SEC v. Victor Chilelli, No. 1:21-cv-05429, Southern District of New York (Feb. 28, 2022) — Judgment

1

UNITED STATES DISTRICT COURT
 SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE COMMISSION,

                                                              Plaintiff, Civil Action No. 21-CV-5429 (RA)

OFER ABARBANEL, et al.

Defendants.

JUDGMENT AS TO DEFENDANT VICTOR CHILELLI

The Securities and Exchange Commission having filed a Complaint and Defendant
Victor Chilelli (“Defendant”) having entered a general appearance; consented to the Court’s
jurisdiction over Defendant and the subject matter of this action; consented to entry of this
Judgment without admitting or denying the allegations of the Complaint (except as to
jurisdiction and except as otherwise provided herein in paragraph VI and VIII); waived findings
of fact and conclusions of law; and waived any right to appeal from this Judgment:
I.
 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is
permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the
Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5
promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of
interstate commerce, or of the mails, or of any facility of any national securities exchange, in
connection with the purchase or sale of any security:
(a) to employ any device, scheme, or artifice to defraud;

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(b) to make any untrue statement of a material fact or to omit to state a material fact
necessary in order to make the statements made, in the light of the circumstances
under which they were made, not misleading; or
(c) to engage in any act, practice, or course of business which operates or would
operate as a fraud or deceit upon any person.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who
receive actual notice of this Judgment by personal service or otherwise:  (a) Defendant’s officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or
participation with Defendant or with anyone described in (a).
II.
 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant
is permanently restrained and enjoined from violating Section 17(a) of the Securities Act of 1933
(the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any security by the use of any
means or instruments of transportation or communication in interstate commerce or by use of the
mails, directly or indirectly:
(a) to employ any device, scheme, or artifice to defraud;
(b) to obtain money or property by means of any untrue statement of a material fact
or any omission of a material fact necessary in order to make the statements
made, in light of the circumstances under which they were made, not misleading;
or
(c) to engage in any transaction, practice, or course of business which operates or
would operate as a fraud or deceit upon the purchaser.

3

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who
receive actual notice of this Judgment by personal service or otherwise:  (a) Defendant’s officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or
participation with Defendant or with anyone described in (a).
III.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to Section
21(d)(5) of the Exchange Act [15 U.S.C. § 78u(d)(5)], Defendant is permanently restrained and
enjoined from, directly or indirectly, participating in the issuance, offer, or sale of any security,
including, but not limited to, through any entity owned or controlled by defendants in this action,
provided, however, that such injunction shall not prevent Defendant from taking any actions
necessary to effectuate the disgorgement obligations set forth in paragraph IV; and shall not
prevent Defendant from purchasing or selling securities listed on a national securities exchange
for his own personal account.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in
Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who
receive actual notice of this Judgment by personal service or otherwise:  (a) Defendant’s officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or
participation with Defendant or with anyone described in (a).
IV.
IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant
shall pay disgorgement of $4,757,750, representing net profits gained as a result of the conduct
alleged in the Complaint, together with prejudgment interest thereon in the amount of $181,983,

4

for a total of $$4,939,733, which amounts shall be deemed satisfied as with respect to the
Defendant’s disgorgement obligations (and not the disgorgement obligations of any other party,
which may be additionally liable) by the Defendant’s consent to the release of all funds in the
following accounts identified herein to Investor Group A (c/o Walden Macht & Haran –
Attorney Escrow), as identified in the Complaint, as provided in Section V.  To the extent that
any of the following accounts have open positions in non-cash securities or assets, the Defendant
consents to the liquidation of those positions and to the consolidation of the cash balances in the
relevant master accounts to facilitate the transfer of funds.
Institution Account Name Account Number(s)
Wells Fargo Bank, N.A. North American Liquidity Resources LLC -5664
Wells Fargo Bank, N.A. Institutional Syndication LLC -0277
Wells Fargo Bank, N.A. Growth Income Holdings LLC -3043
TIAA, FSB,
d/b/a TIAA Bank
North American Liquidity Resources LLC -0450
PNC Bank Institutional Syndication LLC -9191
Interactive Brokers LLC North American Liquidity Resources LLC -6883
-7218
-7918
-1670
-4792
-5226
Interactive Brokers LLC Institutional Syndication LLC -3160
-8274
-1903
Interactive Brokers LLC Growth Income Holdings LLC -4946
-8065
-6225
StoneX Financial Inc. North American Liquidity Resources LLC -0430
-0436

Through such payments, Defendant relinquishes all legal and equitable right, title, and
interest in such funds and no part of the funds shall be returned to Defendant or any entity owned
or controlled by Defendant.

