoofed domain  name and the Ema il Address 3 account  had
been registered by the perpetrators on  January 6,  2020.
99. After receiving  the email,  the investor  completed  and  submitted  a CD application
identical   to  the  previous applications,  with  the exception that this version  of the CD application
used Bank 5’s logo.   The very  next  day,  the  investor  received  a welc oming  e ma il  f r om  the person
using A lia s   2 which,  like  the past iterations,  stated that  “your  account is now active,  and ready
for funding,”  and attached instructions to fund  the CD purchase by  wiring   funds  to  “our  clearing
partner Cleared by ATL Business  Group  LLC  through  [Bank 5].”  The wire instructions directed
the investor  to wire the funds to Defendant ATL Business Group’s  account at Bank 5, an account
opened  by  Sotnikov  just two weeks earlier  and for which  he had sole signatory  authority.
100. On January  10,  2020,  the  investor  wired  $250,000   to  ATL Business Group’s  Bank
5 account.  The  next  business  day  – Monday,  January 13,  2020 – the investor  received an
“account statement” showing his   opening  balance of $250,000,  as well as a $25 credit to refund
the investor’s  wire  transfer fee.

30

101. On January 13,  2020, Sotnikov   withdrew  $9,000  from  ATL Business Group’s
Bank 5  account and wired $20,000  to a corporate account at a Russian  bank.  On the same day,
Sotnikov   withdrew  $9,000   from  ATL  Business  Group’s  account  at a Bank 5 branch in
Hallandale  Beach, Florida.    On  January  14,  2020,  Sotnikov  wired  $215,000  to  Relief Defendant
Great Imperial’s account  at   Bank  3, an account controlled  by Relief  Defendant Mazitova.
102. The amrbusinessgroup.com  website was taken down  on January  13.
103. On January 21,  2020,  another investor  submitted  an account opening  application
to the person using A lia s   2 at Email  Address 3.  On January 21,  after the person using A lia s   2
confirmed ( f a ls e ly)  that the investor’s  CD  account had been opened,  the investor  wired $500,000
to  ATL Business Group’s  Bank 5 account,  an  account  opened  and  controlled   by  Sotnikov.
104. On January 21,  2020,  the same day the investor funds  were received into  ATL
Business  Group’s  Bank  5  account,  Sotnikov   withdrew  $5,000   from  the account at a Bank 5
branch  in  Sunny  Isles,  Florida.   On January 22,  2020,  Sotnikov  wrote a $470,000  check from
ATL Business Group’s  Bank  5  account for deposit  into  the Bank  4 account of Relief Defendant
Inteko  Cargo,  another  account controlled  by Sotnikov  in the name of an entity  he organized  and
controls.
105. On January 22,  2020,  the day after the investor’s  funds were received into  Relief
Defendant ATL Business Group’s  Bank  5 account, and as Defendants Sotnikov  and ATL
Business  Group were actively  depleting  the investor’s  funds,  the investor  received an “account
statement” showing  an “opening  balance” of  $500,000   and  a  $25  credit  to  refund the investor’s
wire fee.  The “account statement” did  not disclose  that Sotnikov  and ATL Business Group had
diverted  most of the investor’s  funds.

31

106. On January 27,  2020, two additional   investors  (a  married  couple)  received an
e ma il  f r om  the person using A lia s   2  at   Email  Address 3 that said “Thank  you  so  much  for
allowing  us to help you  with your recent inquiry  and account opening  procedures. . . . ATL
Wealth  Management  Group-[Bank  5]  is  a  full  service,  global  financial  institution.”    The email
attached an application  to open an account for a $200,000  Jumbo  CD with “ATL Wealth, A
[Bank 5]  Company – Member  FDIC.”  After completing  and returning  the application  to
purchase a $225,000  CD, the investors  received another email  from the person using A lia s   2
describing  “ATL  Wealth  Group”  as a “registered  FDIC Institution  of [Bank 5].”  Upon
information  and belief,  “ATL Wealth Group”  does not exist,  and Defendant ATL Business
Group is      neither  an FDIC member  nor an affiliate  of the real Bank 5.  Instead, Defendant ATL
Business  Group’s  bank  accounts  are  controlled   by  Sotnikov,   and  the  only  business  activity
observable  from  ATL Business Group’s banking  records is the laundering  by Sotnikov  of funds
received from duped  investors.
107. The following  day, January 28, 2020,  the investors  received a letter from A lia s   2
informing   them  that  “on  behalf  of  our  entire  ATL-[Spoofed  Bank  4]  & [Bank  5] staff,” their
application  had been approved and their account was now open.
16
  The letter claimed  that the
investors’  CD purchases were “cleared  by [Bank 2] through  Adaptive  Technology  LLC.”    And
the attached wire instructions  stated:  “Cleared by AMR Business Group  LLC  through  [Bank 4]”
and instructed the investors  to  wire  their  funds  to  Adaptive  Technology’s [Bank 2] account.
Defendant Adaptive  Technology  is not a clearing  firm,  nor does it offer or sell  legitimate  CDs or
other  securities.    Adaptive  Technology’s   bank  accounts  are  controlled   by  Sotnikov,   and  the  only

16
  This email  also used a name almost  identical  to that of a large financial  institution   offering
investment  banking  and other services (“Spoofed  Bank 4”), a firm that was featured in  a
subsequent iteration  of the scheme described  below.

32

business  activity  observable  from its banking  records is the laundering  by Sotnikov  of funds
received from duped  investors.
108. On January 27,  2020, Bank 5 closed Adaptive  Technology’s  account.
109. On January 28,  2020,  Sotnikov  opened a new bank account for Adaptive
Technology  at Bank 2.  Shortly  thereafter, the person using A lia s   2  used Email  Address 3  to
direct investors  to  w ir e   funds to the new Adaptive  Technology  account at Bank 2.
110. On January 28,  2020, after receiving  updated instructions  from  the  person  using
A lia s   2,  the  investors  wired  their  $225,000   investment  to Adaptive  Technology’s  new account at
Bank 2.  On  January  29,  2020,  the investors  received an “account  statement” showing  their
$225,000  depos it.
111. On January 30,  2020,  Sotnikov  transferred $22,500 from  Adaptive  Technology’s
Bank 2  account to a bank account in  Russia. Shortly  thereafter,  Adaptive  Technology’s  account
was  frozen  by  Bank  2.
112. Also  on  January  30,  2020,  the atlbusinessgroup.com  website  was taken down.
VII. Spoofe d B ank 4 – Sotnikov and Adaptive  Te chnology
113. Defendants Sotnikov  and Adaptive  Technology  were also instrumental  in the next
iteration  of the spoofing  scheme.
114. On or about on  January  28,  2020,  the perpetrators registered another  spoofed
website  with  a U.S. domain  registrar, using  a name almost  identical  to that of a large financial
institution  offering  investment  banking  and other services (“Spoofed  Bank 4”), and created an
email  account (“Email  Address 4”) that combined  the name of Spoofed  Bank 4 and the name of
a  real  broker  affiliated  with  Spoofed  Bank  4  who,  upon information  and belief,  had no
knowledge  of the scheme (“Alias  3”).

33

115. The website purported  to  offer high  interest rate CDs from Spoofed  Bank 4.  The
website  was similar  to the  previous  websites,  offering  no  penalty,   above-market-rate CDs.
However, unlike  the websites used  in  prior  iterations  of  the  scheme, this   website identified  Bank
2,  Bank  4,  Bank  5,  and  another  well-known   bank  (“Bank  6”),  a ll   le gitima te    U . S.   f ina nc ia l
ins titutio ns ,  as clearing  partner banks.  The website provided  the same telephone  number  as one
of the prior  websites and the same address as the real Spoofed  Bank 4’s Los Angeles office.
116.  Two potential  investors  found  the  website  through  an  Internet  search of  CD rates,
called  the number provided,  and  spoke  to  a  person  who  identified   himself  as  A lia s   3,  the name of
an actual registered investment  adviser at Spoofed  Bank  4.
117. On January 29,  2020,  one  of  the  investors  received  a  follow   up  email  from  Ema il
Address 4,  in  which  the  person  using  Alias  3  identified   himself  as a “Senior  Account Executive”
at   Spoofed  Bank  4,  and provided Spoofed  Bank 4’s real FINRA CRD number.
118. The  email  to  the  investor,  which  enclosed  a  CD account application,  stated that
the f ic titious  bank offering  the CDs “is  a  Registered  FDIC  Institution   of  [Spoofed  Bank 4].
Securities offered through Adaptive Technology LLC Clearing through [Bank 2].  Member
FINRA/SIPC.  Investment Advisory  Services offered through [Spoofed  Bank  4]” (emphasis
added).
119. In fact, Defendant Adaptive  Technology,  an entity  Sotnikov  formed three months
earlier  and that he controlled, was not  a clearing  firm,  nor did it    offer or   s e ll  le gitima te    C D s   or
other  securities.    Adaptive  Technology   had  no  affiliation   with  Spoofed  Bank 4 and no affiliation
with  Bank  2  other  than  maintaining  an account at Bank 2.
120. On January 29,  2020,  the  investor  returned the completed  application  to purchase
a $350,000  CD, and later that day received another email  from an individua l  using A lia s   3.  The

34

second email  stated that his  account was “now active,  and ready for funding”  and instructed  him
to  wire  his  investment   to  “our clearing  partner Cleared by [Bank 2]  through  Adaptive
Technology  LLC.”
121. The wire instructions directed  the  investor  to  send the funds to Adaptive
Technology’s  Bank 2 account, an account that  Sotnikov   had  opened  the  previous  day and that he
controlled.
122. Luckily,  the potential investor  conducted additional  due diligence  before
transferring  any funds pursuant  to the instructions  received from  the person using A lia s   3.  The
potential  investor  contacted  the real Spoofed  Bank 4 investment  advisor  whose  identity  was
being used by the perpetrators,  learned that the website was fake, and did not  wire  any funds  to
Adaptive  Technology.
123. The Spoofed Bank 4 website  was  taken  down  on  February  4,  2020 after Spoofed
Bank 4 complained  to  the  domain  registrar.
VIII. Spoofe d B ank 5 – De fe ndants  Sotnikov and AGQ B us ine ss Group
124. Defendants Sotnikov  and AGQ  Business  Group were instrumental  to  the latest
ite  ration  of the scheme,  which  is  markedly  similar   to  other  iterations   described  in  this  Complaint.
125. On February 3, 2020,  Sotnikov   formed  Defendant  AGQ  Business  Group,   listing
himself  as “manager”  in papers filed  with  the State of Florida.    On February 19,  2020,  Sotnikov
opened  a  bank  account  for  AGQ  Business  Group  at  Bank 3.  The account opening  documents
state  that  AGQ  Business  Group  is  in  the  “[f]looring   and  kitchen  construction”   business.
Sotnikov  has sole signatory  authority  over the account.
126. Based on  information  and belief  and available  bank records,  Sotnikov   is  a  36-
year-old  Russian  citizen   who  lives  in  Florida,   but  in  opening   the  Bank  3 account for AGQ

35

Business  Group,  he  f a ls e ly  claimed  to be a 34-year  old  Spanish  citizen  living   in  Milan,  Italy and
presented a false Spanish  passport.
127. On  February  11,  2020,  using  a  domain  registrar  in  Russia,  the perpetrators
registered  a  website  using  a domain  name  s imila r    to  tha t  of   a   w e ll-known  national  bank
(“Spoofed  Bank  5”).
128. The website described  high-interest-rate,  no-penalty  CDs with  a minimum   deposit
of $200,000  purportedly  offered by an affiliate  of Spoofed  Bank 5.  The website claimed  that all
accounts were FDIC-insured  and  that  deposits  in  those  accounts  were  maintained by Spoofed
Bank 5 and cleared by “[Spoofed  Bank  5] Clearing  Systems (DGQ & AGQ)”  (emphasis  added).
129. On  February  13,  two  investors  who inquired  about  the CDs offered on the website
received introductory  emails  from an individua l  claiming  to be a “Senior  Account Executive” at
Spoofed  Bank 5 and using  the name of a real registered investment  adviser employed  by an
affiliate  of  Spoofed  Bank  5  (“Alias  4”) who, upon  information  and belief,  had no knowledge  of
the scheme.  The person using A lia s   4 used the FINRA CRD number for the real investment
adviser of the same name.
130. The email  attached a CD application  nearly identical  to the applications used by
the perpetrators in  prior  iterations  of the scheme, and stated:  “Securities  offered through
clearing via DGQ, AGQ, & [Spoofed Bank 5] FDIC.  Member FINRA/SIPC.  Investment
Advisory  Services offered through [Spoofed  Bank  5] Direct Banking  Group  & Wealth
Management” (emphasis added).
131. After submitting a completed  application on  February  19,  the  investors  received
the standard welcoming  email  explaining  that their  CD account  was “now active and ready for
funding,”  and attaching  wire instructions.   The emails  and wiring  instructions from the person

