SEC v. Jeffrey Goldman; and Christopher Eikenberry, No. 2:18-cv-13550, District of New Jersey (Jan. 1, 2018) — Complaint

Joseph G. Sansone
Chief, Market Abuse Unit
Simona K. Suh
Barry P. O’Connell
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
Brookfield Place
200 Vesey Street, Suite 400
New York, NY 10281
(212) 336-0103 (Suh)
Email: [email protected]
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
-against-
JEFFREY GOLDMAN and CHRISTOPHER
EIKENBERRY,
Defendants.
No. 18 Civ. _______
COMPLAINT
JURY TRIAL DEMANDED
Plaintiff Securities and Exchange Commission (“Commission” or “SEC”) files this
Complaint against Defendant Jeffrey Goldman (“Goldman”) (who, upon information and belief,
resides at Stratford Drive, West Bloomfield, Michigan 48322) and Defendant Christopher
Eikenberry (“Eikenberry”) (who, upon information and belief, resides at Larchlea Drive,
Birmingham, Michigan 48009) (together, “Defendants”), and alleges as follows:

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SUMMARY
1.This case concerns Defendants Goldman’s and Eikenberry’s participation in an
illegal scheme to establish and operate an offshore broker-dealer, Nonko Trading (“Nonko”),
without the necessary registration and later to defraud Nonko’s customers by providing them
with fake trading accounts and stealing funds that these customers deposited with the firm.  The
scheme resulted in at least $1.4 million in net losses to over 260 investors in over 30 countries
worldwide, including over 180 investors in the United States.
2.Between 2011 and early 2013, Goldman and Eikenberry, who both had extensive
experience in day-trading operations, helped their associate Naris Chamroonrat (“Chamroonrat”)
to establish Nonko as a purported offshore proprietary trading firm that would secretly cater to
U.S.-based day-traders while also evading the U.S. broker-dealer registration requirements.
Once Nonko was established, starting in late 2013, Goldman and Eikenberry worked with
Chamroonrat and his Nonko associates to develop and execute a fraudulent scheme to pocket
Nonko’s customer deposits by secretly providing certain customers with fake accounts instead of
real ones.
3.As alleged in the SEC’s Amended Complaint against Chamroonrat and his Nonko
associates Yaniv Avnon (“Avnon”), Ran Armon (“Armon”), and Adam Plumer (“Plumer”), as
well as Avnon’s entity G Six Trading Y.R Ltd (“G6”) and Chamroonrat’s entity NKO Holdings
Co. Ltd,
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 the Nonko team lured investors to day-trade through Nonko with promises of generous
leverage, low trading commissions, and low minimum deposit requirements.  But instead of
providing investors with access to a live securities trading platform, as it had promised, the
Nonko team secretly provided certain investors with training accounts that merely simulated the
1
  SEC v. Chamroonrat, et al., 16-CV-09403-KM-JBC (D.N.J.) (DE 10).

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placement and execution of trade orders.  So when these investors sent funds to Nonko and
proceeded to place what they believed were securities trade orders, the orders were never
actually routed to the markets.  Instead, the Nonko team simply stole the investors’ money, using
it, among other things, to fund their personal expenses and to make Ponzi-like payments to those
investors who asked to close their Nonko accounts.
4.As set forth below, Goldman and Eikenberry were knowing and substantial
participants in the training accounts fraud, providing the rest of the Nonko team with extensive
guidance and direction, including on the specific lies that the Nonko team should tell investors in
order to evade detection.  Goldman and Eikenberry also provided the Nonko scheme with
operational and back-office support.
5.Goldman and Eikenberry deliberately concealed their involvement with Nonko
by, among other things, avoiding direct contact with Nonko’s customers and inserting multiple
intermediary entities, both offshore and domestic, between Nonko and themselves.
6.For their roles in the scheme, Goldman and Eikenberry collected an agreed-upon
portion of the fraud’s proceeds, which they funneled to themselves through bank accounts of the
intermediary entities.
VIOLATIONS
7.By virtue of the conduct alleged herein, Goldman and Eikenberry each violated
and aided and abetted violations of Section 17(a) of the Securities Act of 1933 (“Securities Act”)
[15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“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 aided and abetted violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and

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Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)] and Section 15(a)(1) of the Exchange Act
[15 U.S.C. § 78o(a)(1)].
8.Unless Goldman and Eikenberry are permanently restrained and enjoined, they
will again engage in the acts, practices and courses of business set forth in this Complaint and in
acts, practices and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
9.The Commission brings this action under the authority conferred upon it by
Sections 20(b) and (d) of the Securities Act [15 U.S.C. § 77t(b), (d)], and Sections 21(d)(1), (3)
and (5) of the Exchange Act [15 U.S.C. §§ 78u(d)(1), (3), (5)].  The Commission seeks a final
judgment: (a) permanently restraining and enjoining each Defendant from engaging in the acts,
practices and courses of business alleged herein; (b) requiring each Defendant to disgorge ill-
gotten gains and to pay prejudgment interest thereon, on a joint and several basis with each
other; and (c) imposing civil money penalties on each Defendant pursuant to Sections 20(d) of
the Securities Act [15 U.S.C. § 77t(d)] and 21(d)(3) of the Exchange Act [15 U.S.C. §
78u(d)(3)].
JURISDICTION AND VENUE
10.This Court has jurisdiction over this action pursuant to Sections 22(a) and (c) of
the Securities Act and Section 27 of the Exchange Act [15 U.S.C. §§ 77v(a), 77v(c), 78aa].
11.Venue lies in this District pursuant to Section 22(a) of the Securities Act and
Section 27(a) of the Exchange Act [15 U.S.C. §§ 77v(a), 78aa(a)].  Some of the acts, practices,
courses of business and transactions constituting the violations alleged herein occurred within the
District of New Jersey.  Among other things, many of the fictitious securities transactions
reported to the victims of the Nonko fraud were generated via a server located in the District of

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New Jersey.  The trading simulator program used in the Nonko fraud starting in September 2014
relied on a market data stream provided by a New Jersey-headquartered vendor, retained for the
scheme by Chamroonrat and his associates.  In addition, multiple residents of the District of New
Jersey were among the victims of the fraud.  From the District of New Jersey, these victims
submitted to Nonko securities trade orders that the victims believed were real but in fact were
never sent to or executed in the market.
DEFENDANTS
12.Goldman, age 52, resides West Bloomfield, Michigan.   Goldman held multiple
securities licenses and was associated with a number of registered broker-dealers between 1990
and 2017, including during the time period of his involvement with the Nonko fraud, as alleged
herein.  Over the years, Goldman frequently partnered with Eikenberry in various ventures,
including those related to securities trading.
13.Eikenberry, age 49, resides in Birmingham, Michigan.  Eikenberry held multiple
securities licenses and was associated with a number of registered broker-dealers between 1991
and 2015, including during the time period of his involvement with the Nonko fraud, as alleged
herein.  Over the years, Eikenberry frequently partnered with Goldman in various ventures,
including those related to securities trading.
NEVIS TRADING AND RELATED ENTITIES
14.Nevis Trading purported to be a non-U.S. proprietary trading firm for non-U.S.
online day-traders.  Goldman and Eikenberry established, controlled, and ran Nevis Trading,
with Chamroonrat’s assistance, for several years before the launch of Nonko.  Using nominees as
purported shareholders and officers, Goldman and Eikenberry established a number of offshore
corporate entities in connection with Nevis Trading’s operations, including Nevis Capital LLC

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(a Nevis limited liability company, with a registered office in Charlestown, Nevis, and with bank
accounts in Belize and the Cook Islands); Nevis Capital Trading Co. Ltd. (a limited company
registered in Thailand, with a registered address in Thailand, and with bank accounts in
Thailand); and Nevis Trading Group, LLC (a Nevis limited liability company, with a registered
office in Charlestown, Nevis, and with bank accounts in Belize) (together, the “Nevis Entities”).
After the launch of Nonko as a separate business, as alleged below, Goldman and Eikenberry
used the Nevis Entities, among other things, as a buffer between themselves and Nonko, so as to
distance themselves from and conceal their roles in the fraud.  In particular, Goldman and
Eikenberry used the Nevis Entities’ offshore bank accounts to funnel to themselves their portion
of the illicit proceeds generated by the Nonko fraud.
FACTS
A. Goldman’s and Eikenberry’s Roles in the Creation of Nonko
15.In approximately 2011, while operating Nevis Trading together with
Chamroonrat, Goldman and Eikenberry suggested to Chamroonrat that the three of them launch
a separate business that would expand Nevis Trading’s customer base to U.S.-based traders
while also evading U.S. broker-dealer registration requirements and related regulations.
16.As these plans became more specific, Goldman and Eikenberry instructed
Chamroonrat to create two layers of separation between the customers of the new firm and any
clearing or trading firms that would process the customers’ real (as opposed to simulated)
securities transactions.  One firm would perform all customer-facing functions, while another
firm, operating under a different name and nominally controlled by different individuals, would
interact with any clearing or trading firms.
17.As Goldman explained to Chamroonrat in a Skype chat in January 2012:

