SEC v. Edward O'Donnell; and Victor Bozzo, No. LR-26334, Southern District of New York (June 24, 2025) — Press Release

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26334 / June 24, 2025 Accounting and Auditing Enforcement No. 4571 / June 24, 2025 Securities and Exchange Commission v. Edward O’Donnell and Victor Bozzo, No. 1:23-cv-08543-AS (S.D.N.Y. filed Sept. 28, 2023) SEC Obtains Final Judgments Against Former Pareteum Executives On May 12, 2025, the Securities and Exchange Commission obtained final judgments against Edward O’Donnell and Victor Bozzo, the former Chief Financial Officer and former Chief Commercial Officer, respectively, of New York–based telecommunications company Pareteum Corp., for their roles in a revenue recognition scheme. The entry of these final judgments concludes the SEC’s litigation in this matter. The SEC’s complaint, filed on September 28, 2023, alleged that from at least 2018 through mid-2019, O’Donnell and Bozzo, along with other Pareteum executives, engaged in a fraudulent scheme to recognize revenue from Pareteum customers’ non-binding purchase orders for SIM card services, despite knowing that the customers had not committed to paying for the services and that the SIM cards had not yet been shipped. This misconduct allowed Pareteum to materially overstate its revenue by $12 million – or 60 percent – for fiscal year 2018 and by $27 million – or 91 percent – for the first and second quarters of 2019 combined in its financial statements filed with the SEC. The SEC’s complaint charged O’Donnell and Bozzo with violating Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The complaint also charged O’Donnell with violating Section 13(b)(5) of the Exchange Act and Rules 13a-14, 13b2-1, and 13b2-2 thereunder, as well as with aiding and abetting Pareteum’s violations of Sections 13(a), 13(b)(2)(A), and 13(b)(2)(B) of the Exchange Act and Rules 12b-20, 13a-1, 13a-11, and 13a-13 thereunder. In a parallel action, the U.S. Attorney’s Office for the Southern District of New York filed criminal charges against Bozzo and O’Donnell. On May 22, 2024, both pleaded guilty. On August 26, 2024, Bozzo was sentenced to a prison term of one year and one day, and was ordered to pay forfeiture of $225,000. On October 9, 2024, O’Donnell was also sentenced to a prison term of one year and one day, and was ordered to pay forfeiture of $60,000. Bozzo and O’Donnell consented to entries of final judgments permanently enjoining them from violating the charged provisions, prohibiting them from serving as officers or directors of publicly traded companies, and ordering them to pay disgorgement of $225,000 and $60,000, respectively, which shall be deemed satisfied by the forfeiture ordered against them in the parallel criminal proceedings. The SEC’s investigation was conducted by Megan Ryan under the supervision of Julia C. Green and Scott A. Thompson of the Philadelphia Regional Office. The litigation was handled by Karen Klotz and Judson Mihok, under the supervision of Gregory R. Bockin. The SEC appreciates the assistance of the U.S. Attorney’s Office for the Southern District of New York and the FBI.

U.S. SECURITIES AND EXCHANGE COMMISSION Litigation Release No. 26334 / June 24, 2025 Accounting and Auditing Enforcement No. 4571 / June 24, 2025 Securities and Exchange Commission v. Edward O’Donnell and Victor Bozzo, No. 1:23-cv-08543-AS (S.D.N.Y. filed Sept. 28, 2023) SEC Obtains Final Judgments Against Former Pareteum Executives On May 12, 2025, the Securities and Exchange Commission obtained final judgments against Edward O’Donnell and Victor Bozzo, the former Chief Financial Officer and former Chief Commercial Officer, respectively, of New York–based telecommunications company Pareteum Corp., for their roles in a revenue recognition scheme. The entry of these final judgments concludes the SEC’s litigation in this matter. The SEC’s complaint, filed on September 28, 2023, alleged that from at least 2018 through mid-2019, O’Donnell and Bozzo, along with other Pareteum executives, engaged in a fraudulent scheme to recognize revenue from Pareteum customers’ non-binding purchase orders for SIM card services, despite knowing that the customers had not committed to paying for the services and that the SIM cards had not yet been shipped. This misconduct allowed Pareteum to materially overstate its revenue by $12 million – or 60 percent – for fiscal year 2018 and by $27 million – or 91 percent – for the first and second quarters of 2019 combined in its financial statements filed with the SEC. The SEC’s complaint charged O’Donnell and Bozzo with violating Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The complaint also charged O’Donnell with violating Section 13(b)(5) of the Exchange Act and Rules 13a-14, 13b2-1, and 13b2-2 thereunder, as well as with aiding and abetting Pareteum’s violations of Sections 13(a), 13(b)(2)(A), and 13(b)(2)(B) of the Exchange Act and Rules 12b-20, 13a-1, 13a-11, and 13a-13 thereunder. In a parallel action, the U.S. Attorney’s Office for the Southern District of New York filed criminal charges against Bozzo and O’Donnell. On May 22, 2024, both pleaded guilty. On August 26, 2024, Bozzo was sentenced to a prison term of one year and one day, and was ordered to pay forfeiture of $225,000. On October 9, 2024, O’Donnell was also sentenced to a prison term of one year and one day, and was ordered to pay forfeiture of $60,000. Bozzo and O’Donnell consented to entries of final judgments permanently enjoining them from violating the charged provisions, prohibiting them from serving as officers or directors of publicly traded companies, and ordering them to pay disgorgement of $225,000 and $60,000, respectively, which shall be deemed satisfied by the forfeiture ordered against them in the parallel criminal proceedings. The SEC’s investigation was conducted by Megan Ryan under the supervision of Julia C. Green and Scott A. Thompson of the Philadelphia Regional Office. The litigation was handled by Karen Klotz and Judson Mihok, under the supervision of Gregory R. Bockin. The SEC appreciates the assistance of the U.S. Attorney’s Office for the Southern District of New York and the FBI.