5

The Commission may enforce the Court’s judgment for disgorgement and prejudgment
interest by using all collection procedures authorized by law, including, but not limited to,
moving for civil contempt at any time after 30 days following entry of this Judgment.  Defendant
shall pay post judgment interest on any amounts due after 30 days of entry of this Judgment
pursuant to 28 U.S.C. § 1961.
V.

 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, within 3 days after
being served with a copy of this Judgment, the following financial institutions shall transfer the
entire balance of the following accounts, which were frozen pursuant to the June 21, 2021 Order
of this Court [ ECF No. 4], and as amended, to Investor Group A:
Institution Account Name Account Number(s)
Wells Fargo Bank, N.A. North American Liquidity Resources LLC -5664
Wells Fargo Bank, N.A. Institutional Syndication LLC -0277
Wells Fargo Bank, N.A. Growth Income Holdings LLC -3043
TIAA, FSB,
d/b/a TIAA Bank
North American Liquidity Resources LLC -0450
PNC Bank Institutional Syndication LLC -9191
Interactive Brokers LLC North American Liquidity Resources LLC -6883
-7218
-7918
-1670
-4792
-5226
Interactive Brokers LLC Institutional Syndication LLC -3160
-8274
-1903
Interactive Brokers LLC Growth Income Holdings LLC -4946
-8065
-6225
StoneX Financial Inc. North American Liquidity Resources LLC -0430
-0436
To the extent that any of the accounts have open positions in non-cash securities or assets, the
financial institutions shall liquidate those positions and consolidate the cash balances in the

6

relevant master accounts to facilitate the transfer of funds.  The above payments shall be made in
care of counsel for Investor Group A and deposited into counsel’s attorney escrow account by
wire transfer (to Walden Macht & Haran LLP, Attorney Escrow, Citibank Account number -
6012) or check (made payable to Walden Macht & Haran – Attorney Escrow), and mailed to:
Att: Millie Quiroz
Walden Macht & Haran LLP
250 Vesey Street, 27th Floor
New York, New York 10281
The asset freeze entered in the June 21, 2021 Order shall be temporarily lifted for the
limited purpose of allowing the above transfers to take place.  All other terms and conditions in
the June 21, 2021 Order, as amended, shall remain in full effect pending further order of the
Court.
The above financial institutions shall simultaneously transmit photocopies of evidence of
the above payments and case identifying information to the Commission’s counsel in this action.
VI.

Upon motion of the Commission, the Court shall determine whether it is appropriate to
order a civil penalty pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and
Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and, if so, the amount of the civil
penalty.  In connection with the Commission’s motion for civil penalties, and at any hearing held
on such a motion:  (a) Defendant will be precluded from arguing that he did not violate the
federal securities laws as alleged in the Complaint; (b) Defendant may not challenge the validity
of the Consent or this Judgment; (c) solely for the purposes of such motion, the allegations of the
Complaint shall be accepted as and deemed true by the Court; and (d) the Court may determine
the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn
deposition or investigative testimony, and documentary evidence, without regard to the standards

7

for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure.  In
connection with the Commission’s motion for civil penalties, the parties may take discovery,
including discovery from appropriate non-parties.
VII.

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is
incorporated herein with the same force and effect as if fully set forth herein, and that Defendant
shall comply with all of the undertakings and agreements set forth therein.

VIII.

IT
 IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of
exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. §523, the
allegations in the Complaint are true and admitted by Defendant, and further, any debt for
disgorgement, prejudgment interest, civil penalties or other amounts due by Defendant under this
Judgment or any other judgment, order, consent order, decree or settlement agreement entered in
connection with this proceeding, is a debt for the violation by Defendant of the federal securities
laws or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the
Bankruptcy Code, 11 U.S.C. §523(a)(19).
IX.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain
jurisdiction of this matter for the purposes of enforcing the terms of this Judgment.
X.

There being no just reason for delay, pursuant to Rule 54(b) of the Federal Rules of Civil
Procedure, the Clerk is ordered to enter this Judgment forthwith and without further notice.

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Dated:  February 25, 2022
New York, New York
____________________________________
UNITED STATES DISTRICT JUDGE

1 
 

UNITED STATES DISTRICT COURT 
 SOUTHERN DISTRICT OF NEW YORK   
 

SECURITIES AND EXCHANGE COMMISSION, 
 

 

                                                              Plaintiff, Civil Action No. 21-CV-5429 (RA) 
 

OFER ABARBANEL, et al. 
 

Defendants. 

 
  

  
 

 
JUDGMENT AS TO DEFENDANT VICTOR CHILELLI 

 
The Securities and Exchange Commission having filed a Complaint and Defendant 

Victor Chilelli (“Defendant”) having entered a general appearance; consented to the Court’s 

jurisdiction over Defendant and the subject matter of this action; consented to entry of this 

Judgment without admitting or denying the allegations of the Complaint (except as to 

jurisdiction and except as otherwise provided herein in paragraph VI and VIII); waived findings 

of fact and conclusions of law; and waived any right to appeal from this Judgment: 

I. 