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we need 2 llc's. LLC 1 opens the account with [clearing firm]. We
might be able to use your nevisllc. LLC 2 (lets call it Jerome
Trading) opens an LLC in Nevis. Jerome Trading plugs into
nevicllc.  All our US traders sign paperwork and wire to Jerome
Trading. This adds a layer between the traders and nevisllc and
allows us (nevisllc) to say that we only know our trader as Jerome
Trading who has multiple sub accounts
18.This multi-layered structure would allow Goldman and Eikenberry to deny
knowledge that their operation serviced U.S.-based customers.  As Goldman explained to
Chamroonrat via Skype, this structure also ensured that the “clearing firm doesnt [sic] know they
[the customers] are US.”
19.Although the name of the customer-facing firm ultimately became “Nonko
Trading” rather than from “Jerome Trading” (a reference to the first name of a nominee that
Goldman and Eikenberry often used for the offshore entities they controlled), in substance,
Nonko’s operation was structured exactly as Goldman laid out in that January 2012 chat.  Nonko
was the firm that interacted with investors:  It solicited investors to open accounts, entered into
agreements with them, received their funds, provided them with trading technology (real or
simulated), and answered their inquiries.  Nevis Trading and the Nevis Entities, on the other
hand, maintained relationships with trading firms that processed any real, rather than simulated,
trading of Nonko’s customers.
20.Goldman and Eikenberry closely collaborated with Chamroonrat in establishing
Nonko’s operations.  For example, until at least March 2014, Goldman administered Nonko’s
back-office and accounting system, monitored users’ activities and account balances, and stayed
in constant contact with Chamroonrat via Skype about all aspects of Nonko’s business.

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21.Eikenberry, among other things, supervised every step of establishing the Belize
bank accounts for the Nonko business, guiding Chamroonrat step-by-step through the required
paperwork via Skype.
22.Eikenberry also advised Chamroonrat to move Nonko’s back-office and
accounting operations from its initial third-party system to the system provided by another,
smaller third-party provider – a step that Chamroonrat began working on in the second half of
2013 and fully implemented, under Goldman’s and Eikenberry’s ongoing supervision, by early
March 2014.
23.In September 2013, Chamroonrat asked Eikenberry, in a Skype chat, whether to
pay the new back office system provider from Nonko’s bank account or from Chamroonrat’s
personal bank account in the U.S.  Even though the wire fees at the U.S. bank were three times
lower, Eikenberry advised Chamroonrat to pay from “nonko[;] keep it clean.”  Chamroonrat
followed Eikenberry’s direction and paid the provider from Nonko’s Belize bank account.
B. Goldman’s and Eikenberry’s Roles in the Nonko Training Accounts Fraud
24.By late 2013, under Goldman’s and Eikenberry’s ongoing but concealed
guidance, Nonko was operating as a purported proprietary trading firm for investors seeking to
engage in electronic day-trading in the United States securities markets.
25.To attract day-traders, Chamroonrat, through Nonko, offered terms that were not
available at any SEC-registered broker-dealer in the United States, including low trading
commissions (typically at or below $0.006 per share), a minimum deposit of only $2,500 (and
occasionally lower), as well as leverage (or margin) of 20:1 (that is, purporting to give traders the
ability to trade $20 of total capital for each dollar deposited).  Such low account balances and

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high leverage ratios are prohibited for many day traders in the United States under FINRA’s
rules.
26.In late 2013, Goldman, Eikenberry, Chamroonrat, and Chamroonrat’s close
Nonko associate Avnon conceived of the training accounts scheme as a way to profit from the
frequent trading losses of Nonko’s day-trading customers.  At that time, Nonko gave its
customers live accounts set up on an electronic securities trading platform provided by a third-
party vendor (“Platform A”).  As is common in electronic securities trading, Platform A had a
training account module, typically provided to new users of the software, so that they could
become familiar with its features in a simulated trading environment.  These training accounts on
Platform A accessed a trading simulator program that was not programmed to send the users’
“orders” to any market centers for execution, but simply generated records of potential, or
simulated, “executions” of the orders, based on then-current market prices for the securities in
question.
27.Observing that many of Nonko’s day-trading customers often lost money in the
market, the Nonko team decided to take advantage of this pattern by secretly providing some of
Nonko’s customers with training accounts instead of live ones and simply pocketing those
customers’ deposits.  To minimize the risk of detection, Goldman, Eikenberry, Chamroonrat, and
Chamroonrat’s associates Avnon, Armon, and later Plumer targeted traders who appeared
inexperienced or unsophisticated, or had a history of trading losses.  The Nonko team reasoned
that such traders were likely to place more losing trades and thus unlikely to ask to withdraw
funds from their accounts.
28.In Skype chats, emails, and other internal communications, the Nonko team
(including Goldman and Eikenberry) referred to the scheme as their “TRZ program,” named

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after the prefix “TRZ” that all of Nonko’s training accounts were assigned on Platform A.  From
the launch of the training accounts scheme in late 2013, Goldman and Eikenberry both
understood that Nonko’s “TRZ program” involved holding out training accounts as real ones to
unwitting traders and pocketing the traders’ deposits.
29.In early December 2013, during the initial phases of the training accounts scheme,
Goldman commented to Chamroonrat on Skype:  “trz group down 3k...every trader down.  How
come part of me feels good and part of me feels bad?!?!??”
30.Later, on December 17, 2013, Goldman questioned Chamroonrat, “why are you
letting TRZNK3015 make money??”
31.Two days later, on December 19, 2013, Goldman pushed Chamroonrat to finalize
the split of proceeds among the scheme’s participants:  “whats the deal if a guy deposits $5,000
and loses $5,000.  How is that being split between Nonko and Yaniv [Avnon] and [another
Nonko associate]?”
32.Goldman continued to work with Chamroonrat to perpetrate the scheme on a
nearly daily basis until approximately April 2014, managing the back-office and accounting
program that the group used and keeping track of activity and balances in all user accounts.
33.Similarly, Eikenberry at all times understood the fraudulent nature of Nonko’s
training accounts scheme and advised Chamroonrat how to manage the fraudulent training
accounts.  For example, in July 2014, in a Skype chat with Chamroonrat about the planned move
of the scheme from Platform A to Nonko’s own trading simulator program called Logix,
Eikenberry expressed a concern that some traders could figure out how to game the new
platform.  Chamroonrat then reminded Eikenberry of Nonko’s existing approach as follows:
the current frame work [sic] now with TRZ is that we interview the
traders first and make sure they are complete newbs before putting

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them on TRZ, while at the same time, we have a close watch to see
which account is starting to make money, at any point in time they
start to show signs of profitablity [sic] we quickly switch them
over to a NTRD account (live)
with this new platform, we will use the same process but as we
expect to have smaller deposits and more new accounts, we will
have to figuire [sic] a more stricter way to flag “game” accounts,
we havent [sic] gotten that far yet
34.In response, Eikenberry commented:  “easy flag is anyone that makes money over
1k or is up for the week[;]most of these guys just grind themselves.”  Eikenberry and
Chamroonrat then proceeded to discuss the estimated costs and profit splits in the group after the
move to Logix.  After Chamroonrat detailed to Eikenberry the cost advantages of Logix over
Platform A, Eikenberry approvingly commented, “good plan.”
35.Similar to Goldman, Eikenberry worked closely with Chamroonrat to operate
Nonko and perpetrate the training accounts scheme.  Among other things, Eikenberry managed
multiple aspects of the operation’s finances, handling banking issues and funds transfers, and he
routinely instructed Chamroonrat on how to complete various bank account applications and
what funds transfers to process at what time.
36.In the summer of 2014, the firm that owned and licensed Platform A discovered
Nonko’s training accounts scheme, after a technical inquiry from a Nonko customer revealed that
the customer wrongly believed that his training account was a live one.  On August 29, 2014, the
owner of Platform A sent out an email blast to all Nonko customers alerting them that accounts
starting with “TR” were training accounts; the firm then discontinued its relationship with
Nonko, accusing Nonko of deceiving its customers.
37.Chamroonrat immediately reported this development to Eikenberry by Skype and
asked Eikenberry for guidance on what to tell customers.  Eikenberry responded, “jeff
[Goldman] was saying that you could say that they were on demo today because [Platform A]

