SEC v. Chibuzo Augustine Onyeachonam; Stanley Chidubem Asiegbu; and Chukwuebuka Martin Nweke-Eze, No. 2:24-cv-11026, District of New Jersey (Dec. 12, 2024) — Complaint

ANTONIA M. APPS
REGIONAL DIRECTOR
Tejal Shah
Adam S. Grace
Travis Hill
Rhonda Jung
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-9135 (Hill)
[email protected]
Deborah A. Tarasevich
Elizabeth Doisy
Martin Zerwitz
SECURITIES AND EXCHANGE COMMISSION
100 F Street N.E. / Mail Stop 5631
Washington, D.C. 20549-5631
Attorneys for Plaintiff

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

SECURITIES AND EXCHANGE
COMMISSION,

                                             Plaintiff,

                        -against-

CHIBUZO AUGUSTINE
ONYEACHONAM, STANLEY
CHIDUBEM ASIEGBU, and
CHUKWUEBUKA MARTIN NWEKE-
EZE,

                                             Defendants.

COMPLAINT

24-CV-11026

JURY TRIAL
DEMANDED

Plaintiff Securities and Exchange Commission (“Commission”), located at

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100 Pearl Street, Suite 20-100, New York, New York 10004-2616, for its
Complaint against Defendants Chibuzo Augustine Onyeachonam
(“Onyeachonam”), whose last known address is    No. 15 Sir Clement Ezeodili
Street, Ifite Awka, Anambra State, Nigeria; Stanley Chidubem Asiegbu
(“Asiegbu”), whose last known address is  No. 15 Mission Road, Awka, Anambra
State, Nigeria; and Chukwuebuka Martin Nweke-Eze (“Nweke-Eze”), whose last
known address is    No. 4 Ashawo Street, Akwai, Adamawa State, Nigeria, (together,
“Defendants”) alleges as follows:
SUMMARY
1. Defendants, none of whom is an actual securities industry
professional, impersonated real-life United States securities broker and investment
adviser representatives online and by telephone and fraudulently obtained at least
$2.9 million from mostly U.S.-based investors, who never knew Defendants’ true
identities.
2. Since at least 2019 through the date of this Complaint’s filing (the
“Relevant Period”), Defendants—Nigerian nationals living in Nigeria—created
websites impersonating at least 22 actual securities broker and investment adviser
representatives (collectively, “Representatives”) at    prominent U.S. securities firms
and touted the representatives’ purported securities industry experience in a

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fraudulent scheme to lure potential U.S. investors into investing funds with
Defendants.
3. In addition to posing as representatives, Defendants made repeated
misrepresentations—including promises of monthly investment returns of 15% to
25%—to  potential investors to persuade them to invest.
4. Defendants, posing as Representatives, instructed investors to open
accounts at broker-dealers and crypto-asset trading platforms and purchase crypto
assets, which Defendants then misappropriated.
5. Defendants also directed investors to fake online investment platforms
Defendants created, where Defendants showed investors fictitious high returns.
These fake returns and Defendants’ purportedly successful trading skills led many
investors to invest additional funds that Defendants also misappropriated.
6. When investors ultimately sought to withdraw their funds, Defendants
informed investors that they were required to pay additional fees before funds
would be released to them—holding investors’ funds ransom.
7. In all, Defendants—and/or others working with them—stole at least
$2.9 million from at least 28 investors, most of whom reside in the U.S.
VIOLATIONS
8. By virtue of the foregoing conduct and as alleged further herein,
Defendants violated Section 17(a) of the Securities Act of 1933 (“Securities Act”)