36

using  Alias  4  claimed  that the CDs were “[c]leared by AGQ Business Group LLC through
[Bank 3]” (emphasis  added).  The wiring  instructions  directed the investors  to  wire  their  funds  to
the AGQ Business Group  account at Bank  3.From  February  21  to  26,  2020, six  investors  wired  a
total  of  $1,838,000   to  AGQ  Business  Group’s  Bank 3 account,  an  account  controlled   by
Sotnikov:     On  February  21,  2020,   two  investors  wired  $450,000;   on  February  25,  2020,   another
investor  wired  $232,000;   on  February  25,  2020,   another  investor  wired  $931,000;   and  on
February  26,  2010,   another  investor  wired  $225,000   into  the  account.  Within  a business  day of
wiring  their  funds,  investors  received  fictitious  “account statements” showing   their  opening
balance and a credit for the wire transfer fee.  At least one of the fictitious  account statements
included  an amount  for “interest  earned” in  the “account  balance.”
132. On February 21, 2020,  the two investors  wired  $450,000   to AGQ Business
Group’s  Bank 3  account.  On  February 24,  2020  these investors  received  a fictitious “account
statement” showing  their  “opening  balance,”  “interest  earned,” and a “credit”  for the wire
transfer fee.
133. On February 21, 2020,  two additional  investors  who had inquired  about the CDs
offered on the website received a similar  introductory  email  from the person using  Alias 4.  On
February  25,  2020,  after submitting   the completed  application,  these investors  received the
standard  welcoming  email  attaching  wire  instructions.     On  February  25,  2020,  these two
investors  wired  $931,000   to  the  AGQ  Business  Group  account.
134. On February 24, 2020,  another investor  who inquired  about the CDs offered on
the website received a similar  introductory  email  from a  person  using  Alias  4.  After submitting
the  completed  application,   this  investor  received  the  standard  welcoming   email  attaching  wire

37

instructions.   On February 25,  2020,  this  investor  wired  $232,000  to the AGQ Business Group
account at Bank 3, and received a fictitious  “account statement” on February 26,  2020.
135. Another investor  who inquired  about the CDs offered on the website received a
similar  introductory  email  from an individua l using  Alia s   4.  After submitting  the completed
application   on  February  25,  2020,  this  investor   received  the  standard  welcoming   email  attaching
wire instructions.   On February 26, 2020  this investor  wired $225,000  to the AGQ Business
Group  account at Bank 3, and received a fictitious “account statement” on February 27,  2020.
136. On  February  21,  2020,  Defendant Sotnikov  wrote a check for $250,000 from
AGQ Business  Group’s  Bank  3 account to Relief Defendant Inteko Cargo,  another LLC he
controls.   The check was deposited  into  an Inteko Cargo account  at Bank  5,  an account  opened
and controlled  by Sotnikov.   That same day, Sotnikov  wrote a check to himself  from the Inteko
Cargo account  at Bank  5 for $190,000,  which was deposited into  an unidentified  account at a
Florida  bank.    Upon  information   and  belief,  the  remaining   funds  in  AGQ  Business  Group’s
account at Bank 3 have been frozen.
FIRST CLAIM FOR RELIEF

Violations of Section 17(a)(1) and 17(a)(3) of the  Se curitie s  Act

(De fe ndants  Sotnikov, Adaptive  Te chnology, AGQ B us iness Gro up, ATL B us ine s s Group,
B O&SA, DN Indus trial, and  Expe rt Digital)

137.  The Commission  re-alleges  and  incorporates  paragraphs  1  through  136 a s  if   f ully
set forth  herein.
138. Sotnikov  and the Defendant LLCs, by use of the means or instrumentalit ies  of
inte r s tate commerce or of the mails,  in  the offer or sale of securities,  directly  or indirectly,  with
scienter, employed  devices, schemes, or artifices to defraud;  and/or  engaged  in  any  transaction,

38

practice, or course of dealing  which  operated or would  operate as a fraud or deceit upon  the
purchaser.
139. By reason of the actions  alleged  herein,  Sotnikov  and the Defendant LLCs
violated  Section  17(a)(1) and 17(a)(3)  of the Securities  Act [15 U.S.C. § 77q(a)(1),  (3)] and
unless  restrained  and  enjoined   will   continue  to  do  so.
SECOND CLAIM FOR RELIEF

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

(De fe ndants  Sotnikov, Adaptive  Te chnology, AGQ B us iness Group, ATL B us ine s s Group,
B O&SA, DN Indus trial, and  Expe rt Digital)

140. The Commission  re-a lleges and incorporates  paragraphs 1 through 136 a s   if   f ully
set forth  herein.
141. By engaging  in the conduct  described above, Sotnikov  and the Defendant LLCs,
with scienter,  by use of the means or instrumentalit ies  of interstate commerce, in  connection  with
the purchase or sale of a security:  (a) 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 conduct  which operated or would
operate as a fraud or deceit.
142. By reason of the actions  alleged  herein,  Sotnikov  and the Defendant LLCs
violated  Section  10(b) of the Exchange Act [15 U.S.C. § 78j(b)]  and Rules  10b-5(a) and 10b-5(c)
thereunder  [17  C.F.R. § 240.10b-5(a),  (c)] and unless  restrained and enjoined  will  continue  to do
so.

39

THIRD CLAIM FOR RELIEF
Aiding and  Abe tting Violations  of  Se ction 17(a) of the  Se curitie s  Act
(De fe ndant Sotnikov)
143. The Commission  realleges and incorporates  by reference each and every
allegation   in  paragraphs  1  through  136, inclusive,   as  if  they  were  fully   set  forth  herein.
144. Sotnikov,  by engaging  in  the conduct described above, singly  or in  concert,
directly  or  indirectly,   knowingly   or  recklessly  provided  substantial  assistance  to  the Defendant
LLCs,  each of which by use of the means or instrumentalit ies  of interstate commerce, or by use
of the mails,  in  the offer or sale of securities,  knowingly   or  recklessly  employed   devices,
schemes, or artifices to defraud; and knowingly,  recklessly  or negligently  engaged in
transactions,  practices, or courses of business  which operated or would  operate as a fraud or
deceit upon purchasers of securities.
145. By engaging   in  the  conduct  described  above,  Sotnikov   aided  and  abetted,  and,
unless  restrained  and  enjoined,   will   continue  aiding   and  abetting,   violations   of  Sections  17(a)  of
the Securities  Act [15  U.S.C. § 77q(a)].
FOURTH CLAIM FOR RELIEF
Aiding and Abe tting Violations  of Se ction 10(b) of the  Exchange  Act
(De fe ndant Sotnikov)
146. The Commission  realleges and incorporates  by reference each and every
allegation   in  paragraphs  1  through  136,  inclusive,   as  if  they  were  fully   set  forth  herein.
147. Sotnikov,  by engaging in  the  conduct  described  above,  singly   or  in  concert,
directly  or  indirectly,   knowingly   or  recklessly  provided  substantial  assistance  to  the Defendant
LLCs, who in  connection  with  the purchase or sale of securities,  by use of the means or
ins tr ume nta lit ies  of interstate  commerce, or of the mails,  or of any facility  of any national

40

securities  exchange,  knowingly   or  recklessly employed  devices, schemes, or artifices to defraud;
and  knowingly   or  recklessly  engaged  in  acts,  practices,  or  courses  of business  whic h  would
operate as a fraud or deceit upon other persons.
148. By  engaging   in  the  conduct  described  above,  Sotnikov   aided  and  abetted,  and,
unless  restrained  and  enjoined,   will   continue  aiding   and  abetting,   violations   of  Section  10(b)  of
the  Exchange  Act  [15  U.S.C. § 78j(b)]  and Rule 10b-5  thereunder  [17  C.F.R. § 240.10b-5].
FIFTH CLAIM FOR RELIEF
Unjus t Enrichme nt
(Re lie f De fe ndants  M azitova, Gre at Impe rial, HRC Cle aring, and Inte ko Cargo)
149. The Commission  realleges and incorporates  by reference each and every
allegation   in  paragraphs  1  through  136,  inclusive,  as if  they  were fully  set forth  herein.
150. Between February 2019  and February 2020,  the Defendants have diverted  to
accounts held  in the name of the Relief Defendants proceeds from the Defendants’ fraudulent
scheme as part of, and in  furtherance of, the securities law violations  alleged  above.
151. The Relief Defendants have no legitimate  claim  to these ill-gotten   gains,  which
are proceeds of the securities  fraud alleged  above,  and it is not just,  equitable,  or conscionable
for the Relief  Defendants to retain the funds.
152. Accordingly,  the Relief Defendants are liable  as Relief  Defendants for unjust
enrichment  and  must  disgorge  the  amount  of  their  ill-gotten   gains.

41

PRAYER FOR RELIEF
 WHEREFORE, the SEC respectfully  requests that the Court enter a judgment:
( i) Finding  that  Sotnikov,   Adaptive  Technology,  AGQ Business  Group, ATL Business
Group,  BO&SA, DN Industrial,  and Expert  Digital  violated  the provisions  of the
federal securities  laws as alleged  herein;
( ii) Finding  that  Sotnikov  aided and abetted the violations  of the federal securities laws
committed  by  the Defendant LLCs as alleged  herein;
(iii) Permanently  restraining  and  enjoining  Sotnikov,   Adaptive  Technology,  AGQ
Business  Group,  ATL Business Group,  BO&SA, DN Industrial,  and Expert Digital
from violating  Section  10(b) of the Exchange Act and Rule 10b-5  thereunder  and
Section  17(a) of the Securities  Act;
(iv) Permanently  restraining  and  enjoining   Sotnikov   from,  directly  or  indirectly,   aiding
and  abetting  violations   of  Section  17(a) of the Securities  Act, Section  10(b) of the
Exchange  Act  and  Rule  10b-5  thereunder;
(v) Ordering Sotnikov,   Adaptive  Technology,  AGQ  Business  Group,  ATL Business
Group,  BO&SA, DN Industrial,  and Expert  Digital  to disgorge  an amount equal  to the
proceeds of the conduct  alleged  herein  and  to  pay  prejudgment   interest  thereon;
( v i) Ordering Sotnikov,   Adaptive  Technology,  AGQ  Business  Group,  ATL Business
Group,  BO&SA, DN Industrial,  and Expert  Digital  to  pay  a  civil   monetary  penalty
pursuant to Section  21A of the Exchange  Act and Section  20(b) of the Securities  Act;
( v ii) Ordering  the Relief Defendants to  dis gor ge   a ll  ill-gotten   gains  to  which  they  do  not
have a legitimate  claim  received as a result  of the conduct alleged  in  the Complaint,
together  with  prejudgment   interest;  and
(viii) Granting  such  other  and further  relief  as  this  Court  may  deem  just  and  proper.