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found out that they were moving everyone to their own platform [that is, Logix], or that there
was some kind of miscommunciation [sic] with [Platform A] with shutting all these down.”
38.Following Goldman’s and Eikenberry’s advice, Chamroonrat and his Nonko
associates adopted the “miscommunication” strategy:  They categorically and falsely denied the
allegations of Platform A’s owner and falsely told customers that Nonko was ending its
relationship with Platform A because of poor communication and repeated technical glitches.
Chamroonrat also instructed his team to immediately move all Nonko customers from Platform
A to Logix, the trading simulator program that Chamroonrat had commissioned specifically for
the training accounts scheme.
39.In the following days, Chamroonrat and his Nonko team moved most of Nonko’s
TRZ traders to Logix, which they falsely described to traders as Nonko’s “proprietary trading
system” that was technologically superior to Platform A.  Whenever questioned about the
allegations made by Platform A’s owner, the Nonko team, following Goldman’s and
Eikenberry’s advice, continued to claim that those allegations resulted from a misunderstanding.
Thus, from September 2014 through at least the summer of 2015, Nonko’s fraudulent scheme
continued to operate largely in the same manner as before, with the Logix simulator serving as
its purported trading platform.
C. Goldman’s and Eikenberry’s Roles in
 Nonko’s Material False Statements to Customers
40.Throughout the existence of the training accounts scheme, Chamroonrat and his
Nonko associates Avnon, Armon, and Plumer made repeated and material misrepresentations to
Nonko’s customers, including in emails to customers, on Nonko’s website, in Nonko’s trading
agreements with customers, during phone calls, in Skype chats, and in other interactions with
customers.

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41.For example, on its website, Nonko claimed to offer “state-of-the-art online stock
trading infrastructure, designed to meet the exacting requirements of demanding day trading
professionals” and “the ability to trade a wide range of US stocks and options from a single
trading platform” – when in reality most of Nonko’s business consisted of providing traders with
training accounts and pocketing their deposits.
42.In agreements executed by victims of Nonko’s training accounts scheme, Nonko
stated that each Nonko customer would “select purchases and sales of securities (‘Stock Trades’)
for day-trades in [his or her] Trader Sub-Account” and discussed account balances, commission
rates, trading venue and other trading fees, and other terms of the arrangement as if it was an
arrangement for real securities trading, and without disclosing that the “trading” would, in fact,
be fictitious.
43.After the move to Logix, Nonko’s website described Logix as “one of the world’s
advanced stock trading platforms” that “provides powerful, lightweight access to multiple US
equity and derivatives markets.”  In reality, Logix was merely a trading simulator program, not
capable of sending any orders for execution to any market centers.
44.Chamroonrat and his Nonko associates at all times knew or were reckless in not
knowing that these statements were materially false and misleading.
45.Goldman and Eikenberry provided knowing and substantial assistance to
Chamroonrat’s and his Nonko associates’ material misrepresentations, including by advising
Chamroonrat how to structure the business, how to handle communications with customers, and
how to respond when customers or others questioned Nonko’s legitimacy.
46.For example, in a Skype chat on December 27, 2013, Goldman advised
Chamroonrat on how to deflect any trader suspicions about the anomalous behavior of Nonko’s

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TRZ accounts.  If traders noticed that their simulated “orders” did not change the publicly
disseminated market quotes, Goldman advised, “for why bid/offer doesnt [sic] change can be
explained that it is in a dark pool or being internalized by a wholesale desk.”  Goldman and
Chamroonrat then proceeded to discuss how best to present the accounts to customers without
raising suspicions.  Chamroonrat further noted that he was preparing a checklist for the Nonko
team on TRZ accounts.
47.Later that same day, Chamroonrat circulated to Goldman via Skype a document
entitled “TRZ Guideline” – a guidelines document that Chamroonrat later, in January 2014, also
provided to Plumer as part of Plumer’s “orientation” on joining the Nonko team.  The document
instructed the Nonko team members on which traders should be part of the TRZ program
(novices and those with a history of trading losses), and on what to say if traders questioned any
“anomalies” in their purported trade “executions.”  The suggested explanations included
“alternative routing” and, as Goldman had suggested, “internaliz[ation] by a wholesale desk” and
order routing to dark pools – explanations that were entirely bogus, as all members of the Nonko
team, including Goldman, understood.  When Chamroonrat sent Goldman the guidelines
document, Goldman directly expressed his approval of the document.  Chamroonrat stated “ok
im [sic] sending this out,” and Goldman replied, “excellent.”  Chamroonrat asked Goldman if he
wanted to add anything to the document, and Goldman responded, “no.... looks good.”
48.Similarly, as alleged above, both Goldman and Eikenberry advised Chamroonrat
on how to handle the allegations of fraud made by Platform A’s owner in August 2014.
Chamroonrat and his team swiftly implemented Goldman’s and Eikenberry’s advice, moving
Nonko’s customers to Logix, a trading simulator that they falsely described to customers as

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Nonko’s own and superior trading platform, and falsely claiming that the incident with Platform
A’s owner resulted from mere miscommunication.
49.For their contributions to the Nonko scheme, Goldman and Eikenberry negotiated
a 10-percent cut of the fraud’s proceeds.  Overall, Goldman and Eikenberry together withdrew at
least $100,000 from the Nonko scheme, funneling these withdrawals first through offshore
accounts of the Nevis Entities and then through U.S.-based accounts of entities that Goldman and
Eikenberry controlled.
50.Although Goldman’s day-to-day involvement with the Nonko fraud declined after
approximately April 2014, Goldman stayed in contact with Eikenberry and the Nonko team.  As
alleged above, in August 2014, Goldman advised the Nonko team on how to handle Platform A
owner’s allegations of fraud.  In November 2014, when Eikenberry asked Chamroonrat in a
Skype chat, “who all is on the nko [that is, Nonko] team,” Chamroonrat responded, “me, yaniv,
ran, u jeff,” referencing Avnon, Armon, Eikenberry and Goldman.  Approximately a week later,
in mid-November 2014, the Nonko team – consisting of Chamroonrat, Avnon, Armon, Plumer,
Goldman, and Eikenberry – met in Las Vegas to discuss Nonko’s operations.
D. Goldman’s and Eikenberry’s Roles in Nonko’s Unregistered Brokerage Operations
51.As was alleged in the Commission’s Amended Complaint against Chamroonrat
and his Nonko associates
2
, by operating Nonko without broker-dealer registration, Chamroonrat,
Avnon, Armon, Plumer, and Avnon’s entity G6 each violated the U.S. broker-dealer registration
requirements.  Although Nonko held itself out as a proprietary trading firm, in substance, it
operated as a broker, processing fictitious, and in some instances real, securities transactions for
customer accounts.
2
  SEC v. Chamroonrat, et al., 16-CV-09403-KM-JBC (D.N.J.) (DE 10).

