SEC v. Tomislav Vukota; Vukota Capital Management, LLC; and VCM Global Asset Management Ltd., No. LR-26393, District of Colorado (Sept. 9, 2025) — Press Release
raw: Tomislav Vukota; Vukota Capital Management, LLC; VCM Global Asset Management Ltd.
Tomislav Vukota; Vukota Capital Management, LLC; VCM Global Asset Management Ltd., No. LR-26393 (Sept. 9, 2025)
summary
Tomislav Vukota and his two advisory firms settled SEC charges for breaching fiduciary duties and making material misrepresentations regarding fund loans, buyouts, and marketing materials.
paragraph
Tomislav Vukota and his firms, Vukota Capital Management and VCM Global Asset Management, settled charges for violating the Securities Act of 1933 and the Investment Advisers Act of 1940. The defendants were accused of making undisclosed below-market loans, failing to disclose buyout conflicts, and misstating assets under management. The settlement requires total combined monetary relief of $9,709,794, including $6,943,212 in disgorgement, $1,766,582 in interest, and $1,000,000 in penalties.
narrative
The SEC filed settled charges against Tomislav Vukota and his two firms, Vukota Capital Management, LLC and VCM Global Asset Management Ltd., for multiple forms of misconduct. Between 2017 and 2022, the defendants caused private funds to make undisclosed below-market loans to VCM to cover cash shortfalls. Additionally, they failed to disclose conflicts of interest during investor buyouts in 2021 and provided misleading marketing materials regarding assets under management and auditing status through 2023. The defendants face charges for violating the Securities Act of 1933 and the Investment Advisers Act of 1940. To resolve the matter, the parties agreed to a total settlement of $9,709,794. This amount consists of $6,943,212 in disgorgement, $1,766,582 in prejudgment interest, and $1,000,000 in penalties. The settlement remains subject to court approval.
Classified investment-adviser-fraud(confidence 100%). EDGAR detection: forms ADV/ADV-E/ADV-W/Form D· recall 33% / precision 13%. detection rule →
Statutes
Parties
Securities and Exchange CommissionTomislav VukotaVukota Capital Management, LLCVCM Global Asset Management Ltd.
Keywords
vukotamanagementvcmasset managementprivate fundstomislav vukotavukota vukotavukota capitalcapital managementglobal assetfundssecurities exchangeexchange commissiontomislavasset
Exhibits & Attached Documents (1)
Extracted insights
Dollar amounts 3
- $6.94M $6,943,212 $1M–$10M
- $1.77M $1,766,582 $1M–$10M
- $1.00M $1,000,000 $1M–$10M
Entities 9
- organization Defendants
- person Defendants
- person fiduciary duties
- person material misrepresentations
- agency Securities and Exchange Commission
- organization Securities and Exchange Commission
- person Tomislav Vukota
- company Vukota Capital Management, LLC
- organization Vukota Capital Management, LLC
Triples 13
- Tomislav Vukota breached fiduciary duties
- Tomislav Vukota made material misrepresentations
- Vukota Capital Management, LLC caused private funds to make short-term loans
- Tomislav Vukota sent misleading letters to investors
- Vukota Capital Management, LLC failed to disclose conflicts of interest
- Vukota And Vgam made material misstatements in marketing materials
- Securities And Exchange Commission filed settled charges against Tomislav Vukota
- Tomislav Vukota agreed to settle SEC charges
- Defendants consented to injunctions and monetary relief
- Securities And Exchange Commission charged Defendants with violating Sections 17(a)(2) and 17(a)(3)
- Tomislav Vukota paid $6,943,212 in disgorgement
- Tomislav Vukota paid $1,766,582 in prejudgment interest
- Tomislav Vukota paid $1,000,000 in penalties
PDF (from attached: complaint)
Text layers
Extracted body text (3,088c)
U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26393 / September 9, 2025 Securities and Exchange Commission v. Tomislav Vukota, Vukota Capital Management, LLC, and VCM Global Asset Management Ltd., No. 25-cv-02821 (D. Colo. filed Sept. 9, 2025) Tomislav Vukota and His Two Advisory Firms Settle Charges for Breaches of Fiduciary Duty and Misrepresentations The Securities and Exchange Commission filed settled charges against former Colorado resident Tomislav “Tom” Vukota (Vukota) and the two investment adviser entities he controls, Vukota Capital Management, LLC (VCM) and VCM Global Asset Management Ltd. (VGAM), for breaching their fiduciary duties and making material misrepresentations to private funds and investors who purchased limited partnership interests in those funds. According to the SEC’s complaint, the Defendants engaged in three distinct types of negligent misconduct. First, the complaint alleges that from at least 2017 through May 2022, Vukota and VCM caused various private funds they advised to make short-term loans to VCM at below-market rates to, among other things, cover cash shortfalls at other private funds. The complaint further alleges that the private funds’ partnership agreements prohibited these loans, and neither the practice of providing such loans nor the resulting conflict of interest was disclosed to investors. Second, per the complaint, during February and March 2021, Vukota and VCM sent misleading letters to the investors in four private funds in connection with Vukota’s attempt to buy the investors’ interests. According to the complaint, the buyout letters failed to disclose Vukota’s conflicts of interest, and Vukota and VCM failed to obtain investors’ consent to those conflicts. Third, the complaint alleges that from at least 2017 through 2023, Vukota and VGAM made material misstatements in marketing and offering materials for the Vukota Multi-Strategy Fund concerning the existence of an auditor, the amount of assets under management, the investment strategy, and the filing status as an exempt reporting adviser. The SEC’s complaint, filed in the United States District Court for the District of Colorado, charges all Defendants with violating Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933, Vukota and VCM with violating Section 206(2) of the Investment Advisers Act of 1940, and Vukota and VGAM with violating Section 206(4) of the Advisers Act and Rule 206(4)-8 thereunder. Without admitting or denying the SEC’s allegations, the Defendants agreed to settle the SEC’s charges, consenting to injunctions and total combined monetary relief of $6,943,212 in disgorgement, prejudgment interest of $1,766,582, and penalties of $1,000,000. The settlement is subject to court approval. The SEC’s investigation was conducted by John Mulhern, Jeffrey Felder, Tracy Bowen, and Brian Fitzpatrick, with the assistance of Gregory Kasper, and was supervised by Corey Schuster and Kimberly Frederick of the Division of Enforcement’s Asset Management Unit and Nicholas Heinke of the Denver Regional Office.
OCR text (3,088c · html-text · 99% conf)
U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26393 / September 9, 2025 Securities and Exchange Commission v. Tomislav Vukota, Vukota Capital Management, LLC, and VCM Global Asset Management Ltd., No. 25-cv-02821 (D. Colo. filed Sept. 9, 2025) Tomislav Vukota and His Two Advisory Firms Settle Charges for Breaches of Fiduciary Duty and Misrepresentations The Securities and Exchange Commission filed settled charges against former Colorado resident Tomislav “Tom” Vukota (Vukota) and the two investment adviser entities he controls, Vukota Capital Management, LLC (VCM) and VCM Global Asset Management Ltd. (VGAM), for breaching their fiduciary duties and making material misrepresentations to private funds and investors who purchased limited partnership interests in those funds. According to the SEC’s complaint, the Defendants engaged in three distinct types of negligent misconduct. First, the complaint alleges that from at least 2017 through May 2022, Vukota and VCM caused various private funds they advised to make short-term loans to VCM at below-market rates to, among other things, cover cash shortfalls at other private funds. The complaint further alleges that the private funds’ partnership agreements prohibited these loans, and neither the practice of providing such loans nor the resulting conflict of interest was disclosed to investors. Second, per the complaint, during February and March 2021, Vukota and VCM sent misleading letters to the investors in four private funds in connection with Vukota’s attempt to buy the investors’ interests. According to the complaint, the buyout letters failed to disclose Vukota’s conflicts of interest, and Vukota and VCM failed to obtain investors’ consent to those conflicts. Third, the complaint alleges that from at least 2017 through 2023, Vukota and VGAM made material misstatements in marketing and offering materials for the Vukota Multi-Strategy Fund concerning the existence of an auditor, the amount of assets under management, the investment strategy, and the filing status as an exempt reporting adviser. The SEC’s complaint, filed in the United States District Court for the District of Colorado, charges all Defendants with violating Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933, Vukota and VCM with violating Section 206(2) of the Investment Advisers Act of 1940, and Vukota and VGAM with violating Section 206(4) of the Advisers Act and Rule 206(4)-8 thereunder. Without admitting or denying the SEC’s allegations, the Defendants agreed to settle the SEC’s charges, consenting to injunctions and total combined monetary relief of $6,943,212 in disgorgement, prejudgment interest of $1,766,582, and penalties of $1,000,000. The settlement is subject to court approval. The SEC’s investigation was conducted by John Mulhern, Jeffrey Felder, Tracy Bowen, and Brian Fitzpatrick, with the assistance of Gregory Kasper, and was supervised by Corey Schuster and Kimberly Frederick of the Division of Enforcement’s Asset Management Unit and Nicholas Heinke of the Denver Regional Office.