42

DEMAND FOR JURY TRIAL
P ursuant  to  Rule  38  of  the  Federal  Rules  of  Civil   P rocedure,  the  Commission   demands
trial  by  jury  in  this  action  of  all  issues  so  triable.
Dated:  March 13,  2020  Respectfully  submitted,
/s/John J. Bowers
      John  J. Bowers
Thomas  A. Bednar
      100  F  Street,  NE
      Washington,  DC 20549-4473
      Telephone: 202-551-4645 (Bowers)
      Ema il:    [email protected]

COUNSEL FOR PLAINTIFF SECURITIES
      AND EXCHANGE  COMMISSION

43

DESIGNATION OF AGENT FOR SERVICE
P ursuant  to  Local  Rule  101.1(f),  because  P laintiff   Securities  and  Exchange  Commission
(the “Commission”)  does not have an office in this  district,  the United States Attorney for the
District  of New Jersey is hereby designated  as an alternative  to the Commission  to receive
service of all  notices or papers in the captioned  action.  Therefore, service upon  the United States
Attorney’s Office or its authorized  designee:
David E. Dauenheimer
Deputy  Chief,  Government  Fraud  Unit
United  States Attorney’s  Office
District  of New Jersey
970  Broad  Street,  Suite  700
Newark, NJ 07102-2534

shall  constitute  service upon  the Commission  for purposes of this  action.
Dated:  March 13,  2020  Respectfully  submitted,
/s/John J. Bowers
      John  J. Bowers
      100  F  Street,  NE
      Washington,  DC 20549-4473
      Telephone: 202-551-4645
      Ema il:    [email protected]

COUNSEL FOR PLAINTIFF SECURITIES
      AND EXCHANGE  COMMISSION

UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 

__________________________________________  
: 

UNITED STATES SECURITIES AND   : 
EXCHANGE COMMISSION,    : 

: 
Plaintiff,     : 

: 
vs.     : Civil No. 

: 
DENIS GEORGIYEVICH SOTNIKOV, : 
ADAPTIVE TECHNOLOGY LLC, : 
AGQ BUSINESS GROUP LLC,   : 
ATL BUSINESS GROUP LLC,  : 
BO&SA CORPORATION,  : 
DN INDUSTRIAL LLC, and : 
EXPERT DIGITAL LLC,   : COMPLAINT 

: 
Defendants,    : 

: 
and       : 

: 
NATALIA ALEKSANDROVNA MAZITOVA, : 
GREAT IMPERIAL LLC,  : JURY TRIAL DEMANDED 
HRC CLEARING HOUSE LLC, : 
INTEKO CARGO LLC,  : 

: 
Relief Defendants.   : 

__________________________________________: 

COMPLAINT 

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

“Commission”) alleges as follows against the following Defendants, whose names and last 

known addresses are set forth below: 

a) Denis Georgiyevich Sotnikov (“Sotnikov”), 706 Diplomat Parkway, Hallandale
Beach, Florida 33009;

b) Adaptive Technology LLC (“Adaptive Technology”), 801 Three Island
Boulevard, Apt. 520, Hallandale Beach, Florida 33009;

c) AGQ Business Group LLC (“AGQ Business Group”), 1201 S Ocean Drive, Apt.
800, Hollywood, Florida 33019;

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d) ATL Business Group LLC (“ATL Business Group”), 801 Three Island Boulevard, 
Apt. 520, Hallandale Beach, Florida 33009; 

e)  BO&SA Corporation (“BO&SA”), 1201 S. Ocean Drive, #2107S, Hollywood, 
Florida 33019; 

f) DN Industrial LLC (“DN Industrial”), 3180 S Ocean Drive, #230, Hallandale 
Beach, Florida 33009; and 

g) Expert Digital LLC (“Expert Digital”), 1201 S. Ocean Drive, #2107S, 
Hollywood, Florida 33019; 

and as to the following Relief Defendants, whose names and last known addresses are set forth 

below: 

a) Natalia Aleksandrovna Mazitova (“Mazitova”), 706 Diplomat Parkway, 
Hallandale Beach, Florida 33009; 

b) Great Imperial LLC (“Great Imperial”), 18401 Collins Ave., Apt. 1173, Sunny 
Isles Beach, Florida 33160; 

c) HRC Clearing House LLC (“HRC Clearing”), 801 Three Island Boulevard, Apt. 
520, Hallandale Beach, Florida 33009; and 

d) Inteko Cargo LLC (“Inteko Cargo”), 706 Diplomat Parkway, Hallandale Beach, 
Florida 33009. 

SUMMARY 

1. This matter concerns an ongoing fraudulent scheme in which U.S investors – 

many of whom are older and using their retirement savings – are lured to websites offering 

fictitious Certificates of Deposit (“CDs”) at above-market rates.1  Some of the websites “spoof” 

actual U.S.-based financial firms,2 while others offer CDs from fake financial firms.   

                                                             
1  Like bonds, CDs are debt-based, fixed-income securities that an investor holds until a fixed 
maturity date.  The CDs offered as part of the scheme described here are fictitious instruments 
not issued by a legitimate U.S. bank, and are therefore not subject to protections offered by the 
federal banking laws.  These fictitious CDs did, however, mimic real CDs by purporting to have 
a fixed maturity and promising a specific and above-market-rate of return, and they were offered 
to the general public and marketed as legitimate securities. 
2  “Spoofing” is the act of disguising a communication from an unknown source as being from a 
known, trusted source.  See, e.g., https://www.investopedia.com/terms/s/spoofing.asp. 

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2. The spoofed websites use domain names similar to the domain names of actual 

financial institutions or that sound like real financial firms.  The spoofed websites falsely claim 

that the firms offering CDs to investors are FDIC, FINRA, SIPC, or New York Stock Exchange 

members, and that the deposits are FDIC-insured.   

3. The spoofed websites are advertised in search results provided by the two leading 

internet search and advertising companies.  As a result, unsuspecting investors see 

advertisements for the spoofed websites at the top of their search results when conducting 

internet searches for CDs with attractive rates.  Potential investors who visit a spoofed website 

are directed to call a telephone number on the website.  Believing that they are dealing with a 

legitimate U.S.-based financial firm offering legitimate CDs, potential investors who call the 

number on a spoofed website speak with an individual purporting to be an “account executive” 

of the firm identified on the website.  Potential investors provide an email address, after which 

they are contacted via email by the fake account executive, who often impersonates a real broker 

or sales representative of a spoofed financial firm.   

4. Investors are instructed by the fake account executives to wire funds to bank 

accounts opened on behalf of purported “clearing firms” identified in the emails.  Once the funds 

are received by the purported “clearing firm,” they are quickly transferred to different bank 

accounts, both domestic and foreign, making it difficult or impossible for investors to regain 

their funds.   

5. Since November 2014, the perpetrators of this scheme have created websites 

spoofing at least 24 actual financial firms and 8 fictitious financial firms, resulting in over $26 

million in known investor losses.  As described in this Complaint, Sotnikov and the entity 

defendants – Adaptive Technology, AGQ Business Group, ATL Business Group, BO&SA, DN 

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Industrial, and Expert Digital (collectively, the “Defendant LLCs”) – are directly linked to 7 of 

the spoofed websites, through which investors have lost over $1.8 million.3 

6. Sotnikov’s participation is essential to the fraudulent scheme.  He organized 

and/or controls the Defendant LLCs, each of which has been represented to investors as 

“clearing” or “offering” the CDs of a spoofed or fictitious financial firm and received investor 

funds.  In fact, the Defendant LLCs are not clearing firms, and they do not offer or sell legitimate 

CDs or other securities.  Instead, the Defendant LLCs were created by Sotnikov to serve as 

conduits to receive wire transfers from duped investors in furtherance of the fraudulent scheme 

alleged in this Complaint.   

7. After investor funds are wired into a bank account nominally owned by one of the 

Defendant LLCs, but in fact controlled by Sotnikov, he either transfers the funds to other LLC-

owned bank accounts that he or his wife, Relief Defendant Mazitova, control, including accounts 

nominally owned by the Relief Defendant LLCs, transfers the funds to other foreign bank 

accounts, transfers the funds to one of his personal bank accounts, or directly pays for his and/or 

his wife’s personal expenses out of the accounts. 

NATURE OF PROCEEDING AND RELIEF SOUGHT 

8. The SEC brings this action against Sotnikov, the Defendant LLCs, Mazitova and 

the Relief Defendant LLCs pursuant to Section 21A [15 U.S.C. § 78u-l] of the Exchange Act and 

Section 20(b) of the Securities Act [15 U.S.C. § 77t(b)] seeking a judgment from the Court:  

(a) enjoining Sotnikov and the Defendant LLCs from engaging in future violations of the federal 

securities laws; (b) ordering the Defendants and the Relief Defendants to disgorge an amount 

                                                             
3  In addition to $1.8 million in investor losses identified thus far, over $4 million of investor 
funds have been frozen by the banks at which the Defendant LLCs and Relief Defendant LLCs 
held or hold accounts.   

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equal to the profits gained and losses avoided as a result of the actions described herein, with 

prejudgment interest; and (c) ordering Sotnikov and the Defendant LLCs to pay civil monetary 

penalties.  

JURISDICTION AND VENUE 

9. This Court has jurisdiction over this action pursuant to Sections 21(d), 21(e), 21A 

and 27(a) of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), 78u-l, and 78aa(a)] and Sections 

20(b) and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b) and 77v(a)]. 

10. Sotnikov and the Defendant LLCs, directly or indirectly, used the means of 

interstate commerce and/or the facilities of a national securities exchange, in connection with the 

transactions, acts, practices, and courses of business alleged in this Complaint. 

11. Venue in this district is proper pursuant to Section 27 of the Exchange Act [15 

U.S.C. § 78aa] because certain of the offers and sales of securities and certain of the acts, 

practices, transactions, and courses of business constituting the violations alleged in this 

Complaint occurred within this District.  Specifically, the spoofed websites described herein 

were available to investors throughout this District, at least one investor residing in this District 

wired funds to one of the Sotnikov-controlled Defendant LLCs as a result of the fraudulent 

scheme,4 and many of the investor wire transfers for fake CDs alleged in this Complaint were 

cleared through bank facilities in Mount Laurel, New Jersey.   

DEFENDANTS 

12. Denis Georgiyevich Sotnikov, age 36, is a Russian national who resides in 

Hallandale Beach, Florida.  Sotnikov organized and/or controls or controlled each of the 

Defendant LLCs and Relief Defendant LLCs HRC Clearing and Inteko Cargo, and opened and 

                                                             
4  Upon information and belief, that investor is a resident of Voorhees, New Jersey. 

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controls or controlled bank accounts nominally owned by the Defendant LLCs and Relief 

Defendant LLCs HRC Clearing and Inteko Cargo. 

13. Adaptive Technology LLC is a Wyoming limited liability corporation (“LLC”), 

with a Hallandale Beach, Florida address listed in its incorporation papers.  Sotnikov organized 

Adaptive Technology and he is listed in its incorporation papers as its “manager.”  Adaptive 

Technology is the nominal owner of bank accounts controlled by Sotnikov that directly received 

investor funds.  Sotnikov has sole signatory authority over the Adaptive Technology bank 

accounts used in the scheme alleged in this Complaint. 

14. AGQ Business Group LLC is a Florida LLC, with a Hallandale Beach, Florida 

address listed in its incorporation papers.  Sotnikov organized AGQ Business Group and he is 

listed in its incorporation papers as its “manager.”  AGQ Business Group is the nominal owner 

of a bank account controlled by Sotnikov that directly received investor funds.  Sotnikov has sole 

signatory authority over the AGQ Business Group bank account used in the scheme alleged in 

this Complaint. 

15. ATL Business Group LLC is a Wyoming limited liability corporation, with a 

Hallandale Beach, Florida address listed on its incorporation papers – the same address used by 

Adaptive Technology.  Sotnikov organized ATL Business Group and he is listed in its 

incorporation papers as its “manager.”  ATL Business Group is the nominal owner of a bank 

account controlled by Sotnikov that directly received investor funds.  Sotnikov has sole signatory 

authority over the ATL Business Group bank account used in the scheme alleged in this 

Complaint. 

16. BO&SA Corporation is a Florida corporation, with a Hollywood, Florida 

address listed in its incorporation papers – the same address used by AGQ Business Group.  

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Sotnikov was a founding member of BO&SA and was an officer of BO&SA at various times 

throughout its history, including from its creation on December 10, 2018 through March 13, 

2019, and from May 21, 2019 through August 2, 2019.  BO&SA is the nominal owner of bank 

accounts that directly received investor funds and that were accessed at various times by 

Sotnikov. 

17. DN Industrial LLC was a Florida limited liability corporation, with a Hallandale 

Beach, Florida address listed in its incorporation papers – the same address used by AGQ 

Business Group, Expert Digital, and BO&SA.  Sotnikov organized DN Industrial and was listed 

as its “manager” in its incorporation papers until it was dissolved on October 3, 2019.5  DN 

Industrial is the nominal owner of bank accounts controlled by Sotnikov that directly received 

investor funds. 