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52.Chamroonrat and his Nonko associates aggressively solicited investors to trade
U.S. securities in the U.S. securities markets, including on registered securities exchanges,
through Nonko’s website, social media, individual outreach, and other advertising and marketing
efforts.  These marketing efforts, at least in part, targeted investors based in the United States.
Once a trader signed on to trade through Nonko, the Nonko team, among other things, solicited
and received the trader’s deposits; provided the trader with access to trading technology (real or
simulated); extended credit; handled the trader’s cash and securities (real or fictitious); handled
the trader’s orders (real or simulated); and charged transaction-based compensation, in the form
of per-share commissions.
53.Nonko’s business was at all times focused on trading securities (whether fictitious
or real) in the United States securities markets, and its target customer base consisted largely of
United States residents.  For example, in its marketing materials, Nonko touted its “real-time
access to a wide range of US exchanges,” “reliable real-time access to multiple US markets,
including both equities and derivatives,” and its “access to a wide range of US asset classes.”  In
its agreements with traders, Nonko routinely included instructions for wiring funds from U.S.
banks, instructed customers to send only U.S. Dollar-denominated deposits, and listed a schedule
of fees and rebates to be charged by various U.S. securities exchanges.  No non-U.S. trading
venues were referenced.  Moreover, both fictitious and real transactions executed for Nonko’s
customers routinely included transactions in stocks listed on United States securities exchanges
such as The NASDAQ Stock Market LLC, The Nasdaq Global Select Market, and others.
54.Through their actions alleged above – including their guidance and ongoing
operational and back-office support – Goldman and Eikenberry provided knowing and
substantial assistance in Nonko’s unregistered brokerage operations.  Indeed, as alleged above,

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the very idea for Nonko originated with Goldman’s and Eikenberry’s efforts to access U.S.
customers while also evading U.S. broker-dealer registration requirements and related
regulations.
FIRST CLAIM FOR RELIEF
Violations and Aiding and Abetting Violations of
Section 17(a) of the Securities Act
(Both Defendants)
55.Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein.
56.By virtue of the foregoing, each of Goldman and Eikenberry, directly or
indirectly, singly or in concert with others, by use of the means or instruments of transportation
or communication in interstate commerce, or of the mails, in the offer or sale of securities:  (1)
employed devices, schemes, or artifices to defraud; (2) obtained money or property by means of
untrue statements of material fact or omissions to state material facts necessary in order to make
the statements made, in light of the circumstances under which they were made, not misleading;
and (3) engaged in transactions, practices, or courses of business which operated or would
operate as a fraud or deceit upon the purchasers.
57.By virtue of the foregoing, each of Goldman and Eikenberry violated and, unless
restrained and enjoined, will continue violating, Section 17(a) of the Securities Act [15 U.S.C. §
77q(a)].
58.By virtue of the foregoing, each of Goldman and Eikenberry also knowingly or
recklessly provided substantial assistance to persons who, directly or indirectly, singly or in
concert with others, by use of the means or instruments of transportation or communication in
interstate commerce, or of the mails, in the offer or sale of securities:  (1) employed devices,
schemes, or artifices to defraud; (2) obtained money or property by means of untrue statements
of material fact or omissions to state material facts necessary in order to make the statements

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made, in light of the circumstances under which they were made, not misleading; and (3)
engaged in transactions, practices, or courses of business which operated or would operate as a
fraud or deceit upon the purchasers.
59.By virtue of the foregoing, each of Goldman and Eikenberry aided and abetted
and, unless restrained and enjoined, will continue aiding and abetting, violations of Section 17(a)
of the Securities Act [15 U.S.C. § 77q(a)], in violation of Section 15(b) of the Securities Act [15
U.S.C. § 77o(b)].
SECOND CLAIM FOR RELIEF
Violations and Aiding and Abetting Violations of
Section 10(b) of the Exchange Act and Rules 10b-5(a) and 10b-5(c) Thereunder
(Both Defendants)
60.Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein.
61.By virtue of the foregoing, each of Goldman and Eikenberry, directly or
indirectly, singly or in concert with others, in connection with the purchase or sale of a security,
with scienter, used the means or instrumentalities of interstate commerce, or of the mails, or of a
facility of a national securities exchange to:  (1) employ devices, schemes, or artifices to defraud;
and (2) engage in acts, practices, or courses of business which operated or would operate as a
fraud or deceit upon others.
62.By virtue of the foregoing, each of Goldman and Eikenberry violated and, unless
restrained and enjoined, will continue violating, 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)].
63.By virtue of the foregoing, each of Goldman and Eikenberry also knowingly or
recklessly provided substantial assistance to persons who, directly or indirectly, singly or in
concert with others, in connection with the purchase or sale of a security, with scienter, used the
means or instrumentalities of interstate commerce, or of the mails, or of a facility of a national

19
securities exchange to:  (1) employ devices, schemes, or artifices to defraud; and (2) engage in
acts, practices, or courses of business which operated or would operate as a fraud or deceit upon
others.
64.By virtue of the foregoing, each of Goldman and Eikenberry 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 Rules 10b-5(a) and 10b-5(c) thereunder [17 C.F.R.
§§ 240.10b-5(a), (c)], in violation of Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)].
THIRD CLAIM FOR RELIEF
Aiding and Abetting Violations of
Section 10(b) of the Exchange Act and Rule 10b-5(b) Thereunder
(Both Defendants)
65.Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein.
66.By virtue of the foregoing, each of Goldman and Eikenberry knowingly or
recklessly provided substantial assistance to persons who, directly or indirectly, singly or in
concert with others, in connection with the purchase or sale of a security, with scienter, used the
means or instrumentalities of interstate commerce, or of the mails, or of a facility of a national
securities exchange to make untrue statements of a material fact or to omit to state material facts
necessary in order to make the statements made, in the light of the circumstances under which
they were made, not misleading.
67.By virtue of the foregoing, each of Goldman and Eikenberry 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(b) thereunder [17 C.F.R. § 240.10b-
5(b)], in violation of Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)].

20
FOURTH CLAIM FOR RELIEF
Aiding and Abetting Violations of Section 15(a)(1) of the Exchange Act
(Both Defendants)
68.Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein.
69.By virtue of the foregoing, each of Goldman and Eikenberry knowingly or
recklessly provided substantial assistance to persons who, in connection with Nonko’s
operations, made use of the mails or any means or instrumentality of interstate commerce to
effect any transactions in, or to induce or attempt to induce the purchase or sale of, securities
(other than an exempted security or commercial paper, bankers’ acceptances, or commercial
bills) without being registered with the Commission in accordance with Section 15(b) of the
Exchange Act [15 U.S.C. § 78o(b)], and without complying with any exemptions promulgated
pursuant to Section 15(a)(2) of the Exchange Act [15 U.S.C. § 78o(a)(2)].
70.By virtue of the foregoing, each of Goldman and Eikenberry aided and abetted
and, unless restrained and enjoined, will continue aiding and abetting, violations of Section
15(a)(1) of the Exchange Act [15 U.S.C. § 78o(a)(1)], in violation of Section 20(e) of the
Exchange Act [15 U.S.C. § 78t(e)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that this Court enter a Final
Judgment:
I.
 Permanently restraining and enjoining each of Goldman and Eikenberry and their
respective agents, servants, employees and attorneys and all persons in active concert or
participation with them who receive actual notice of the injunction by personal service or
otherwise from violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)] and Sections

Joseph G. Sansone 
Chief, Market Abuse Unit 
Simona K. Suh 
Barry P. O’Connell 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION  
New York Regional Office 
Brookfield Place 
200 Vesey Street, Suite 400 
New York, NY 10281 
(212) 336-0103 (Suh)
Email: [email protected] 

UNITED STATES DISTRICT COURT   
DISTRICT OF NEW JERSEY   

SECURITIES AND EXCHANGE COMMISSION,  

Plaintiff, 

-against-

JEFFREY GOLDMAN and CHRISTOPHER 
EIKENBERRY,  

Defendants.

No. 18 Civ. _______

COMPLAINT 

JURY TRIAL DEMANDED   

Plaintiff Securities and Exchange Commission (“Commission” or “SEC”) files this 

Complaint against Defendant Jeffrey Goldman (“Goldman”) (who, upon information and belief, 

resides at Stratford Drive, West Bloomfield, Michigan 48322) and Defendant Christopher 

Eikenberry (“Eikenberry”) (who, upon information and belief, resides at Larchlea Drive, 

Birmingham, Michigan 48009) (together, “Defendants”), and alleges as follows: 

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SUMMARY

1. This case concerns Defendants Goldman’s and Eikenberry’s participation in an 

illegal scheme to establish and operate an offshore broker-dealer, Nonko Trading (“Nonko”), 

without the necessary registration and later to defraud Nonko’s customers by providing them 

with fake trading accounts and stealing funds that these customers deposited with the firm.  The 

scheme resulted in at least $1.4 million in net losses to over 260 investors in over 30 countries 

worldwide, including over 180 investors in the United States. 