 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is 

permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the 

Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 

promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of 

interstate commerce, or of the mails, or of any facility of any national securities exchange, in 

connection with the purchase or sale of any security: 

(a) to employ any device, scheme, or artifice to defraud; 

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http://www.google.com/search?q=17+c.f.r.++240.10b-5
http://www.google.com/search?q=15+u.s.c.++78j(b)


2 
 

(b) to make any untrue statement of a material fact or to omit to state a material fact 

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

under which they were made, not misleading; or 

(c) to engage in any act, practice, or course of business which operates or would 

operate as a fraud or deceit upon any person. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise:  (a) Defendant’s officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

II. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating Section 17(a) of the Securities Act of 1933 

(the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any security by the use of any 

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

mails, directly or indirectly: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to obtain money or property by means of any untrue statement of a material fact 

or any omission of a material fact necessary in order to make the statements 

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

or 

(c) to engage in any transaction, practice, or course of business which operates or 

would operate as a fraud or deceit upon the purchaser. 

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http://www.google.com/search?q=FRCP+65(d)(2)
http://www.google.com/search?q=15+u.s.c.++77q(a)


3 
 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise:  (a) Defendant’s officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

III. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to Section 

21(d)(5) of the Exchange Act [15 U.S.C. § 78u(d)(5)], Defendant is permanently restrained and 

enjoined from, directly or indirectly, participating in the issuance, offer, or sale of any security, 

including, but not limited to, through any entity owned or controlled by defendants in this action, 

provided, however, that such injunction shall not prevent Defendant from taking any actions 

necessary to effectuate the disgorgement obligations set forth in paragraph IV; and shall not 

prevent Defendant from purchasing or selling securities listed on a national securities exchange 

for his own personal account. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Judgment by personal service or otherwise:  (a) Defendant’s officers, 

agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

IV. 

IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

shall pay disgorgement of $4,757,750, representing net profits gained as a result of the conduct 

alleged in the Complaint, together with prejudgment interest thereon in the amount of $181,983, 

Case 1:21-cv-05429-RA   Document 83   Filed 02/24/22   Page 3 of 8Case 1:21-cv-05429-RA   Document 84   Filed 02/25/22   Page 3 of 17

http://www.google.com/search?q=FRCP+65(d)(2)
http://www.google.com/search?q=FRCP+65(d)(2)
http://www.google.com/search?q=15+u.s.c.++78u(d)(5)


4 
 

for a total of $$4,939,733, which amounts shall be deemed satisfied as with respect to the 

Defendant’s disgorgement obligations (and not the disgorgement obligations of any other party, 

which may be additionally liable) by the Defendant’s consent to the release of all funds in the 

following accounts identified herein to Investor Group A (c/o Walden Macht & Haran – 

Attorney Escrow), as identified in the Complaint, as provided in Section V.  To the extent that 

any of the following accounts have open positions in non-cash securities or assets, the Defendant 

consents to the liquidation of those positions and to the consolidation of the cash balances in the 

relevant master accounts to facilitate the transfer of funds. 

Institution Account Name Account Number(s) 
Wells Fargo Bank, N.A. North American Liquidity Resources LLC -5664  
Wells Fargo Bank, N.A. Institutional Syndication LLC -0277 
Wells Fargo Bank, N.A. Growth Income Holdings LLC -3043  
TIAA, FSB,  
d/b/a TIAA Bank 

North American Liquidity Resources LLC -0450  

PNC Bank Institutional Syndication LLC -9191  
Interactive Brokers LLC North American Liquidity Resources LLC -6883 

-7218 
-7918 
-1670 
-4792 
-5226 

Interactive Brokers LLC Institutional Syndication LLC -3160 
-8274 
-1903 

Interactive Brokers LLC Growth Income Holdings LLC -4946 
-8065 
-6225  

StoneX Financial Inc. North American Liquidity Resources LLC -0430 
-0436  

 

Through such payments, Defendant relinquishes all legal and equitable right, title, and 

interest in such funds and no part of the funds shall be returned to Defendant or any entity owned 

or controlled by Defendant. 

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5 
 

The Commission may enforce the Court’s judgment for disgorgement and prejudgment 

interest by using all collection procedures authorized by law, including, but not limited to, 

moving for civil contempt at any time after 30 days following entry of this Judgment.  Defendant 

shall pay post judgment interest on any amounts due after 30 days of entry of this Judgment 

pursuant to 28 U.S.C. § 1961.   

V. 
 