18. Expert Digital LLC was a New York limited liability corporation, with a 

Hollywood, Florida address – the same address used by AGQ Business Group and BO&SA.  

Sotnikov organized Expert Digital and was listed in its incorporation papers as its “manager” 

until it was voluntarily dissolved on September 13, 2019.  Expert Digital was the nominal owner 

of bank accounts controlled by Sotnikov that directly received investor funds. 

RELIEF DEFENDANTS 

19. Natalia Aleksandrovna Mazitova, age 37, is a Russian national who resides in 

Hallandale Beach, Florida. 

20. Great Imperial LLC is a Florida limited liability corporation, with a Lauderhill, 

Florida address.  Relief Defendant Mazitova organized Great Imperial and she is listed in its 

                                                             
5  Where an LLC is described in this Complaint as “dissolved,” it means that, upon information 
and belief, the entity failed to file required annual paperwork with the government of the state in 
which the entity was organized. 

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incorporation papers as its “manager.”  Great Imperial is the nominal owner of bank accounts 

controlled by Mazitova that indirectly received investor funds. 

21. HRC Clearing House LLC is a Florida limited liability corporation, with a 

Hallandale Beach, Florida address – the same address used by Adaptive Technology and ATL 

Business Group.  Sotnikov organized HRC Clearing and he is listed in its incorporation papers as 

its “manager.”  HRC Clearing is the nominal owner of at least seven bank accounts controlled by 

Sotnikov, some of which indirectly received investor funds.  Sotnikov has sole signatory 

authority over all HRC Clearing bank accounts used in the scheme. 

22. Inteko Cargo LLC is a Florida limited liability corporation, with a Sunny Isles 

Beach, Florida address – the home address of Sotnikov and Mazitova.  Sotnikov organized 

Inteko Cargo and he is listed in its incorporation papers as its “manager.”  Inteko Cargo is the 

nominal owner of at least six bank accounts controlled by Sotnikov, some of which indirectly 

received investor funds.  Sotnikov has sole signatory authority over all Inteko Cargo bank 

accounts used in the scheme. 

FACTUAL ALLEGATIONS 

I.  The Fraudulent Scheme To Sell Fake Certificates Of Deposit To U.S. Investors  

23. Since at least November 2014 and continuing through March 2020, unidentified 

perpetrators have been spoofing websites of actual broker-dealers, investment advisers, and 

banks, or creating websites for fake financial firms, to offer fictitious CDs to U.S. investors.6  

These perpetrators have registered numerous domain names that are similar to the domain names 

of real financial institutions and then have used those domain names to create websites that 

purport to offer jumbo CDs at rates slightly higher than market rates.  The websites typically use 

                                                             
6  All investors referred to in this Complaint resided in the United States at the time of their 
investments. 

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the actual logos of the spoofed firms, and claim that the firms are FDIC, FINRA, SIPC, or New 

York Stock Exchange members, and that deposits are FDIC insured.  The websites often use the 

spoofed firms’ actual FINRA and/or FDIC member identification numbers.   

24. In furtherance of the scheme, the perpetrators of the scheme have purchased 

internet advertising from, among others, the top two providers of internet search and advertising 

services, causing advertisements for the spoofed websites to appear at the top of search results 

for phrases such as “best CD rates,” “highest cd rates,” or other similar phrases. 

25. As a result, unsuspecting investors, when conducting internet searches for CDs 

with attractive rates, received advertisements for the spoofed websites and clicked on links that 

directed them to the spoofed websites operated by the perpetrators of the scheme.  They then 

called the telephone numbers provided on the spoofed websites and spoke to an individual 

claiming to be a representative of the spoofed firm, often impersonating an actual employee of 

the spoofed firm and using the real employee’s name and FINRA CRD number.7   

26. Investors then received an email from the purported account executive providing 

an application to open an “account” to purchase the CDs and wiring instructions to purported 

“clearing firms” with either foreign or U.S.-based accounts.  After investors funded their CD 

accounts by wiring in their investments, the funds were quickly transferred to other bank 

accounts, including accounts overseas. 

27. In addition to using the names of spoofed real or nonexistent financial firms and 

posing as actual employees of spoofed firms, the perpetrators have gone to significant lengths to 

                                                             
7  FINRA operates the Central Registration Depository (“CRD”), the central licensing and 
registration system used by the U.S. securities industry and its regulators, which contains the 
registration records of broker-dealer firms and their associated individuals (e.g., brokers and 
investment advisors). 

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hide their identities.  For example, they have used:  (1) virtual private networks (“VPNs”) to 

anonymize their digital footprints, such as internet protocol (“IP”) addresses; (2) prepaid gift 

cards to pay for domain-name registration services, state incorporation filings, internet ads, and 

VPN, website, and call-answering services; (3) prepaid phones or encrypted communication 

products to communicate; and (4) fake invoices and websites to explain large money transfers in 

response to inquiries by banks that received large wire transfers of investor funds.   

28. In some cases, the real financial firms being spoofed learned about the spoofed 

website from victims or potential victims of the scheme, and took steps to shut down the spoofed 

websites by contacting the domain-name registrar and asserting trademark or copyright 

infringement.  Even though the spoofed websites were typically up for only a few weeks before 

they were taken down, the perpetrators raised and wired abroad millions of dollars from duped 

U.S. investors.  Since November 2014, the perpetrators have created websites spoofing at least 

24 U.S.-based financial firms or using at least 8 fictitious entities, resulting in at least $26 million 

in known investor losses and $44.9 million in attempted investments.8  As described below, 

Sotnikov and the Defendant LLCs are directly linked to 7 of the spoofed websites, through which 

investors have lost over $1.8 million.  Many of the victimized investors were elderly and were 

investing their retirement savings. 

II.  Sotnikov’s Role In The Fraudulent Scheme  

29. Beginning no later than February 2019 and continuing through at least February 

2020, Defendant Sotnikov participated in a scheme involving spoofs of at least seven different 

                                                             
8  Investor losses are less than the total amount sent by investors to bank accounts controlled by 
the perpetrators of the larger scheme because investors, banks, or government agencies became 
suspicious or flagged specific transactions and some accounts were frozen before investor funds 
could be sent to foreign accounts or otherwise dispersed. 

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U.S.-based financial firms, with each spoofed website offering fictitious CDs to investors in a 

manner consistent with the scheme outlined above.   

30. Sotnikov formed many U.S. limited liability companies, including the Defendant 

LLCs and several of the Relief Defendant LLCs.  

31. In forming the Defendant LLCs and/or in opening bank accounts for them, 

Sotnikov claimed that the Defendant LLCs were engaged in legitimate businesses unrelated to 

the offer and sale of securities or the clearing of securities transactions:   

a. DN Industrial - “Industrial Construction Business Equipment” (Bank account 
opening documents) and “Kitchen and restaurant equipment sales” (Bank account 
opening documents);  

b. BO&SA - “Development and sale of software, provision of virtual space for sales 
representatives, development of web resources” (Florida incorporation 
documents);  

c. Expert Digital - “IT Consulting, Computer, Technology and Program Consulting” 
business (Bank 1 account opening documents); 

d. Adaptive Technology - “Custom computer programming services” (Bank account 
opening documents);   

e. ATL Business Group - “custom computer programming services.”  (Bank account 
opening documents); and 

f. AGQ Business Group - “Flooring and Kitchen construction” (Bank account 
opening documents). 

Upon information and belief based on available bank records, however, none of these entities 

engaged in any legitimate business activity.  Instead, their primary function was to serve as a 

conduit for the proceeds of the fraudulent scheme undertaken by Sotnikov and other perpetrators. 

32. One of the Defendant LLCs, ATL Business Group, was also named as the entity 

offering the CDs on two spoofed websites — amrbusinessgroup.com and atlbusinessgroup.com.  

Each of the Defendant LLCs was based in a residential apartment or condominium in the Miami 

Beach area, including several at the same address, one of which is Sotnikov’s personal residence.   

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33. Upon information and belief based on review of available records, Defendant DN 

Industrial, another of the Defendant LLCs controlled by Sotnikov, made payments to a leading 

provider of Internet search and advertising services for advertising that directed potential 

investors to at least one of the spoofed websites described below in this Complaint. 

34. As with the Defendant LLCs, Sotnikov and Mazitova claimed that the Relief 

Defendant LLCs they created and controlled were engaged in legitimate businesses:   

a. Great Imperial - “Marketing Consulting” in the “Professional, Scientific, and 
Technical Services” industry  and “prefabricated wood building manufacturing” 
(Bank account opening documents); 9 

b. Inteko Cargo – “Transportation and warehousing” (Bank account opening 
documents); and 

c. HRC Clearing – “[C]ustomer computer programming services” (Bank account 
opening documents).  

But again, upon information and belief based on available bank records, the Relief Defendant 

LLCs created by Sotnikov and Mazitova were not engaged in any legitimate business activity.  

Instead, they were used by Sotnikov as conduits for his transfer of investor funds initially 

received into the Defendant LLC bank accounts.  And as with the Defendant LLCs, each of the 

Relief Defendant LLCs was based in a residential apartment or condominium in the Miami 

Beach area, including several at the same address, one of which is Sotnikov’s personal residence. 

35. Sotnikov opened and controlled bank accounts on behalf of the Defendant LLCs, 

other than BO&SA, into which investors were instructed to wire their funds, and opened and 

controlled bank accounts on behalf of the Relief Defendant LLCs, other than Great Imperial, into 

which investor funds were ultimately transferred.   

                                                             
9  Relief Defendant Mazitova is listed in state incorporation records as having organized Relief 
Defendant Great Imperial.  Defendant BO&SA was organized by Sotnikov and two other 
individuals.  The other Defendant LLCs and Relief Defendant LLCs were organized by 
Sotnikov. 

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36. After investor funds were wired into accounts nominally owned by the Defendant 

LLCs, Sotnikov laundered the funds by transferring money to accounts he or Relief Defendant 

Mazitova controlled that were nominally owned by the Relief Defendant LLCs, including 

accounts in the names of Great Imperial, HRC Clearing, and Inteko Cargo, or to other accounts 

at overseas banks.  Some of the investor funds received into accounts controlled by Sotnikov and 

nominally owned by the Defendant LLCs were ultimately transferred to overseas accounts, either 

directly or after one or more transfers through bank accounts controlled by Sotnikov and 

nominally owned by the Relief Defendant LLCs:   

37. In addition to transferring funds between the various LLC accounts, and 

transferring funds overseas, Sotnikov also transferred funds to his and Mazitova’s personal bank 

accounts, and used those funds to pay for personal items, such as doctors’ bills, jewelry and 

vacations.   

38. Sotnikov also transferred funds from his personal bank account and the Relief 

Defendant LLCs’ accounts he controlled into Defendant LLC accounts he controlled.   

III. Spoofed Bank 1 – Sotnikov and DN Industrial 

39. Defendants Sotnikov and DN Industrial were instrumental in an iteration of the 

spoofing scheme targeting Spoofed Bank 1, a real bank headquartered in California.   

40. Sotnikov formed Defendant DN Industrial in Florida on July 26, 2018, listing 

himself as the sole manager of the company.   

41. On August 9, 2018, Sotnikov opened an account at a well-known national bank 

(“Bank 1”) in the name of DN Industrial.  In the account opening documents, Sotnikov claimed 

that DN Industrial was in the “industrial construction business equipment business.”  On 

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December 6, 2018, Sotnikov opened an account at another major national bank (“Bank 2”) in the 

name of DN Industrial.  Sotnikov had sole signatory authority over each of these bank accounts.   

42. Upon information and belief, DN Industrial is not a clearing firm, nor does it offer 

or sell legitimate CDs or other securities.  Bank records demonstrate that Sotnikov used DN 

Industrial’s bank accounts for personal purposes.  For example, in addition to transferring money 

from DN Industrial’s bank accounts into his personal accounts, he also transferred money from 

his personal accounts into DN Industrial’s accounts on several occasions.  And on January 14, 

2019, Sotnikov used a check card linked to DN Industrial’s Bank 2 account to pay $599 to a 

service provider to fly an aerial banner over a South Florida beach that read “Natalia will you 

marry me Denis.”   