2. Between 2011 and early 2013, Goldman and Eikenberry, who both had extensive 

experience in day-trading operations, helped their associate Naris Chamroonrat (“Chamroonrat”) 

to establish Nonko as a purported offshore proprietary trading firm that would secretly cater to 

U.S.-based day-traders while also evading the U.S. broker-dealer registration requirements.  

Once Nonko was established, starting in late 2013, Goldman and Eikenberry worked with 

Chamroonrat and his Nonko associates to develop and execute a fraudulent scheme to pocket 

Nonko’s customer deposits by secretly providing certain customers with fake accounts instead of 

real ones.

3. As alleged in the SEC’s Amended Complaint against Chamroonrat and his Nonko 

associates Yaniv Avnon (“Avnon”), Ran Armon (“Armon”), and Adam Plumer (“Plumer”), as 

well as Avnon’s entity G Six Trading Y.R Ltd (“G6”) and Chamroonrat’s entity NKO Holdings 

Co. Ltd,1 the Nonko team lured investors to day-trade through Nonko with promises of generous 

leverage, low trading commissions, and low minimum deposit requirements.  But instead of 

providing investors with access to a live securities trading platform, as it had promised, the 

Nonko team secretly provided certain investors with training accounts that merely simulated the 

1  SEC v. Chamroonrat, et al., 16-CV-09403-KM-JBC (D.N.J.) (DE 10).

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placement and execution of trade orders.  So when these investors sent funds to Nonko and 

proceeded to place what they believed were securities trade orders, the orders were never 

actually routed to the markets.  Instead, the Nonko team simply stole the investors’ money, using 

it, among other things, to fund their personal expenses and to make Ponzi-like payments to those 

investors who asked to close their Nonko accounts. 

4. As set forth below, Goldman and Eikenberry were knowing and substantial 

participants in the training accounts fraud, providing the rest of the Nonko team with extensive 

guidance and direction, including on the specific lies that the Nonko team should tell investors in 

order to evade detection.  Goldman and Eikenberry also provided the Nonko scheme with 

operational and back-office support.

5. Goldman and Eikenberry deliberately concealed their involvement with Nonko 

by, among other things, avoiding direct contact with Nonko’s customers and inserting multiple 

intermediary entities, both offshore and domestic, between Nonko and themselves.  

6. For their roles in the scheme, Goldman and Eikenberry collected an agreed-upon 

portion of the fraud’s proceeds, which they funneled to themselves through bank accounts of the 

intermediary entities.   

VIOLATIONS 

7. By virtue of the conduct alleged herein, Goldman and Eikenberry each violated 

and aided and abetted violations of Section 17(a) of the Securities Act of 1933 (“Securities Act”) 

[15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“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 aided and abetted violations of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and 

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Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)] and Section 15(a)(1) of the Exchange Act 

[15 U.S.C. § 78o(a)(1)].

8. Unless Goldman and Eikenberry are permanently restrained and enjoined, they 

will again engage in the acts, practices and courses of business set forth in this Complaint and in 

acts, practices and courses of business of similar type and object. 

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT

9. The Commission brings this action under the authority conferred upon it by 

Sections 20(b) and (d) of the Securities Act [15 U.S.C. § 77t(b), (d)], and Sections 21(d)(1), (3) 

and (5) of the Exchange Act [15 U.S.C. §§ 78u(d)(1), (3), (5)].  The Commission seeks a final 

judgment: (a) permanently restraining and enjoining each Defendant from engaging in the acts, 

practices and courses of business alleged herein; (b) requiring each Defendant to disgorge ill-

gotten gains and to pay prejudgment interest thereon, on a joint and several basis with each 

other; and (c) imposing civil money penalties on each Defendant pursuant to Sections 20(d) of 

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

78u(d)(3)].

JURISDICTION AND VENUE 

10. This Court has jurisdiction over this action pursuant to Sections 22(a) and (c) of 

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

11. Venue lies in this District pursuant to Section 22(a) of the Securities Act and 

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

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

District of New Jersey.  Among other things, many of the fictitious securities transactions 

reported to the victims of the Nonko fraud were generated via a server located in the District of 

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New Jersey.  The trading simulator program used in the Nonko fraud starting in September 2014 

relied on a market data stream provided by a New Jersey-headquartered vendor, retained for the 

scheme by Chamroonrat and his associates.  In addition, multiple residents of the District of New 

Jersey were among the victims of the fraud.  From the District of New Jersey, these victims 

submitted to Nonko securities trade orders that the victims believed were real but in fact were 

never sent to or executed in the market.    

DEFENDANTS 

12. Goldman, age 52, resides West Bloomfield, Michigan.   Goldman held multiple 

securities licenses and was associated with a number of registered broker-dealers between 1990 

and 2017, including during the time period of his involvement with the Nonko fraud, as alleged 

herein.  Over the years, Goldman frequently partnered with Eikenberry in various ventures, 

including those related to securities trading.

13. Eikenberry, age 49, resides in Birmingham, Michigan.  Eikenberry held multiple 

securities licenses and was associated with a number of registered broker-dealers between 1991 

and 2015, including during the time period of his involvement with the Nonko fraud, as alleged 

herein.  Over the years, Eikenberry frequently partnered with Goldman in various ventures, 

including those related to securities trading.

NEVIS TRADING AND RELATED ENTITIES 

14. Nevis Trading purported to be a non-U.S. proprietary trading firm for non-U.S. 

online day-traders.  Goldman and Eikenberry established, controlled, and ran Nevis Trading, 

with Chamroonrat’s assistance, for several years before the launch of Nonko.  Using nominees as 

purported shareholders and officers, Goldman and Eikenberry established a number of offshore 

corporate entities in connection with Nevis Trading’s operations, including Nevis Capital LLC 

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(a Nevis limited liability company, with a registered office in Charlestown, Nevis, and with bank 

accounts in Belize and the Cook Islands); Nevis Capital Trading Co. Ltd. (a limited company 

registered in Thailand, with a registered address in Thailand, and with bank accounts in 

Thailand); and Nevis Trading Group, LLC (a Nevis limited liability company, with a registered 

office in Charlestown, Nevis, and with bank accounts in Belize) (together, the “Nevis Entities”).

After the launch of Nonko as a separate business, as alleged below, Goldman and Eikenberry 

used the Nevis Entities, among other things, as a buffer between themselves and Nonko, so as to 

distance themselves from and conceal their roles in the fraud.  In particular, Goldman and 

Eikenberry used the Nevis Entities’ offshore bank accounts to funnel to themselves their portion 

of the illicit proceeds generated by the Nonko fraud.

FACTS 

A. Goldman’s and Eikenberry’s Roles in the Creation of Nonko  

15. In approximately 2011, while operating Nevis Trading together with 

Chamroonrat, Goldman and Eikenberry suggested to Chamroonrat that the three of them launch 

a separate business that would expand Nevis Trading’s customer base to U.S.-based traders 

while also evading U.S. broker-dealer registration requirements and related regulations.  

16. As these plans became more specific, Goldman and Eikenberry instructed 

Chamroonrat to create two layers of separation between the customers of the new firm and any 

clearing or trading firms that would process the customers’ real (as opposed to simulated) 

securities transactions.  One firm would perform all customer-facing functions, while another 

firm, operating under a different name and nominally controlled by different individuals, would 

interact with any clearing or trading firms.    

17. As Goldman explained to Chamroonrat in a Skype chat in January 2012:

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we need 2 llc's. LLC 1 opens the account with [clearing firm]. We 
might be able to use your nevisllc. LLC 2 (lets call it Jerome 
Trading) opens an LLC in Nevis. Jerome Trading plugs into 
nevicllc.  All our US traders sign paperwork and wire to Jerome 
Trading. This adds a layer between the traders and nevisllc and 
allows us (nevisllc) to say that we only know our trader as Jerome 
Trading who has multiple sub accounts 

18. This multi-layered structure would allow Goldman and Eikenberry to deny 

knowledge that their operation serviced U.S.-based customers.  As Goldman explained to 

Chamroonrat via Skype, this structure also ensured that the “clearing firm doesnt [sic] know they 

[the customers] are US.”