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[15 U.S.C. § 77q(a)],  Section 10(b) of the Securities Exchange Act of 1934
(“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R.
§ 240.10b-5], and Sections 206(1) and (2) of the Investment Advisers Act of 1940
(“Advisers Act”) [15 U.S.C. §§ 80b-6(1)  and 80b-6(2)].
9. Unless Defendants are restrained and enjoined, they will engage in the
acts, practices, transactions, and courses of business set forth in this Complaint or
in acts, practices, transactions, and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
10. The Commission brings this action pursuant to the authority conferred
upon it by Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and
77t(d)],  Exchange Act Section 21(d) [15 U.S.C. § 78u(d)], and Advisers Act
Sections 209(d) and 209(e) [15 U.S.C. §§ 80b-9(d) and 80b-9(e)].
11. The Commission seeks a final judgment: (a) permanently enjoining
Defendants from violating the federal securities laws and rules this Complaint
alleges they violated; (b) permanently enjoining Defendants from directly or
indirectly, including, but not limited to, through any entity controlled by each
Defendant: (i) participating in the issuance, purchase, offer, or sale of any security
on behalf of someone else; or (ii) engaging in activities for purposes of inducing or
attempting to induce the purchase or sale of any security, including holding
themselves out as industry professionals; provided, however, that such injunction

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shall not prevent each Defendant from purchasing or selling securities for his own
personal account; (c) ordering Defendants to disgorge all ill  -gotten gains they
received as a result of the violations alleged here and to pay prejudgment interest
thereon, pursuant to Exchange Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15
U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; (d)  ordering Defendants to pay
civil money penalties pursuant to Securities Act Section 20(d) [15 U.S.C. § 77t(d)],
Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], and Advisers Act Section
209(e) [15 U.S.C. § 80b-9(e)];  and (e) ordering any other and further relief the
Court may deem just and proper.
JURISDICTION AND VENUE
12. This Court has jurisdiction over this action pursuant to Securities Act
Section 22(a) [15 U.S.C. § 77v(a)], Exchange Act Section 27 [15 U.S.C. § 78aa],
and Advisers Act Section 214 [15 U.S.C. § 80b-14].
13. Defendants, directly and indirectly, have made use of the means or
instrumentalities of interstate commerce or of the mails in connection with the
transactions, acts, practices, and courses of business alleged herein.
14. Venue lies in this District under Securities Act Section 22(a) [15
U.S.C. § 77v(a)], Exchange Act Section 27 [15 U.S.C. § 78aa], and Advisers Act
Section 214 [15 U.S.C. § 80b-14].  Certain of the acts, practices, transactions, and
courses of business alleged in this Complaint occurred within this District.  At least

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one of Defendants’ investor victims resides in New Jersey and communicated with
Defendants from New Jersey.
DEFENDANTS
15. Onyeachonam, age 30, resides in Awka, Nigeria.  He has never been
associated with any entity registered with the Commission.  According to social
media, Onyeachonam purports to be a web developer with Nicrotech.com, a web
design and development business that uses Onyeachonam’s personal cell phone
number and address.
16. Asiegbu, age 27, resides in Awka, Nigeria.  He has never been
associated with any entity registered with the Commission.
17. Nweke-Eze, age 29, resides in Akwai, Nigeria.  He has never been
associated with any entity registered with the Commission.
DEFENDANTS’ FICTITIOUS ENTITIES
18. Alpha Crypto Fund is a fake investment fund at least Onyeachonam
pitched by impersonating a financial professional.  The associated website was
visible to users in the U.S. and included an investor portal that was used to provide
false information to investors regarding the performance of their investment.
Onyeachonam set up, controlled, and operated The Alpha Crypto Fund domains
(alphacryptofund.com and alphacryptofund.io).  An email address attributable to

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Onyeachonam registered the alphacryptofund.com domain in May 2023 and the
alphacryptofund.io domain in July 2023.
19. CopyTradeApp is a fake internet platform visible to users in the U.S.
and abroad that was used to make investors think that impersonated financial
professionals were engaging in “copy trading,” a portfolio management strategy by
which the financial professional would trade the investor’s assets in sync with
other trading activity being conducted by the professional.  Both CopyTradeApp
domains (CopyTradeApp.io and CopyTradeApp.com) were set up by
Onyeachonam.  An email address attributable to Onyeachonam registered the
Copytradeapp.io domain in August 2020 and the Copytradeapp.com domain in
September 2022.
20. InstaForex Service, with a website visible to users in the U.S. and
abroad, purported to hold investors’ funds for the duration of their investment.
When investors attempted to withdraw their funds, InstaForex Service purported to
require various costs and fees before any funds would be released to investors.  A
credit card in Nweke-Eze’s name was used to deposit funds into the domain
registrar account through which instaforexservice.com was registered.  Those
funds were used to renew the hosting plan for instaforexservice.com.
21. LumenTrades is a fake investment account platform visible to users
in the U.S. and abroad, where investors were shown their initial investment and