43. In February 2019, the perpetrators of the spoofing scheme created several 

websites spoofing Spoofed Bank 1, in order to lure investors into purchasing fictitious CDs.   

44. The domain names for these spoofed websites were designed to closely 

approximate Spoofed Bank 1’s real domain name, using techniques such as adding initials after 

the real domain name, and the content of the websites was designed to mimic a real bank 

offering CDs to investors.   

45. Each domain name created as part of the scheme to spoof Spoofed Bank 1 was 

registered in the U.S. by an individual using the name of a real registered representative 

employed by Spoofed Bank 1 who, upon information and belief, was not involved in the scheme 

(“Alias 1”).  The person who registered the domain name paid the domain registrar to create an 

email account with an address using the names of Alias 1 and Spoofed Bank 1 (“Email Address 

1”) to communicate with investors, and provided a business address of 601 S. Figueroa Street, 

Los Angeles, California.   

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46. On February 11, 2019, a prospective investor viewed one of the spoofed websites, 

which used a domain name that was a slight variation on Spoofed Bank 2’s real domain name 

(“Spoofed Website 1”), and which offered no penalty, above-market-rate CDs with a minimum 

deposit of $200,000, and inquired about investing in a nine-month jumbo CD.   

47. The investor received an introductory email from Email Address 1, signed by an 

individual using Alias 1, and claiming to be a “Senior Account Executive” at Spoofed Bank 1.   

48. In the email, the person using Alias 1 provided the potential investor with a real 

FINRA CRD number belonging to the real registered investment advisor affiliated with Spoofed 

Bank 1 in New Mexico, whose name matched Alias 1.   

49. The email from the person using Alias 1 instructed the potential investor to 

complete and submit the attached “CD application,” which required the potential investor to 

provide personally identifiable information (“PII”), including a Social Security Number and his 

mother’s maiden name.  The email also falsely stated that the entity offering the CDs:  

[I]s a Registered FDIC Institution.  Securities offered through [Bank 1] & [Bank 
2]. DN Industrial LLC Clearing or CM International – Member FINRA/SIPC.  
Investment Advisory Services offered through [Spoofed Bank Alias 1] Los 
Angeles. 
 
(emphasis added). 

In fact, DN Industrial was not a clearing firm, nor did it offer or sell legitimate CDs or other 

securities, and “Spoofed Bank Alias 1,” named in the email and using a slight variation on 

Spoofed Bank 1’s name, was not a real, FDIC-insured bank. 

50. In addition to the CD application, the introductory email from Alias 1 also 

attached a fictitious CD Term Sheet, an example of FDIC coverage, a spoofed “Statement of 

Condition,” which included a spoofed picture and statement from the spoofed bank’s purported 

CEO, and a spoofed summary of the bank’s assets and liabilities.  The spoofed “Statement of 

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Condition” was copied nearly verbatim from the Statement of Condition of the real Spoofed 

Bank 1, but provided a different picture and misidentified Spoofed Bank 1’s CEO. 

51. Via email, the potential investor asked the person using Alias 1 to provide the 

FDIC number10 of Spoofed Bank Alias 1, as he was unable to find the bank on the FDIC’s 

website.  The person using Alias 1 responded by email, providing the FDIC number for the real 

Spoofed Bank 1, headquartered in California.   

52. The suspicious potential investor forwarded his communications with the person 

using Alias 1 to the real Spoofed Bank 1.  Shortly thereafter, on February 13, 2019, Spoofed 

Website 1 was suspended by its domain-name registrar.  

53. Another potential investor was not so fortunate.  On February 12, 2019, when this 

investor emailed the person using Alias 1 to ask why his funds would not be “sent directly to” 

the bank listed on the spoofed website, the person using Alias 1 responded as follows: 

The funds clear through the [Bank 1] clearinghouse (DN Industrial LLC) for the 
sole purpose to facilitate the exchange of payments, and secure the purchaser . . . .  
The clearing house stands between two parties (also known as member firms or 
participants of FDIC).  Its purpose is to eliminate the risk of, and honor settlement 
obligations in larger transactions. 
  
(emphasis added). 

54. On February 15, 2019, based on the assurances provided by the person using 

Alias 1, and believing that he was buying a legitimate CD based on the information provided on 

Spoofed Website 1, this investor wired his life savings of $250,000 to DN Industrial’s Bank 2 

account – an account opened and controlled by Sotnikov.   

                                                             
10  The FDIC assigns a registration number to each bank or savings association it insures.  The 
“BankFind” tool on the FDIC’s website allows visitors to obtain information about all FDIC-
insured institutions based on a bank’s name and/or FDIC number. 

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55. Within days after the investor’s $250,000 wire was received into DN Industrial’s 

account at Bank 2, rather than providing the investor with the promised CDs, Sotnikov made a 

series of fraudulent transfers that depleted the investor’s funds:  (i) on February 21, 2019, he 

wired $100,000 to an account at a Hong Kong bank; (ii) on February 21, 2019 and February 22, 

2019, he wired a total of almost $40,000 to his and Relief Defendant Mazitova’s joint checking 

account at Bank 2; and (iii) on February 22, 2019, he wired $130,000 to an account at Bank 2 in 

Relief Defendant Inteko Cargo’s name, an account he opened and controlled.  Later on February 

22, 2019, Sotnikov transferred $43,000 from the Inteko Cargo account into his and Mazitova’s 

personal joint checking account at Bank 2, and then transferred $30,200 from his and Mazitova’s 

joint checking account back into DN Industrial’s Bank 2 account.   

56. With Spoofed Website 1 suspended, the perpetrators turned to the other domain 

names related to Spoofed Bank 1 that they had previously registered to continue the scheme.  

Like Spoofed Website 1, these spoofed websites offered no penalty, above-market-rate CDs with 

a minimum deposit of $200,000.  The website also claimed that Spoofed Bank Alias 1 was a 

“Member FDIC” and had offices located at 601 S. Figueroa St., Los Angeles, California. 

57. In late February 2019, upon inquiring about the CDs offered on these websites, at 

least four elderly retired investors received the same introductory email from the person using 

Alias 1, including the following language:  “Securities offered through [Bank 1] & [Bank 2]. DN 

Industrial LLC Clearing or CM International – Member FINRA/SIPC” (emphasis added).  

These emails attached the same CD application as that used earlier in the scheme.  On February 

25, 2019, after returning the completed applications, each investor received an email from the 

person using Alias 1, containing the Bank 2 logo and welcoming them to “[Spoofed Bank Alias 

1] . . . Cleared by [Bank 2] DN Industrial LLC” (emphasis added).   

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58. The emails received by these investors also stated that their CD accounts were 

“now active and ready for funding,” and attached wire instructions to fund their CD accounts 

“with our clearing partner [Bank 2].”  Like the previous wire instructions, these instructions 

directed the investors to wire their funds to DN Industrial’s Bank 2 account, and identified DN 

Industrial as:  “DN Industrial LLC . . . A [Bank 2] Company” and “Member FINRA Member 

FDIC.”  In fact, DN Industrial is not a FINRA or FDIC member, its bank accounts are controlled 

by Sotnikov, and the only business activity observable from its banking records is the laundering 

by Sotnikov of funds received from duped investors.  Further, Bank 2 had no knowledge of or 

involvement in the scheme, and DN Industrial was not a “[Bank 2] company,” but rather simply 

had an account at Bank 2. 

59. On February 25, 2019, an elderly couple wired $383,000 to the DN Industrial 

account at Bank 2 controlled by Sotnikov after receiving the CD application and wire 

instructions from the person using Alias 1.  Rather than providing the investor with the promised 

CDs, Sotnikov made a series of fraudulent transfers that rapidly depleted the investor’s funds.  

On February 26, 2019, the day after the investor’s wire was received, Sotnikov transferred 

$382,900 of the investor’s funds to another account he controlled – Relief Defendant Inteko 

Cargo’s account at Bank 2.  Two days later, Sotnikov transferred $35,000 from that Inteko Cargo 

account to his and Relief Defendant Mazitova’s joint checking account at Bank 2, some of which 

was used to make purchases at a luxury jewelry retailer and a luxury clothing and accessories 

retailer. 

60. On February 28, 2019, after being contacted by the person using Alias 1, another 

elderly investor wired $200,000 into the DN Industrial account at Bank 2 controlled by Sotnikov.  

Again, rather than providing the investor with the promised CDs, Sotnikov made a series of 

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fraudulent transfers that rapidly depleted the investor’s funds.  The day after the investor’s funds 

were received, March 1, 2019, Sotnikov wired $171,880 of that investor’s funds from DN 

Industrial’s Bank 2 account to an account at a Turkish bank with the following payment detail:  

“PMNT FOR EQUIPMENT INVOICE 37 POPSERVICES.”   

61. Shortly after each investor’s funds were received into Sotnikov’s DN Industrial’s 

Bank 2 account controlled by Sotnikov, each investor received a fictitious account statement 

from “[Spoofed Bank Alias 1] FDIC,” via email from the person using Alias 1.  Although each 

investor’s funds had in fact been rapidly depleted by Sotnikov, the fictitious account statements 

reflected each investor’s purported “opening balance,” “interest earned” and “credits” 

reimbursing them for their wire transfer costs. 

62. On February 26, 27 and 28, 2019 Sotnikov wired a total of $15,000 to a leading 

provider of Internet search and advertising services, using funds from the same DN Industrial 

Bank 2 account that received the investors’ funds.  Records obtained from that provider indicate 

that these payments were made to purchase advertising that directed potential investors to at least 

one of the spoofed websites described below. 

IV. Spoofed Bank 2 – Sotnikov and DN Industrial 

63. Defendants Sotnikov and DN Industrial were also instrumental in another 

iteration of the spoofing scheme targeting Spoofed Bank 2, a real bank headquartered in Green 

Bay, Wisconsin. 

64. By early March 2019, the perpetrators began spoofing Spoofed Bank 2, again 

directing investors to wire money to a DN Industrial bank account controlled by Sotnikov.   

65. On March 4, 2019, a person using Alias 1, still using the 601 S. Figueroa Street 

address in Los Angeles and spoofed Email Address 1, registered a domain name using a slight 

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variation on Spoofed Bank 2’s name (“Spoofed Website 2”).  The domain registration fee was 

paid with a prepaid gift card purchased a day earlier at a grocery store in Irvine, California.   

66. The new website claimed to offer above-market-rate CDs from “[Spoofed Bank 

Alias 2], Member FDIC,” with no penalties and a minimum deposit of $200,000.  The website 

claimed that Spoofed Bank Alias 2 was affiliated with another bank with a slightly different 

variation on Spoofed Bank 2’s name (“Spoofed Bank Alias 3”) and claimed that Spoofed Bank 

Alias 3 had offices at 601 S. Figueroa Street, Los Angeles, California.  In fact, neither Spoofed 

Bank Alias 2 nor Spoofed Bank Alias 3 was a real, FDIC-insured bank. 

67. The documents and correspondence used for the Spoofed Bank 2 iteration of the 

scheme were nearly identical to those used in the Spoofed Bank 1 iteration of the scheme.  The 

introductory email to potential investors was again signed by the person using Alias 1.  He stated 

that he was a “Senior Account Executive,” provided the FINRA CRD number of the real person 

with the same name as Alias 1, and attached a nearly identical CD application.  In this iteration 

of the scheme, however, the person using Alias 1 claimed to be associated with “Spoofed Bank 

Alias 4,” another slight variation on Spoofed Bank 2’s name, and provided the FDIC number of 

the real Spoofed Bank 2.   

68. After completing and submitting the application, investors received a “welcome” 

email from the person using Alias 1, stating that the investor’s CD account was “now active and 

ready for funding,” and attaching wiring instructions “with our clearing partner DN Industrial, 

LLC and [Bank 1] to fund” the CD.  The wire instructions directed investors to fund their CD 

“account with DN Industrial, LLC” by wiring money to DN Industrial’s Bank 1 account, an 

account controlled by Sotnikov.  The wire instructions for DN Industrial’s Bank 1 account used 

the real Bank 1 logo and identified DN Industrial as “DN Industrial LLC . . . Member FINRA 

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Member FDIC.”  In fact, upon information and belief, none of the spoofed bank aliases are 

associated with a real, FDIC-insured bank, and DN Industrial is not a clearing firm, is not a 

FINRA or FDIC member, and it does not offer or sell legitimate CDs or other securities.  Instead, 

DN Industrial’s bank accounts are controlled by Sotnikov, and the only business activity 

observable from DN Industrial’s banking records is the laundering by Sotnikov of funds received 

from duped investors. 