19. Although the name of the customer-facing firm ultimately became “Nonko 

Trading” rather than from “Jerome Trading” (a reference to the first name of a nominee that 

Goldman and Eikenberry often used for the offshore entities they controlled), in substance, 

Nonko’s operation was structured exactly as Goldman laid out in that January 2012 chat.  Nonko 

was the firm that interacted with investors:  It solicited investors to open accounts, entered into 

agreements with them, received their funds, provided them with trading technology (real or 

simulated), and answered their inquiries.  Nevis Trading and the Nevis Entities, on the other 

hand, maintained relationships with trading firms that processed any real, rather than simulated, 

trading of Nonko’s customers.   

20. Goldman and Eikenberry closely collaborated with Chamroonrat in establishing 

Nonko’s operations.  For example, until at least March 2014, Goldman administered Nonko’s 

back-office and accounting system, monitored users’ activities and account balances, and stayed 

in constant contact with Chamroonrat via Skype about all aspects of Nonko’s business.

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21. Eikenberry, among other things, supervised every step of establishing the Belize 

bank accounts for the Nonko business, guiding Chamroonrat step-by-step through the required 

paperwork via Skype.

22. Eikenberry also advised Chamroonrat to move Nonko’s back-office and 

accounting operations from its initial third-party system to the system provided by another, 

smaller third-party provider – a step that Chamroonrat began working on in the second half of 

2013 and fully implemented, under Goldman’s and Eikenberry’s ongoing supervision, by early 

March 2014.

23. In September 2013, Chamroonrat asked Eikenberry, in a Skype chat, whether to 

pay the new back office system provider from Nonko’s bank account or from Chamroonrat’s 

personal bank account in the U.S.  Even though the wire fees at the U.S. bank were three times 

lower, Eikenberry advised Chamroonrat to pay from “nonko[;] keep it clean.”  Chamroonrat 

followed Eikenberry’s direction and paid the provider from Nonko’s Belize bank account.   

B. Goldman’s and Eikenberry’s Roles in the Nonko Training Accounts Fraud  

24. By late 2013, under Goldman’s and Eikenberry’s ongoing but concealed 

guidance, Nonko was operating as a purported proprietary trading firm for investors seeking to 

engage in electronic day-trading in the United States securities markets.    

25. To attract day-traders, Chamroonrat, through Nonko, offered terms that were not 

available at any SEC-registered broker-dealer in the United States, including low trading 

commissions (typically at or below $0.006 per share), a minimum deposit of only $2,500 (and 

occasionally lower), as well as leverage (or margin) of 20:1 (that is, purporting to give traders the 

ability to trade $20 of total capital for each dollar deposited).  Such low account balances and 

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high leverage ratios are prohibited for many day traders in the United States under FINRA’s 

rules.   

26. In late 2013, Goldman, Eikenberry, Chamroonrat, and Chamroonrat’s close 

Nonko associate Avnon conceived of the training accounts scheme as a way to profit from the 

frequent trading losses of Nonko’s day-trading customers.  At that time, Nonko gave its 

customers live accounts set up on an electronic securities trading platform provided by a third-

party vendor (“Platform A”).  As is common in electronic securities trading, Platform A had a 

training account module, typically provided to new users of the software, so that they could 

become familiar with its features in a simulated trading environment.  These training accounts on 

Platform A accessed a trading simulator program that was not programmed to send the users’ 

“orders” to any market centers for execution, but simply generated records of potential, or 

simulated, “executions” of the orders, based on then-current market prices for the securities in 

question.

27. Observing that many of Nonko’s day-trading customers often lost money in the 

market, the Nonko team decided to take advantage of this pattern by secretly providing some of 

Nonko’s customers with training accounts instead of live ones and simply pocketing those 

customers’ deposits.  To minimize the risk of detection, Goldman, Eikenberry, Chamroonrat, and 

Chamroonrat’s associates Avnon, Armon, and later Plumer targeted traders who appeared 

inexperienced or unsophisticated, or had a history of trading losses.  The Nonko team reasoned 

that such traders were likely to place more losing trades and thus unlikely to ask to withdraw 

funds from their accounts.  

28. In Skype chats, emails, and other internal communications, the Nonko team 

(including Goldman and Eikenberry) referred to the scheme as their “TRZ program,” named 

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after the prefix “TRZ” that all of Nonko’s training accounts were assigned on Platform A.  From 

the launch of the training accounts scheme in late 2013, Goldman and Eikenberry both 

understood that Nonko’s “TRZ program” involved holding out training accounts as real ones to 

unwitting traders and pocketing the traders’ deposits.   

29. In early December 2013, during the initial phases of the training accounts scheme, 

Goldman commented to Chamroonrat on Skype:  “trz group down 3k...every trader down.  How 

come part of me feels good and part of me feels bad?!?!??”   

30. Later, on December 17, 2013, Goldman questioned Chamroonrat, “why are you 

letting TRZNK3015 make money??”   

31. Two days later, on December 19, 2013, Goldman pushed Chamroonrat to finalize 

the split of proceeds among the scheme’s participants:  “whats the deal if a guy deposits $5,000 

and loses $5,000.  How is that being split between Nonko and Yaniv [Avnon] and [another

Nonko associate]?”    

32. Goldman continued to work with Chamroonrat to perpetrate the scheme on a 

nearly daily basis until approximately April 2014, managing the back-office and accounting 

program that the group used and keeping track of activity and balances in all user accounts.

33. Similarly, Eikenberry at all times understood the fraudulent nature of Nonko’s 

training accounts scheme and advised Chamroonrat how to manage the fraudulent training 

accounts.  For example, in July 2014, in a Skype chat with Chamroonrat about the planned move 

of the scheme from Platform A to Nonko’s own trading simulator program called Logix, 

Eikenberry expressed a concern that some traders could figure out how to game the new 

platform.  Chamroonrat then reminded Eikenberry of Nonko’s existing approach as follows:   

the current frame work [sic] now with TRZ is that we interview the 
traders first and make sure they are complete newbs before putting 

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them on TRZ, while at the same time, we have a close watch to see 
which account is starting to make money, at any point in time they 
start to show signs of profitablity [sic] we quickly switch them 
over to a NTRD account (live)  
with this new platform, we will use the same process but as we 
expect to have smaller deposits and more new accounts, we will 
have to figuire [sic] a more stricter way to flag “game” accounts, 
we havent [sic] gotten that far yet 

34. In response, Eikenberry commented:  “easy flag is anyone that makes money over 

1k or is up for the week[;]most of these guys just grind themselves.”  Eikenberry and 

Chamroonrat then proceeded to discuss the estimated costs and profit splits in the group after the 

move to Logix.  After Chamroonrat detailed to Eikenberry the cost advantages of Logix over 

Platform A, Eikenberry approvingly commented, “good plan.” 

35. Similar to Goldman, Eikenberry worked closely with Chamroonrat to operate 

Nonko and perpetrate the training accounts scheme.  Among other things, Eikenberry managed 

multiple aspects of the operation’s finances, handling banking issues and funds transfers, and he 

routinely instructed Chamroonrat on how to complete various bank account applications and 

what funds transfers to process at what time. 

36. In the summer of 2014, the firm that owned and licensed Platform A discovered 

Nonko’s training accounts scheme, after a technical inquiry from a Nonko customer revealed that 

the customer wrongly believed that his training account was a live one.  On August 29, 2014, the 

owner of Platform A sent out an email blast to all Nonko customers alerting them that accounts 

starting with “TR” were training accounts; the firm then discontinued its relationship with 

Nonko, accusing Nonko of deceiving its customers.   

37. Chamroonrat immediately reported this development to Eikenberry by Skype and 

asked Eikenberry for guidance on what to tell customers.  Eikenberry responded, “jeff 

[Goldman] was saying that you could say that they were on demo today because [Platform A] 

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found out that they were moving everyone to their own platform [that is, Logix], or that there 

was some kind of miscommunciation [sic] with [Platform A] with shutting all these down.”

38. Following Goldman’s and Eikenberry’s advice, Chamroonrat and his Nonko 

associates adopted the “miscommunication” strategy:  They categorically and falsely denied the 

allegations of Platform A’s owner and falsely told customers that Nonko was ending its 

relationship with Platform A because of poor communication and repeated technical glitches.  

Chamroonrat also instructed his team to immediately move all Nonko customers from Platform 

A to Logix, the trading simulator program that Chamroonrat had commissioned specifically for 

the training accounts scheme.   