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often substantial, fictitious trading returns.  Onyeachonam set up, controlled, and
operated LumenTrades.  Email addresses attributable to Onyeachonam were used
to register the LumenTrades.com domain in August 2018 and incorporate
LumenTrades Financial Incorporated in Oregon in March 2019.  Email addresses
attributable to Onyeachonam also show that he paid to incorporate LumenTrades
as a legal entity in the United Kingdom.  An email address attributable to Asiegbu
shows that he assisted with the operation and control of LumenTrades.com by: (1)
emailing code for displaying stock and trading information to
[email protected], an email address controlled by Onyeachonam; (2)
creating a business profile for LumenTrades so that LumenTrades could be found
on Google Search and Maps; and (3) testing the stock purchasing and live chat
functions for LumenTrades.com.
22. Nuvoak is a fictitious investment adviser firm purported to be
associated with an impersonated representative in Defendants’ scheme.  One of
Nuvoak’s web domains (MyNuvoakOnline.com), visible to users in the U.S. and
abroad, contained an investor portal used to provide false information to investors
regarding their investment performance.  Onyeachonam set up, controlled, and
operated MyNuvoakOnline.com.  An email address attributable to Onyeachonam
registered the MyNuvoakOnline.com domain in November 2023.

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23. Secawallet, with a website visible to users in the U.S. and abroad,
displayed blockchain addresses to which investors were instructed to send their
crypto assets.  The website was used to give investors the false impression that
crypto assets were “stored” with Secawallet for investment on their behalf.  In
reality, the investors’ crypto assets were stolen once they were sent to the
addresses displayed by the Secawallet website.  Onyeachonam set up, controlled,
and operated Secawallet.com.  An email address attributable to both Onyeachonam
and Asiegbu registered the Secawallet.com domain in June 2022.  An email
address attributable to Onyeachonam took ownership of the domain in September
2023.
24. Wealthwindow is a fake investment account platform visible to users
in the U.S. and abroad, where investors were shown their initial investment and
fictitious trading returns, which were often substantial.  An email address
attributable to Onyeachonam was used to register the wealthwindow.io domain in
April 2024.
FACTS
I. THE GENERAL STRUCTURE OF DEFENDANTS’ FRAUDULENT
CYBER INVESTMENT SCHEME
25. Defendants’ scheme involved registering internet domain names with
the real first and last names of actual U.S.-based securities brokerage or investment
adviser representatives—for example, “johndoe.com”—whom Defendants planned

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to impersonate.
26. Most of the Representatives were employed at prominent U.S.
investment firms.
27. Defendants similarly formed limited liability companies (“LLCs”)
using the names of the professionals they were impersonating to make it look like
the professionals had their own investment-related firms.
28. Defendants then created   websites that copied the real Representatives’
genuine employment history and credentials from the Financial Industry
Regulatory Authority’s (“FINRA”) BrokerCheck or the Commission’s Investment
Adviser Public Disclosure websites.
1

29. The websites Defendants created touted the Representatives’
investment advisory, trading, and crypto expertise.
30. The websites also sometimes provided the names of the LLCs
Defendants had created using the names of the professionals they were
impersonating.
31. To lure potential investors to the websites, Defendants (and possibly
others working with them)  created profiles on YouTube and placed fictitious

1
 FINRA is a self-regulatory organization, and BrokerCheck is a publicly-
available, online tool listing employment history, certifications, licenses, and any
legal violations for brokerage firm representatives and investment advisers,
available at https://brokercheck.finra.org.

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comments from purported advisory clients and brokerage customers (collectively,
“Fake Clients”) underneath investment-themed YouTube videos.
32. The Fake Clients’ purported comments praised the Representatives’
investment services and trading success.
33. Defendants used fake LinkedIn personas and participated in
investment group chats in encrypted messaging apps to reach out to potential
victims and encourage them to research the Representative whose identity
Defendants had stolen.
34. Defendants, who impersonated mostly female financial professionals
in the U.S., also purchased voice-changing software.
35. When potential investors, thinking Defendants were the impersonated
Representatives, contacted Defendants, Defendants sent emails claiming that the
Representatives would trade on each investor’s behalf across three markets—the
U.S. stock market, the foreign exchange market, and the crypto asset market—and
recommended an investment allocation strategy that Defendants claimed would
generate profits of 15% to 25% monthly.
36. Defendants’ emails to potential investors claimed that the
Representatives used a “copy trading” program that linked each investor’s and
Representative’s trading accounts to ensure that each investor could see all of the
representative’s trades on the investor’s behalf.