 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, within 3 days after 

being served with a copy of this Judgment, the following financial institutions shall transfer the 

entire balance of the following accounts, which were frozen pursuant to the June 21, 2021 Order 

of this Court [ECF No. 4], and as amended, to Investor Group A: 

Institution Account Name Account Number(s) 
Wells Fargo Bank, N.A. North American Liquidity Resources LLC -5664  
Wells Fargo Bank, N.A. Institutional Syndication LLC -0277 
Wells Fargo Bank, N.A. Growth Income Holdings LLC -3043  
TIAA, FSB,  
d/b/a TIAA Bank 

North American Liquidity Resources LLC -0450  

PNC Bank Institutional Syndication LLC -9191  
Interactive Brokers LLC North American Liquidity Resources LLC -6883 

-7218 
-7918 
-1670 
-4792 
-5226 

Interactive Brokers LLC Institutional Syndication LLC -3160 
-8274 
-1903 

Interactive Brokers LLC Growth Income Holdings LLC -4946 
-8065 
-6225  

StoneX Financial Inc. North American Liquidity Resources LLC -0430 
-0436  

To the extent that any of the accounts have open positions in non-cash securities or assets, the 

financial institutions shall liquidate those positions and consolidate the cash balances in the 

Case 1:21-cv-05429-RA   Document 83   Filed 02/24/22   Page 5 of 8Case 1:21-cv-05429-RA   Document 84   Filed 02/25/22   Page 5 of 17

http://www.google.com/search?q=28+u.s.c.++1961
https://nysd-ecf.sso.dcn/n/cmecfservices/rest/file/finddoc?caseYear=2021&caseNum=05429&caseType=cv&caseOffice=1&docNum=4
https://nysd-ecf.sso.dcn/n/cmecfservices/rest/file/finddoc?caseYear=2021&caseNum=05429&caseType=cv&caseOffice=1&docNum=4


6 
 

relevant master accounts to facilitate the transfer of funds.  The above payments shall be made in 

care of counsel for Investor Group A and deposited into counsel’s attorney escrow account by 

wire transfer (to Walden Macht & Haran LLP, Attorney Escrow, Citibank Account number -

6012) or check (made payable to Walden Macht & Haran – Attorney Escrow), and mailed to: 

Att: Millie Quiroz 
Walden Macht & Haran LLP 
250 Vesey Street, 27th Floor 
New York, New York 10281 

The asset freeze entered in the June 21, 2021 Order shall be temporarily lifted for the 

limited purpose of allowing the above transfers to take place.  All other terms and conditions in 

the June 21, 2021 Order, as amended, shall remain in full effect pending further order of the 

Court. 

The above financial institutions shall simultaneously transmit photocopies of evidence of 

the above payments and case identifying information to the Commission’s counsel in this action. 

VI. 
 

Upon motion of the Commission, the Court shall determine whether it is appropriate to 

order a civil penalty pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and 

Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] and, if so, the amount of the civil 

penalty.  In connection with the Commission’s motion for civil penalties, and at any hearing held 

on such a motion:  (a) Defendant will be precluded from arguing that he did not violate the 

federal securities laws as alleged in the Complaint; (b) Defendant may not challenge the validity 

of the Consent or this Judgment; (c) solely for the purposes of such motion, the allegations of the 

Complaint shall be accepted as and deemed true by the Court; and (d) the Court may determine 

the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn 

deposition or investigative testimony, and documentary evidence, without regard to the standards 

Case 1:21-cv-05429-RA   Document 83   Filed 02/24/22   Page 6 of 8Case 1:21-cv-05429-RA   Document 84   Filed 02/25/22   Page 6 of 17

http://www.google.com/search?q=15+u.s.c.++77t(d)
http://www.google.com/search?q=15+u.s.c.++78u(d)(3)


7 
 

for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure.  In 

connection with the Commission’s motion for civil penalties, the parties may take discovery, 

including discovery from appropriate non-parties. 

VII.  
 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein, and that Defendant 

shall comply with all of the undertakings and agreements set forth therein. 

 
VIII.  

 
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, solely for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. §523, the 

allegations in the Complaint are true and admitted by Defendant, and further, any debt for 

disgorgement, prejudgment interest, civil penalties or other amounts due by Defendant under this 

Judgment or any other judgment, order, consent order, decree or settlement agreement entered in 

connection with this proceeding, is a debt for the violation by Defendant of the federal securities 

laws or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the 

Bankruptcy Code, 11 U.S.C. §523(a)(19). 

IX. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain 

jurisdiction of this matter for the purposes of enforcing the terms of this Judgment. 

X.  
 

There being no just reason for delay, pursuant to Rule 54(b) of the Federal Rules of Civil 

Procedure, the Clerk is ordered to enter this Judgment forthwith and without further notice. 

 

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http://www.google.com/search?q=11+u.s.c.+523
http://www.google.com/search?q=11+u.s.c.+523(a)(19)


8 

Dated:  February 25, 2022
New York, New York 

____________________________________ 
UNITED STATES DISTRICT JUDGE 

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