39. In the following days, Chamroonrat and his Nonko team moved most of Nonko’s 

TRZ traders to Logix, which they falsely described to traders as Nonko’s “proprietary trading 

system” that was technologically superior to Platform A.  Whenever questioned about the 

allegations made by Platform A’s owner, the Nonko team, following Goldman’s and 

Eikenberry’s advice, continued to claim that those allegations resulted from a misunderstanding.  

Thus, from September 2014 through at least the summer of 2015, Nonko’s fraudulent scheme 

continued to operate largely in the same manner as before, with the Logix simulator serving as 

its purported trading platform.   

C. Goldman’s and Eikenberry’s Roles in  
 Nonko’s Material False Statements to Customers 

40. Throughout the existence of the training accounts scheme, Chamroonrat and his 

Nonko associates Avnon, Armon, and Plumer made repeated and material misrepresentations to 

Nonko’s customers, including in emails to customers, on Nonko’s website, in Nonko’s trading 

agreements with customers, during phone calls, in Skype chats, and in other interactions with 

customers.   

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41. For example, on its website, Nonko claimed to offer “state-of-the-art online stock 

trading infrastructure, designed to meet the exacting requirements of demanding day trading 

professionals” and “the ability to trade a wide range of US stocks and options from a single 

trading platform” – when in reality most of Nonko’s business consisted of providing traders with 

training accounts and pocketing their deposits. 

42. In agreements executed by victims of Nonko’s training accounts scheme, Nonko 

stated that each Nonko customer would “select purchases and sales of securities (‘Stock Trades’) 

for day-trades in [his or her] Trader Sub-Account” and discussed account balances, commission 

rates, trading venue and other trading fees, and other terms of the arrangement as if it was an 

arrangement for real securities trading, and without disclosing that the “trading” would, in fact, 

be fictitious.

43. After the move to Logix, Nonko’s website described Logix as “one of the world’s 

advanced stock trading platforms” that “provides powerful, lightweight access to multiple US 

equity and derivatives markets.”  In reality, Logix was merely a trading simulator program, not 

capable of sending any orders for execution to any market centers.   

44. Chamroonrat and his Nonko associates at all times knew or were reckless in not 

knowing that these statements were materially false and misleading. 

45. Goldman and Eikenberry provided knowing and substantial assistance to 

Chamroonrat’s and his Nonko associates’ material misrepresentations, including by advising 

Chamroonrat how to structure the business, how to handle communications with customers, and 

how to respond when customers or others questioned Nonko’s legitimacy. 

46. For example, in a Skype chat on December 27, 2013, Goldman advised 

Chamroonrat on how to deflect any trader suspicions about the anomalous behavior of Nonko’s 

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TRZ accounts.  If traders noticed that their simulated “orders” did not change the publicly 

disseminated market quotes, Goldman advised, “for why bid/offer doesnt [sic] change can be 

explained that it is in a dark pool or being internalized by a wholesale desk.”  Goldman and 

Chamroonrat then proceeded to discuss how best to present the accounts to customers without 

raising suspicions.  Chamroonrat further noted that he was preparing a checklist for the Nonko 

team on TRZ accounts.    

47. Later that same day, Chamroonrat circulated to Goldman via Skype a document 

entitled “TRZ Guideline” – a guidelines document that Chamroonrat later, in January 2014, also 

provided to Plumer as part of Plumer’s “orientation” on joining the Nonko team.  The document 

instructed the Nonko team members on which traders should be part of the TRZ program 

(novices and those with a history of trading losses), and on what to say if traders questioned any 

“anomalies” in their purported trade “executions.”  The suggested explanations included 

“alternative routing” and, as Goldman had suggested, “internaliz[ation] by a wholesale desk” and 

order routing to dark pools – explanations that were entirely bogus, as all members of the Nonko 

team, including Goldman, understood.  When Chamroonrat sent Goldman the guidelines 

document, Goldman directly expressed his approval of the document.  Chamroonrat stated “ok 

im [sic] sending this out,” and Goldman replied, “excellent.”  Chamroonrat asked Goldman if he 

wanted to add anything to the document, and Goldman responded, “no…. looks good.” 

48. Similarly, as alleged above, both Goldman and Eikenberry advised Chamroonrat 

on how to handle the allegations of fraud made by Platform A’s owner in August 2014.  

Chamroonrat and his team swiftly implemented Goldman’s and Eikenberry’s advice, moving 

Nonko’s customers to Logix, a trading simulator that they falsely described to customers as 

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Nonko’s own and superior trading platform, and falsely claiming that the incident with Platform 

A’s owner resulted from mere miscommunication.  

49. For their contributions to the Nonko scheme, Goldman and Eikenberry negotiated 

a 10-percent cut of the fraud’s proceeds.  Overall, Goldman and Eikenberry together withdrew at 

least $100,000 from the Nonko scheme, funneling these withdrawals first through offshore 

accounts of the Nevis Entities and then through U.S.-based accounts of entities that Goldman and 

Eikenberry controlled.

50. Although Goldman’s day-to-day involvement with the Nonko fraud declined after 

approximately April 2014, Goldman stayed in contact with Eikenberry and the Nonko team.  As 

alleged above, in August 2014, Goldman advised the Nonko team on how to handle Platform A 

owner’s allegations of fraud.  In November 2014, when Eikenberry asked Chamroonrat in a 

Skype chat, “who all is on the nko [that is, Nonko] team,” Chamroonrat responded, “me, yaniv, 

ran, u jeff,” referencing Avnon, Armon, Eikenberry and Goldman.  Approximately a week later, 

in mid-November 2014, the Nonko team – consisting of Chamroonrat, Avnon, Armon, Plumer, 

Goldman, and Eikenberry – met in Las Vegas to discuss Nonko’s operations.

D. Goldman’s and Eikenberry’s Roles in Nonko’s Unregistered Brokerage Operations  

51. As was alleged in the Commission’s Amended Complaint against Chamroonrat 

and his Nonko associates2, by operating Nonko without broker-dealer registration, Chamroonrat, 

Avnon, Armon, Plumer, and Avnon’s entity G6 each violated the U.S. broker-dealer registration 

requirements.  Although Nonko held itself out as a proprietary trading firm, in substance, it 

operated as a broker, processing fictitious, and in some instances real, securities transactions for 

customer accounts.   

2  SEC v. Chamroonrat, et al., 16-CV-09403-KM-JBC (D.N.J.) (DE 10).

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52. Chamroonrat and his Nonko associates aggressively solicited investors to trade 

U.S. securities in the U.S. securities markets, including on registered securities exchanges, 

through Nonko’s website, social media, individual outreach, and other advertising and marketing 

efforts.  These marketing efforts, at least in part, targeted investors based in the United States.

Once a trader signed on to trade through Nonko, the Nonko team, among other things, solicited 

and received the trader’s deposits; provided the trader with access to trading technology (real or 

simulated); extended credit; handled the trader’s cash and securities (real or fictitious); handled 

the trader’s orders (real or simulated); and charged transaction-based compensation, in the form 

of per-share commissions.  

53. Nonko’s business was at all times focused on trading securities (whether fictitious 

or real) in the United States securities markets, and its target customer base consisted largely of 

United States residents.  For example, in its marketing materials, Nonko touted its “real-time 

access to a wide range of US exchanges,” “reliable real-time access to multiple US markets, 

including both equities and derivatives,” and its “access to a wide range of US asset classes.”  In 

its agreements with traders, Nonko routinely included instructions for wiring funds from U.S. 

banks, instructed customers to send only U.S. Dollar-denominated deposits, and listed a schedule 

of fees and rebates to be charged by various U.S. securities exchanges.  No non-U.S. trading 

venues were referenced.  Moreover, both fictitious and real transactions executed for Nonko’s 

customers routinely included transactions in stocks listed on United States securities exchanges 

such as The NASDAQ Stock Market LLC, The Nasdaq Global Select Market, and others.

54. Through their actions alleged above – including their guidance and ongoing 

operational and back-office support – Goldman and Eikenberry provided knowing and 

substantial assistance in Nonko’s unregistered brokerage operations.  Indeed, as alleged above, 

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the very idea for Nonko originated with Goldman’s and Eikenberry’s efforts to access U.S. 

customers while also evading U.S. broker-dealer registration requirements and related 

regulations.