69. Between March 22 and March 27, 2019, at least three additional investors wired a 

total of $990,000 to DN Industrial’s bank accounts in connection with the iteration of the scheme 

related to Spoofed Bank 2.   

70. On March 22, 2019, two married investors wired $250,000 to DN Industrial’s 

account at another well-known national bank (“Bank 3”), and another investor wired $240,000 to 

DN Industrial’s Bank 1 account, an account controlled by Sotnikov.  And on March 27, 2019, the 

same married couple invested an additional $500,000 by wiring the funds to DN Industrial’s 

Bank 3 account, another account controlled by Sotnikov. 

71. Within days of receiving these investor funds, rather than providing the investors 

with the promised CDs, Sotnikov fraudulently transferred a substantial portion of the investor 

funds received into DN Industrial’s Bank 1 account to other accounts that he and his wife 

controlled:  On March 27, 2019, he transferred $25,000 to an account in his wife’s name at a 

Russian bank; on March 28 and 29, 2019, he transferred a total of $35,000 to the Bank 1 account 

of Inteko Cargo, which he controlled; and on April 1, he transferred $8,200 to Expert Digital’s 

Bank 1 account, another account he controlled.   

72. Also on April 1, 2019, Sotnikov transferred $16,500 from Inteko Cargo’s Bank 1 

account to Great Imperial’s Bank 2 account, and transferred another $8,000 from Expert 

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Digital’s Bank 1 account to Great Imperial’s Bank 3 account.  Relief Defendant Mazitova, who 

organized and controls Great Imperial, proceeded to transfer a majority of those funds to her 

personal savings account over the next several days. 

73. On April 3, 2019, Sotnikov transferred an additional $10,500 from DN 

Industrial’s Bank 1 account to Inteko Cargo’s Bank 1 account, and transferred $14,100 from DN 

Industrial’s Bank 1 account to Expert Digital’s Bank 1 account.  Shortly thereafter, Sotnikov 

transferred $13,100 from Expert Digital’s Bank 1 account to Great Imperial’s Bank 3 account, an 

account controlled by Relief Defendant Mazitova.   

74. Also on April 3, 2019, Mazitova used funds from Great Imperial’s Bank 1 

account for purchases at a cell phone provider and department store, and transferred $15,000 to 

her personal savings account at Bank 3. 

V. Spoofed Bank 3 – Sotnikov, Expert Digital, and BO&SA 
 

75. Defendants Sotnikov, Expert Digital, and BO&SA were instrumental in another 

iteration of the spoofing scheme targeting a bank headquartered in St. Louis, Missouri (“Spoofed 

Bank 3”). 

76. On September 12, 2018, Sotnikov formed Expert Digital in New York.  Two days 

later, Sotnikov opened an account for Expert Digital at Bank 1, over which he had sole signatory 

authority.  In the account opening documents, Sotnikov described Expert Digital as being in the 

“IT consulting, computer, technology and program consulting” business.  He listed three 

companies based in Kazan, Russia as being Expert Digital’s major suppliers, and claimed that his 

major customers were primarily retail-based.  On December 7, 2018, Sotnikov opened another 

account for Expert Digital at Bank 2, over which he again had sole signatory authority.   

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77. On December 6, 2018, Sotnikov and two other individuals formed Defendant 

BO&SA in Florida.  BO&SA’s business was described as the “development and sale of software, 

provision of virtual space for sales representatives, [and] development of web resources.”  On 

March 28, 2019, an account was opened in BO&SA’s name at another well-known national bank 

(“Bank 4”).   

78. Although Sotnikov was not BO&SA’s sole organizer or control person, as he was 

with the other Defendant LLC’s, he served as either president or vice president of BO&SA of 

from December 10, 2018 through March 13, 2019, and from May 21, 2019 through August 2, 

2019.11  In addition, BO&SA’s address was listed in corporate records as 1201 S. Ocean Drive, 

2107 S, Hollywood, FL  33019 – the same address as that of three of the other Defendant LLCs 

organized by Sotnikov – Expert Digital, DN Industrial, and AGQ Business Group.12  In addition, 

a significant portion of the investor funds wired into BO&SA’s account was transferred to Relief 

Defendant HRC Clearing, an entity controlled by Sotnikov.   

79. As noted above, on February 26, 27 and 28, 2019, Sotnikov wired a total of 

$15,000 to a leading provider of Internet search and advertising services.  Records obtained from 

that provider indicate that the payments were for advertising that directed potential investors to at 

least one of the spoofed websites related to this iteration of the scheme.13 

                                                             
11  Sotnikov was removed as an officer of BO&SA shortly before BO&SA opened a bank 
account at Bank 4 that received investor funds, and was later re-installed as an officer of 
BO&SA. 
12  Account opening documents submitted to Bank 4 listed a different address for BO&SA – 
18401 Collins Ave., Apt. 1243, Sunny Isles Beach, FL 33160 – the same street address as Relief 
Defendant Great Imperial, albeit with a different apartment number. 
13  These payments were made with funds from DN Industrial’s Bank 2 account, the same 
account that received investor funds from an earlier iteration of the scheme involving Spoofed 
Bank 1. 

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80. Beginning in late February 2019, the perpetrators began using websites spoofing 

Spoofed Bank 3.  In certain instances, they directed investors to wire money to Expert Digital’s 

Bank 1 account, an account controlled by Sotnikov.  In other instances, they directed investors to 

wire money to BO&SA’s Bank 4 account.  Although Sotnikov was no longer listed as an officer 

of BO&SA as of late February 2019, corporate records listed the managing members of BO&SA 

as two individuals who were officers of BO&SA at the same time as Sotnikov.  

81. Between mid-March 2019 and May 2019, using four different domain-name 

registration providers based in the U.S., Russia and Israel, the perpetrators registered at least six 

domain names designed to convince investors that they were dealing with the real Spoofed Bank 

3 by using slight variations on the bank’s name.  The domain names registered in the U.S. were 

again registered by an individual using Alias 1, and were paid for using two prepaid gift cards 

purchased at a grocery store in California.  In registering the domain names, the person using 

Alias 1 again identified his business address as 601 S. Figueroa Street, Los Angeles, California. 

82. Like the previous websites, these new websites offered no penalty, above-market-

rate CDs with a minimum deposit of $200,000, claimed that the fictitious offering bank was a 

“Member FDIC,” and claimed that deposits were FDIC-insured.  The websites also claimed to 

use real U.S. banks (Bank 1, Bank 2, and Bank 3) and other entities as “clearing partners.”14   

83. Investors who inquired about the CDs offered on these Spoofed Bank 3-related 

websites received an introductory email from an email address that featured Alias 1 and Spoofed 

Bank 3 (“Email Address 2”).  For example, an investor and a prospective investor received 

emails on May 8, 2019 claiming that the person using Alias 1 was a “Senior Account Executive” 

                                                             
14  The websites again used the same business address – 601 S. Figueroa Street, Los Angeles, 
California – used previously by the person using Alias 1. 

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at Spoofed Bank 3 and again provided the FINRA CRD number of the real person with the same 

name as Alias 1’s and Spoofed Bank 3’s real FDIC number.15   

84. The email also attached a CD application nearly identical to that used in the prior 

spoofs, stating that the purported bank “is a Registered FDIC Institution.  Securities offered 

through [Bank 1], or [Bank 4], Expert Digital LLC or BO&SA Clearing – Member 

FINRA/SIPC.  Investment Advisory Services offered through [Spoofed Bank Alias 4]” (emphasis 

added). 

85. In fact, upon information and belief, “Spoofed Bank Alias 4,” named in the email 

and using a slight variation on Spoofed Bank 3’s name, is not a real, FDIC-insured bank, neither 

Expert Digital nor BO&SA is a clearing firm, and neither LLC offers or sells legitimate CDs or 

any other securities. 

86. After submitting the completed application, investors again received a “welcome” 

email from the person using Alias 1, explaining that their CD accounts were “now active and 

ready for funding” and attaching wire instructions.   

87. An email and wiring instructions sent to at least one investor on May 8, 2019 

claimed that the bank’s transactions were “Cleared by [Bank 1] through Expert Digital LLC 

Clearing” and instructed investors to wire funds to Expert Digital’s Bank 1 account.  As noted 

above, Expert Digital is not a clearing firm.  Its bank accounts are controlled by Sotnikov, and 

the only business activity observable from its banking records is the laundering by Sotnikov of 

funds received from duped investors.  

                                                             
15  Upon information and belief, the real registered representative impersonated by the person 
using Alias 1 has no business relationship with the real Spoofed Bank 3. 

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88. Wire instructions sent to two other investors on May 15, 2019 instructed the 

investors to wire their funds to “BO&SA Corp. Clearing through [Bank 4].”  The wire 

instructions used Bank 4’s logo, and stated “BO&SA Corp.  Clearing through [Bank 4]” and 

“Member FINRA.”  As noted above, BO&SA is not a clearing firm, nor is it a member of 

FINRA.  Instead, BO&SA was organized by Sotnikov and two other individuals, and the only 

business activity observable from BO&SA’s banking records is the laundering of funds received 

from duped investors. 

89.   In May 2019, three investors wired a total of $850,000 to Expert Digital’s Bank 

1 account, an account controlled by Sotnikov.  One investor wired $200,000 on May 8, 2019, 

and two investors (a husband and wife) wired $650,000 on May 9, 2019.  On May 8, Sotnikov 

transferred $70,000 from Expert Digital’s Bank 1 account to Inteko Cargo’s Bank 1 account.  

Shortly thereafter, Expert Digital’s Bank 1 account was frozen. 

90. Also in May 2019, three additional investors wired a total of $407,000 to 

BO&SA’s Bank 4 account.  One investor wired $207,000 on May 13, 2019, and two other 

investors (again a husband and wife) wired $200,000 on May 16, 2019.  Of the $407,000 in 

investor funds wired into BO&SA’s Bank 4 account, $228,000 was sent to an account at another 

well-known national bank (“Bank 7”) in the name of Relief Defendant HRC Clearing, another 

entity controlled by Sotnikov – $50,000 by wire on May 15, 2019, and $178,000 by check dated 

June 10, 2019.  Sotnikov used certain of the funds transferred to HRC Clearing to pay for a trip 

to New York City.  On June 5, $150,000 was transferred from BO&SA’s Bank 4 account to 

Sotnikov’s personal account at another well-known national bank (“Bank 5”).  On June 10, 2019, 

$20,000 was transferred from BO&SA’s Bank 4 account to Relief Defendant Great Imperial’s 

Bank 5 account, an account controlled by Relief Defendant Mazitova. She subsequently used 

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funds from Great Imperial’s account to pay for personal medical services and a purchase at a 

luxury goods retailer. 

VI. AMR Business Group/ATL Business Group Spoofs – Sotnikov, Adaptive 
Technology, and ATL Business Group 

 
91. Defendants Sotnikov, Adaptive Technology, and ATL Business Group were 

instrumental in the next iteration of the spoofing scheme. 

92. On November 7, 2019, Sotnikov formed Defendant Adaptive Technology as a 

Wyoming LLC, providing his Florida address as the business address and naming himself as the 

manager.  On November 27, 2019, Sotnikov opened a bank account for Adaptive Technology at 

Bank 5.  The account opening documents claimed that the company’s purpose was to provide 

“custom computer programming services” and that it “create[d] apps for Apple and other 

companies.”  Sotnikov had sole signatory authority over the account.   

93. On November 25, 2019, Sotnikov formed another Wyoming LLC, Defendant 

ATL Business Group, using the same Florida address as Adaptive Technology, and again 

naming himself as manager.  On December 27, 2019, Sotnikov opened a bank account for ATL 

Business Group at Bank 5, claiming in account opening documents that ATL Business Group 

LLC also provided “customer computer programming services.”  Sotnikov had sole signatory 

authority over the account. 

94. Starting in January 2020, the perpetrators modified their scheme, but continued to 

use websites offering fictitious CDs to investors.  Rather than spoofing real banks and brokerage 

firms, however, the perpetrators created multiple websites, often using fictional financial firms.  