FIRST CLAIM FOR RELIEF 
Violations and Aiding and Abetting Violations of 

Section 17(a) of the Securities Act 
(Both Defendants) 

55. Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein. 

56. By virtue of the foregoing, each of Goldman and Eikenberry, directly or 

indirectly, singly or in concert with others, by use of the means or instruments of transportation 

or communication in interstate commerce, or of the mails, in the offer or sale of securities:  (1) 

employed devices, schemes, or artifices to defraud; (2) obtained money or property by means of 

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

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

and (3) engaged in transactions, practices, or courses of business which operated or would 

operate as a fraud or deceit upon the purchasers.

57. By virtue of the foregoing, each of Goldman and Eikenberry violated and, unless 

restrained and enjoined, will continue violating, Section 17(a) of the Securities Act [15 U.S.C. § 

77q(a)].

58. By virtue of the foregoing, each of Goldman and Eikenberry also knowingly or 

recklessly provided substantial assistance to persons who, directly or indirectly, singly or in 

concert with others, by use of the means or instruments of transportation or communication in 

interstate commerce, or of the mails, in the offer or sale of securities:  (1) employed devices, 

schemes, or artifices to defraud; (2) obtained money or property by means of untrue statements 

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

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made, in light of the circumstances under which they were made, not misleading; and (3) 

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

fraud or deceit upon the purchasers.

59. By virtue of the foregoing, each of Goldman and Eikenberry aided and abetted 

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

of the Securities Act [15 U.S.C. § 77q(a)], in violation of Section 15(b) of the Securities Act [15 

U.S.C. § 77o(b)]. 

SECOND CLAIM FOR RELIEF 
Violations and Aiding and Abetting Violations of 

Section 10(b) of the Exchange Act and Rules 10b-5(a) and 10b-5(c) Thereunder 
(Both Defendants) 

60. Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein. 

61. By virtue of the foregoing, each of Goldman and Eikenberry, directly or 

indirectly, singly or in concert with others, in connection with the purchase or sale of a security, 

with scienter, used the means or instrumentalities of interstate commerce, or of the mails, or of a 

facility of a national securities exchange to:  (1) employ devices, schemes, or artifices to defraud; 

and (2) engage in acts, practices, or courses of business which operated or would operate as a 

fraud or deceit upon others. 

62. By virtue of the foregoing, each of Goldman and Eikenberry violated and, unless 

restrained and enjoined, will continue violating, 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)]. 

63. By virtue of the foregoing, each of Goldman and Eikenberry also knowingly or 

recklessly provided substantial assistance to persons who, directly or indirectly, singly or in 

concert with others, in connection with the purchase or sale of a security, with scienter, used the 

means or instrumentalities of interstate commerce, or of the mails, or of a facility of a national 

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securities exchange to:  (1) employ devices, schemes, or artifices to defraud; and (2) engage in 

acts, practices, or courses of business which operated or would operate as a fraud or deceit upon 

others.

64. By virtue of the foregoing, each of Goldman and Eikenberry 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 Rules 10b-5(a) and 10b-5(c) thereunder [17 C.F.R. 

§§ 240.10b-5(a), (c)], in violation of Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)]. 

THIRD CLAIM FOR RELIEF 
Aiding and Abetting Violations of

Section 10(b) of the Exchange Act and Rule 10b-5(b) Thereunder 
(Both Defendants) 

65. Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein. 

66. By virtue of the foregoing, each of Goldman and Eikenberry knowingly or 

recklessly provided substantial assistance to persons who, directly or indirectly, singly or in 

concert with others, in connection with the purchase or sale of a security, with scienter, used the 

means or instrumentalities of interstate commerce, or of the mails, or of a facility of a national 

securities exchange to make untrue statements of a material fact or to omit to state material facts 

necessary in order to make the statements made, in the light of the circumstances under which 

they were made, not misleading. 

67. By virtue of the foregoing, each of Goldman and Eikenberry 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(b) thereunder [17 C.F.R. § 240.10b-

5(b)], in violation of Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)]. 

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FOURTH CLAIM FOR RELIEF 
Aiding and Abetting Violations of Section 15(a)(1) of the Exchange Act 

(Both Defendants) 

68. Paragraphs 1 through 54 are incorporated by reference as if fully set forth herein. 

69. By virtue of the foregoing, each of Goldman and Eikenberry knowingly or 

recklessly provided substantial assistance to persons who, in connection with Nonko’s 

operations, made use of the mails or any means or instrumentality of interstate commerce to 

effect any transactions in, or to induce or attempt to induce the purchase or sale of, securities 

(other than an exempted security or commercial paper, bankers’ acceptances, or commercial 

bills) without being registered with the Commission in accordance with Section 15(b) of the 

Exchange Act [15 U.S.C. § 78o(b)], and without complying with any exemptions promulgated 

pursuant to Section 15(a)(2) of the Exchange Act [15 U.S.C. § 78o(a)(2)]. 

70. By virtue of the foregoing, each of Goldman and Eikenberry aided and abetted 

and, unless restrained and enjoined, will continue aiding and abetting, violations of Section 

15(a)(1) of the Exchange Act [15 U.S.C. § 78o(a)(1)], in violation of Section 20(e) of the 

Exchange Act [15 U.S.C. § 78t(e)].

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that this Court enter a Final 

Judgment: 

I.

 Permanently restraining and enjoining each of Goldman and Eikenberry and their 

respective agents, servants, employees and attorneys and all persons in active concert or 

participation with them who receive actual notice of the injunction by personal service or 

otherwise from violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)] and Sections 

Case 2:18-cv-13550   Document 1   Filed 09/05/18   Page 20 of 23 PageID: 20Case 2:18-cv-13550 Document 1 Filed 09/05/18 Page 21 of 23 PageID: 21 10(b) and 15(a)(1) of the Exchange Act [15 U.S.C. §§ 78j(b), 78o(a)(1)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. II. Ordering Goldman and Eikenberry to disgorge, with prejudgment interest, all ill-gotten gains from the conduct alleged in this Complaint, on a joint and several basis with each other. III. Ordering Goldman and Eikenberry each to pay civil money penalties pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]. IV. Granting such other and further relief as this Court may deem just and proper. Dated: New York, New York September 5, 2018 /s/ G. 34 SECURITIES AND EXCHANGE COMMISSION New York Regional Office Brookfield Place 200 Vesey Street, Suite 400 New York, New York 10281-1022 (212) 336-0103 [email protected] Of Counsel: Simona K. Suh Barry P. O’Connell 21Case 2:18-cv-13550 Document 1 Filed 09/05/18 Page 22 of 23 PageID: 22 LOCAL CIVIL RULE 11.2 CERTIFICATION Pursuant to Local Civil Rule 11.2, I certify that the matter in controversy alleged against the Defendants in the foregoing Complaint is not the subject of any other civil action pending in any court, or of any pending arbitration or administrative proceeding. A related civil action against other defendants (SEC v. Chamroonrat, et al., 16-CV-09403-KM-JBC) is currently pending before this Court. Related criminal cases are also pending before this Court against multiple defendants. (United States v. Eikenberry; United States v. Chamroonrat, 17-CR-00170-JLL; and United States v. Avnon & Armon, 17-CR-00174-JLL.) SECURITIES AND EXCHANGE COMMISSION By: \Gugne- JoSeHh GY Sansone Brookfield Place 200 Vesey Street, Suite 400 New York, New York 10281-1022 (212) 336-0103 (Suh) suhs(@sec.gov Of Counsel: Simona K. Suh Barry P. O’ConnellCase 2:18-cv-13550 Document 1 Filed 09/05/18 Page 23 of 23 PageID: 23 DESIGNATION PURSUANT TO LOCAL CIVIL RULE 101.1(f) Per the requirements of Local Civil Rule 101.1(f), the undersigned hereby designates the United States Attorney for the District of New Jersey to receive service of all notices or papers in this action at the following address: United States Attorney’s Office, Civil Division District of New Jersey 970 Broad Street, Ste. 700 Newark, New Jersey 07102 SECURITIES AND EXCHANGE COMMISSION By: aac Anane ph ef Brookfield Place 200 Vesey Street, Suite 400 New York, New York 10281-1022 (212) 336-0103 (Suh) suhs@sec. gov Of Counsel: Simona K. Suh Barry P. O’Connell