They also created at least one website using the name of Defendant ATL Business Group, an 

entity organized and controlled by Sotnikov, and at least three of the websites in this iteration of 

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the scheme employed Defendant LLCs organized and controlled by Sotnikov to receive investor 

funds.   

95. Other than moving away from spoofing the websites of actual, legitimate U.S. 

financial institutions, the scheme generally remained unchanged.  After accessing the spoofed 

website, the investor received an email from a fake account executive impersonating a real 

registered investment adviser.  The email stated that the “securities were being offered” by one 

of the Defendant LLCs organized and controlled by Sotnikov, and attached a CD account 

application.  After submitting the completed application, the investor received instructions to 

wire their funds to an account in the name of the Sotnikov-controlled entity; and upon receipt of 

the funds into the account, the investor received a fictitious account statement reflecting their 

opening balance. 

96. On January 6, 2020, the perpetrators registered the domain name 

amrbusinessgroup.com with a Cyprus-based domain registrar and created a website for AMR 

Business Group, which appears to be a fictitious entity.  The website did not spoof an actual 

financial institution, but mimicked a website of a real financial institution.  The website falsely 

claimed that AMR Business Group was “an insured FDIC institution” and “FDIC Member,” that 

offered jumbo CDs.  The website repeated many of the same specific phrases the perpetrators 

had used in many of their previous websites, including offering no penalty, above-market-rate 

CDs.   

97. The following day, on January 7, 2020, the perpetrators registered the domain 

name — atlbusinessgroup.com — corresponding with the Wyoming LLC Sotnikov had 

organized six weeks earlier.  The domain was registered with a Russia-based domain registrar.  

The ATL Business Group website that subsequently appeared in this iteration of the scheme was 

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practically identical to the spoofed AMR Business Group website, using the same business 

telephone number and address and similar text.   

98. On January 8, 2020, an investor expressed interest in the CDs being offered by 

either AMR Business Group or ATL Business Group and received an email with an attached CD 

application from an email address (“Email Address 3”) that used the name of a real person who 

worked as an investment adviser at an affiliate of Bank 5 who, upon information and belief, had 

no knowledge of the scheme (“Alias 2”).  The person using Alias 2 claimed to be a “Senior 

Account Executive” at “AMR Wealth – [Bank 5] Group,” and provided a Los Angeles address 

for a Bank 5 branch, Bank 5’s actual FDIC number, and the real registered investment advisor’s 

FINRA CRD number.  In fact, the spoofed domain name and the Email Address 3 account had 

been registered by the perpetrators on January 6, 2020. 

99. After receiving the email, the investor completed and submitted a CD application 

identical to the previous applications, with the exception that this version of the CD application 

used Bank 5’s logo.  The very next day, the investor received a welcoming email from the person 

using Alias 2 which, like the past iterations, stated that “your account is now active, and ready 

for funding,” and attached instructions to fund the CD purchase by wiring funds to “our clearing 

partner Cleared by ATL Business Group LLC through [Bank 5].”  The wire instructions directed 

the investor to wire the funds to Defendant ATL Business Group’s account at Bank 5, an account 

opened by Sotnikov just two weeks earlier and for which he had sole signatory authority.   

100. On January 10, 2020, the investor wired $250,000 to ATL Business Group’s Bank 

5 account.  The next business day – Monday, January 13, 2020 – the investor received an 

“account statement” showing his opening balance of $250,000, as well as a $25 credit to refund 

the investor’s wire transfer fee.   

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101. On January 13, 2020, Sotnikov withdrew $9,000 from ATL Business Group’s 

Bank 5 account and wired $20,000 to a corporate account at a Russian bank.  On the same day, 

Sotnikov withdrew $9,000 from ATL Business Group’s account at a Bank 5 branch in 

Hallandale Beach, Florida.  On January 14, 2020, Sotnikov wired $215,000 to Relief Defendant 

Great Imperial’s account at Bank 3, an account controlled by Relief Defendant Mazitova.   

102. The amrbusinessgroup.com website was taken down on January 13. 

103. On January 21, 2020, another investor submitted an account opening application 

to the person using Alias 2 at Email Address 3.  On January 21, after the person using Alias 2 

confirmed (falsely) that the investor’s CD account had been opened, the investor wired $500,000 

to ATL Business Group’s Bank 5 account, an account opened and controlled by Sotnikov.   

104. On January 21, 2020, the same day the investor funds were received into ATL 

Business Group’s Bank 5 account, Sotnikov withdrew $5,000 from the account at a Bank 5 

branch in Sunny Isles, Florida.  On January 22, 2020, Sotnikov wrote a $470,000 check from 

ATL Business Group’s Bank 5 account for deposit into the Bank 4 account of Relief Defendant 

Inteko Cargo, another account controlled by Sotnikov in the name of an entity he organized and 

controls. 

105. On January 22, 2020, the day after the investor’s funds were received into Relief 

Defendant ATL Business Group’s Bank 5 account, and as Defendants Sotnikov and ATL 

Business Group were actively depleting the investor’s funds, the investor received an “account 

statement” showing an “opening balance” of $500,000 and a $25 credit to refund the investor’s 

wire fee.  The “account statement” did not disclose that Sotnikov and ATL Business Group had 

diverted most of the investor’s funds. 

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106. On January 27, 2020, two additional investors (a married couple) received an 

email from the person using Alias 2 at Email Address 3 that said “Thank you so much for 

allowing us to help you with your recent inquiry and account opening procedures. . . . ATL 

Wealth Management Group-[Bank 5] is a full service, global financial institution.”  The email 

attached an application to open an account for a $200,000 Jumbo CD with “ATL Wealth, A 

[Bank 5] Company – Member FDIC.”  After completing and returning the application to 

purchase a $225,000 CD, the investors received another email from the person using Alias 2 

describing “ATL Wealth Group” as a “registered FDIC Institution of [Bank 5].”  Upon 

information and belief, “ATL Wealth Group” does not exist, and Defendant ATL Business 

Group is neither an FDIC member nor an affiliate of the real Bank 5.  Instead, Defendant ATL 

Business Group’s bank accounts are controlled by Sotnikov, and the only business activity 

observable from ATL Business Group’s banking records is the laundering by Sotnikov of funds 

received from duped investors. 

107. The following day, January 28, 2020, the investors received a letter from Alias 2 

informing them that “on behalf of our entire ATL-[Spoofed Bank 4] & [Bank 5] staff,” their 

application had been approved and their account was now open.16  The letter claimed that the 

investors’ CD purchases were “cleared by [Bank 2] through Adaptive Technology LLC.”  And 

the attached wire instructions stated:  “Cleared by AMR Business Group LLC through [Bank 4]” 

and instructed the investors to wire their funds to Adaptive Technology’s [Bank 2] account.  

Defendant Adaptive Technology is not a clearing firm, nor does it offer or sell legitimate CDs or 

other securities.  Adaptive Technology’s bank accounts are controlled by Sotnikov, and the only 

                                                             
16  This email also used a name almost identical to that of a large financial institution offering 
investment banking and other services (“Spoofed Bank 4”), a firm that was featured in a 
subsequent iteration of the scheme described below. 

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business activity observable from its banking records is the laundering by Sotnikov of funds 

received from duped investors. 

108. On January 27, 2020, Bank 5 closed Adaptive Technology’s account.   

109. On January 28, 2020, Sotnikov opened a new bank account for Adaptive 

Technology at Bank 2.  Shortly thereafter, the person using Alias 2 used Email Address 3 to 

direct investors to wire funds to the new Adaptive Technology account at Bank 2. 

110. On January 28, 2020, after receiving updated instructions from the person using 

Alias 2, the investors wired their $225,000 investment to Adaptive Technology’s new account at 

Bank 2.  On January 29, 2020, the investors received an “account statement” showing their 

$225,000 deposit.   

111. On January 30, 2020, Sotnikov transferred $22,500 from Adaptive Technology’s 

Bank 2 account to a bank account in Russia. Shortly thereafter, Adaptive Technology’s account 

was frozen by Bank 2. 

112. Also on January 30, 2020, the atlbusinessgroup.com website was taken down. 

VII. Spoofed Bank 4 – Sotnikov and Adaptive Technology  

113. Defendants Sotnikov and Adaptive Technology were also instrumental in the next 

iteration of the spoofing scheme. 

114. On or about on January 28, 2020, the perpetrators registered another spoofed 

website with a U.S. domain registrar, using a name almost identical to that of a large financial 

institution offering investment banking and other services (“Spoofed Bank 4”), and created an 

email account (“Email Address 4”) that combined the name of Spoofed Bank 4 and the name of 

a real broker affiliated with Spoofed Bank 4 who, upon information and belief, had no 

knowledge of the scheme (“Alias 3”). 

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115. The website purported to offer high interest rate CDs from Spoofed Bank 4.  The 

website was similar to the previous websites, offering no penalty, above-market-rate CDs.  

However, unlike the websites used in prior iterations of the scheme, this website identified Bank 

2, Bank 4, Bank 5, and another well-known bank (“Bank 6”), all legitimate U.S. financial 

institutions, as clearing partner banks.  The website provided the same telephone number as one 

of the prior websites and the same address as the real Spoofed Bank 4’s Los Angeles office. 

116.  Two potential investors found the website through an Internet search of CD rates, 

called the number provided, and spoke to a person who identified himself as Alias 3, the name of 

an actual registered investment adviser at Spoofed Bank 4.   

117. On January 29, 2020, one of the investors received a follow up email from Email 

Address 4, in which the person using Alias 3 identified himself as a “Senior Account Executive” 

at Spoofed Bank 4, and provided Spoofed Bank 4’s real FINRA CRD number.   

118. The email to the investor, which enclosed a CD account application, stated that 

the fictitious bank offering the CDs “is a Registered FDIC Institution of [Spoofed Bank 4].  

Securities offered through Adaptive Technology LLC Clearing through [Bank 2].  Member 

FINRA/SIPC.  Investment Advisory Services offered through [Spoofed Bank 4]” (emphasis 

added). 

119. In fact, Defendant Adaptive Technology, an entity Sotnikov formed three months 

earlier and that he controlled, was not a clearing firm, nor did it offer or sell legitimate CDs or 

other securities.  Adaptive Technology had no affiliation with Spoofed Bank 4 and no affiliation 

with Bank 2 other than maintaining an account at Bank 2. 

120. On January 29, 2020, the investor returned the completed application to purchase 

a $350,000 CD, and later that day received another email from an individual using Alias 3.  The 

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second email stated that his account was “now active, and ready for funding” and instructed him 

to wire his investment to “our clearing partner Cleared by [Bank 2] through Adaptive 

Technology LLC.”  

121. The wire instructions directed the investor to send the funds to Adaptive 

Technology’s Bank 2 account, an account that Sotnikov had opened the previous day and that he 

controlled. 

122. Luckily, the potential investor conducted additional due diligence before 

transferring any funds pursuant to the instructions received from the person using Alias 3.  The 

potential investor contacted the real Spoofed Bank 4 investment advisor whose identity was 

being used by the perpetrators, learned that the website was fake, and did not wire any funds to 

Adaptive Technology.   

123. The Spoofed Bank 4 website was taken down on February 4, 2020 after Spoofed 

Bank 4 complained to the domain registrar. 

VIII. Spoofed Bank 5 – Defendants Sotnikov and AGQ Business Group 

124. Defendants Sotnikov and AGQ Business Group were instrumental to the latest 

iteration of the scheme, which is markedly similar to other iterations described in this Complaint. 

125. On February 3, 2020, Sotnikov formed Defendant AGQ Business Group, listing 

himself as “manager” in papers filed with the State of Florida.  On February 19, 2020, Sotnikov 

opened a bank account for AGQ Business Group at Bank 3.  The account opening documents 

state that AGQ Business Group is in the “[f]looring and kitchen construction” business.  

Sotnikov has sole signatory authority over the account.   

126. Based on information and belief and available bank records, Sotnikov is a 36-

year-old Russian citizen who lives in Florida, but in opening the Bank 3 account for AGQ 

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Business Group, he falsely claimed to be a 34-year old Spanish citizen living in Milan, Italy and 

presented a false Spanish passport.   

127. On February 11, 2020, using a domain registrar in Russia, the perpetrators 

registered a website using a domain name similar to that of a well-known national bank 

(“Spoofed Bank 5”). 

128. The website described high-interest-rate, no-penalty CDs with a minimum deposit 

of $200,000 purportedly offered by an affiliate of Spoofed Bank 5.  The website claimed that all 

accounts were FDIC-insured and that deposits in those accounts were maintained by Spoofed 

Bank 5 and cleared by “[Spoofed Bank 5] Clearing Systems (DGQ & AGQ)” (emphasis added). 

129. On February 13, two investors who inquired about the CDs offered on the website 

received introductory emails from an individual claiming to be a “Senior Account Executive” at 

Spoofed Bank 5 and using the name of a real registered investment adviser employed by an 

affiliate of Spoofed Bank 5 (“Alias 4”) who, upon information and belief, had no knowledge of 

the scheme.  The person using Alias 4 used the FINRA CRD number for the real investment 

adviser of the same name.   

130. The email attached a CD application nearly identical to the applications used by 

the perpetrators in prior iterations of the scheme, and stated:  “Securities offered through 

clearing via DGQ, AGQ, & [Spoofed Bank 5] FDIC.  Member FINRA/SIPC.  Investment 

Advisory Services offered through [Spoofed Bank 5] Direct Banking Group & Wealth 

Management” (emphasis added). 

131. After submitting a completed application on February 19, the investors received 

the standard welcoming email explaining that their CD account was “now active and ready for 

funding,” and attaching wire instructions.  The emails and wiring instructions from the person 

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using Alias 4 claimed that the CDs were “[c]leared by AGQ Business Group LLC through 

[Bank 3]” (emphasis added).  The wiring instructions directed the investors to wire their funds to 

the AGQ Business Group account at Bank 3.From February 21 to 26, 2020, six investors wired a 

total of $1,838,000 to AGQ Business Group’s Bank 3 account, an account controlled by 

Sotnikov:  On February 21, 2020, two investors wired $450,000; on February 25, 2020, another 

investor wired $232,000; on February 25, 2020, another investor wired $931,000; and on 

February 26, 2010, another investor wired $225,000 into the account.  Within a business day of 

wiring their funds, investors received fictitious “account statements” showing their opening 

balance and a credit for the wire transfer fee.  At least one of the fictitious account statements 

included an amount for “interest earned” in the “account balance.” 

132. On February 21, 2020, the two investors wired $450,000 to AGQ Business 

Group’s Bank 3 account.  On February 24, 2020 these investors received a fictitious “account 

statement” showing their “opening balance,” “interest earned,” and a “credit” for the wire 

transfer fee.   

133. On February 21, 2020, two additional investors who had inquired about the CDs 

offered on the website received a similar introductory email from the person using Alias 4.  On 

February 25, 2020, after submitting the completed application, these investors received the 

standard welcoming email attaching wire instructions.  On February 25, 2020, these two 

investors wired $931,000 to the AGQ Business Group account. 

134. On February 24, 2020, another investor who inquired about the CDs offered on 

the website received a similar introductory email from a person using Alias 4.  After submitting 

the completed application, this investor received the standard welcoming email attaching wire 

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instructions.  On February 25, 2020, this investor wired $232,000 to the AGQ Business Group 

account at Bank 3, and received a fictitious “account statement” on February 26, 2020.   

135. Another investor who inquired about the CDs offered on the website received a 

similar introductory email from an individual using Alias 4.  After submitting the completed 

application on February 25, 2020, this investor received the standard welcoming email attaching 

wire instructions.  On February 26, 2020 this investor wired $225,000 to the AGQ Business 

Group account at Bank 3, and received a fictitious “account statement” on February 27, 2020. 

136. On February 21, 2020, Defendant Sotnikov wrote a check for $250,000 from 

AGQ Business Group’s Bank 3 account to Relief Defendant Inteko Cargo, another LLC he 

controls.  The check was deposited into an Inteko Cargo account at Bank 5, an account opened 

and controlled by Sotnikov.  That same day, Sotnikov wrote a check to himself from the Inteko 

Cargo account at Bank 5 for $190,000, which was deposited into an unidentified account at a 

Florida bank.  Upon information and belief, the remaining funds in AGQ Business Group’s 

account at Bank 3 have been frozen. 

FIRST CLAIM FOR RELIEF 
 

Violations of Section 17(a)(1) and 17(a)(3) of the Securities Act 
 

(Defendants Sotnikov, Adaptive Technology, AGQ Business Group, ATL Business Group,  
BO&SA, DN Industrial, and Expert Digital) 

 
137.  The Commission re-alleges and incorporates paragraphs 1 through 136 as if fully 

set forth herein. 

138. Sotnikov and the Defendant LLCs, by use of the means or instrumentalities of 

interstate commerce or of the mails, in the offer or sale of securities, directly or indirectly, with 

scienter, employed devices, schemes, or artifices to defraud; and/or engaged in any transaction, 

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practice, or course of dealing which operated or would operate as a fraud or deceit upon the 

purchaser. 

139. By reason of the actions alleged herein, Sotnikov and the Defendant LLCs 

violated Section 17(a)(1) and 17(a)(3) of the Securities Act [15 U.S.C. § 77q(a)(1), (3)] and 

unless restrained and enjoined will continue to do so. 

SECOND CLAIM FOR RELIEF 
 

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

(Defendants Sotnikov, Adaptive Technology, AGQ Business Group, ATL Business Group, 
BO&SA, DN Industrial, and Expert Digital) 

 
140. The Commission re-alleges and incorporates paragraphs 1 through 136 as if fully 

set forth herein. 

141. By engaging in the conduct described above, Sotnikov and the Defendant LLCs, 

with scienter, by use of the means or instrumentalities of interstate commerce, in connection with 

the purchase or sale of a security: (a) 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 conduct which operated or would 

operate as a fraud or deceit. 

142. By reason of the actions alleged herein, Sotnikov and the Defendant LLCs 

violated Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and 10b-5(c) 

thereunder [17 C.F.R. § 240.10b-5(a), (c)] and unless restrained and enjoined will continue to do 

so. 

  

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THIRD CLAIM FOR RELIEF 

Aiding and Abetting Violations of Section 17(a) of the Securities Act  

(Defendant Sotnikov) 

143. The Commission realleges and incorporates by reference each and every 

allegation in paragraphs 1 through 136, inclusive, as if they were fully set forth herein.   

144. Sotnikov, by engaging in the conduct described above, singly or in concert, 

directly or indirectly, knowingly or recklessly provided substantial assistance to the Defendant 

LLCs, each of which by use of the means or instrumentalities of interstate commerce, or by use 

of the mails, in the offer or sale of securities, knowingly or recklessly employed devices, 

schemes, or artifices to defraud; and knowingly, recklessly or negligently engaged in 

transactions, practices, or courses of business which operated or would operate as a fraud or 

deceit upon purchasers of securities. 

145. By engaging in the conduct described above, Sotnikov aided and abetted, and, 

unless restrained and enjoined, will continue aiding and abetting, violations of Sections 17(a) of 

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

FOURTH CLAIM FOR RELIEF 

Aiding and Abetting Violations of Section 10(b) of the Exchange Act  

(Defendant Sotnikov) 

146. The Commission realleges and incorporates by reference each and every 

allegation in paragraphs 1 through 136, inclusive, as if they were fully set forth herein.   

147. Sotnikov, by engaging in the conduct described above, singly or in concert, 

directly or indirectly, knowingly or recklessly provided substantial assistance to the Defendant 

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

instrumentalities of interstate commerce, or of the mails, or of any facility of any national 

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securities exchange, knowingly or recklessly employed devices, schemes, or artifices to defraud; 

and knowingly or recklessly engaged in acts, practices, or courses of business which would 

operate as a fraud or deceit upon other persons. 

148. By engaging in the conduct described above, Sotnikov aided and abetted, and, 

unless restrained and enjoined, will continue aiding and abetting, violations of Section 10(b) of 

the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].  

FIFTH CLAIM FOR RELIEF 

Unjust Enrichment  

(Relief Defendants Mazitova, Great Imperial, HRC Clearing, and Inteko Cargo) 

149. The Commission realleges and incorporates by reference each and every 

allegation in paragraphs 1 through 136, inclusive, as if they were fully set forth herein. 

150. Between February 2019 and February 2020, the Defendants have diverted to 

accounts held in the name of the Relief Defendants proceeds from the Defendants’ fraudulent 

scheme as part of, and in furtherance of, the securities law violations alleged above.   

151. The Relief Defendants have no legitimate claim to these ill-gotten gains, which 

are proceeds of the securities fraud alleged above, and it is not just, equitable, or conscionable 

for the Relief Defendants to retain the funds.   

152. Accordingly, the Relief Defendants are liable as Relief Defendants for unjust 

enrichment and must disgorge the amount of their ill-gotten gains. 

  

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PRAYER FOR RELIEF 

 WHEREFORE, the SEC respectfully requests that the Court enter a judgment: 

(i) Finding that Sotnikov, Adaptive Technology, AGQ Business Group, ATL Business 
Group, BO&SA, DN Industrial, and Expert Digital violated the provisions of the 
federal securities laws as alleged herein; 

(ii) Finding that Sotnikov aided and abetted the violations of the federal securities laws 
committed by the Defendant LLCs as alleged herein; 

(iii) Permanently restraining and enjoining Sotnikov, Adaptive Technology, AGQ 
Business Group, ATL Business Group, BO&SA, DN Industrial, and Expert Digital 
from violating Section 10(b) of the Exchange Act and Rule 10b-5 thereunder and 
Section 17(a) of the Securities Act; 

(iv) Permanently restraining and enjoining Sotnikov from, directly or indirectly, aiding 
and abetting violations of Section 17(a) of the Securities Act, Section 10(b) of the 
Exchange Act and Rule 10b-5 thereunder; 

(v) Ordering Sotnikov, Adaptive Technology, AGQ Business Group, ATL Business 
Group, BO&SA, DN Industrial, and Expert Digital to disgorge an amount equal to the 
proceeds of the conduct alleged herein and to pay prejudgment interest thereon; 

(vi) Ordering Sotnikov, Adaptive Technology, AGQ Business Group, ATL Business 
Group, BO&SA, DN Industrial, and Expert Digital to pay a civil monetary penalty 
pursuant to Section 21A of the Exchange Act and Section 20(b) of the Securities Act;  

(vii) Ordering the Relief Defendants to disgorge all ill-gotten gains to which they do not 
have a legitimate claim received as a result of the conduct alleged in the Complaint, 
together with prejudgment interest; and  

(viii) Granting such other and further relief as this Court may deem just and proper. 

  

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DEMAND FOR JURY TRIAL 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands 

trial by jury in this action of all issues so triable. 

Dated:  March 13, 2020  Respectfully submitted,   

/s/John J. Bowers     
      John J. Bowers 

Thomas A. Bednar 
      100 F Street, NE 
      Washington, DC 20549-4473  
      Telephone: 202-551-4645 (Bowers) 
      Email:  [email protected] 
       

COUNSEL FOR PLAINTIFF SECURITIES  
      AND EXCHANGE COMMISSION 
     

  

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43 
 

DESIGNATION OF AGENT FOR SERVICE 

Pursuant to Local Rule 101.1(f), because Plaintiff Securities and Exchange Commission 

(the “Commission”) does not have an office in this district, the United States Attorney for the 

District of New Jersey is hereby designated as an alternative to the Commission to receive 

service of all notices or papers in the captioned action.  Therefore, service upon the United States 

Attorney’s Office or its authorized designee: 

David E. Dauenheimer  
Deputy Chief, Government Fraud Unit 
United States Attorney’s Office 
District of New Jersey  
970 Broad Street, Suite 700 
Newark, NJ 07102-2534 
 

shall constitute service upon the Commission for purposes of this action. 

Dated:  March 13, 2020  Respectfully submitted,   

/s/John J. Bowers     
      John J. Bowers 
      100 F Street, NE 
      Washington, DC 20549-4473  
      Telephone: 202-551-4645  
      Email:  [email protected] 
 

COUNSEL FOR PLAINTIFF SECURITIES  
      AND EXCHANGE COMMISSION 

 

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