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37. The potential investor then completed a client investment form and
contract agreement and returned them by email to Defendants.
38. Next, Defendants typically instructed each investor to download
legitimate trading apps and open accounts at specific, genuine broker-dealers and
crypto-asset trading platforms and then provide their login credentials to
Defendants so that Defendants could sync the investor’s real accounts to the
impersonated Representative’s purported copy trading program—Defendants’
CopyTradeApp.
39. Defendants—still impersonating real financial professionals—then
typically told each investor that, for the first three weeks, they would
predominantly trade the investor’s funds in the crypto market to take advantage of
its bullish state.
40. Defendants typically instructed each investor to fund specific, genuine
brokerage accounts and crypto accounts at approximately a “20:80 ratio”   or “10:90
ratio”—meaning to put one quarter or one ninth the amount of funds in brokerage
accounts as in crypto accounts.
41. Defendants typically further instructed each investor to purchase
bitcoin with the funds in the crypto account and send the bitcoin to a specified
address to “fund” the investment.  In some cases, the receiving address was set up
by investors at Defendants’ instruction.  In other cases, the address was provided

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by Defendants who claimed that the address was held by third-party entities which
stored the investors’ bitcoin for the duration of their investment.  In reality, the
purported third-party entities—e.g., Secawallet and InstaForex Service—were
controlled by Defendants.
42. When investors purchased and transferred the bitcoin, they incurred
third-party fees associated with the purchase and transfer of crypto assets—
payments that increased their ultimate losses from Defendants’ scheme.
43. Once the bitcoin was in the address Defendants had specified, the
bitcoin was moved through multiple addresses, often ultimately landing in
addresses controlled by Defendants or their associates.
44. Defendants then stole each investor’s bitcoin instead of investing it .
45. Investors’ funds in their real brokerage accounts remained mostly
untouched by Defendants.
46. However, some of the brokerage account funds were subsequently
used to further “fund” the investors’ crypto asset investments, which were
accessible to Defendants.
47. Defendants informed investors that they could view their account
balance on an investment platform website—one of Defendants’ fake platforms
such as LumenTrades, Wealthwindow, or MyNuvoakOnline.com—which showed
investors’ purported returns on their investments.

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48. After investors saw their investment accounts grow substantially, as
fictitiously depicted in Defendants’ fake investment platforms, Defendants—still
posing as the real Representatives—often offered new trading strategies that
Defendants claimed required investors to put in additional funds to maximize their
returns.
49. Many investors, believing their initial investments had been
successful, invested additional funds.
50. When investors requested to withdraw their funds, Defendants
typically demanded that the investors pay commissions, performance, or other
purported fees to access their funds.
51. Some investors paid these purported fees.
52. Investors did not know that they were actually investing with
Defendants and not the Representatives whose identities Defendants had stolen.
53. Onyeachonam participated in the scheme by setting up the
impersonated Representatives’  websites; incorporating entities in the names of at
least six impersonated Representatives; promoting impersonated Representatives
online; setting up and operating fake investment account platforms; purchasing
products and services used in the scheme; and impersonating Representatives to
communicate   with victim investors.
54. According to Onyeachonam’s public Goodreads profile, fifteen days

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after Onyeachonam registered the Lumentrades.com domain in 2018,
Onyeachonam read The Confidence Game: Why We Fall for It . . . Every Time
(Penguin Books 2017), a book written by Maria Konnikova and described by The
Washington Post as an “unnerving manual for conning and getting conned.”
55. Asiegbu participated in the scheme by assisting in setting up websites
used in the scheme; promoting the impersonated Representatives and fake
investment account platforms to the investing public; and managing email
addresses used to communicate with victim investors.
56. Nweke-Eze participated in the scheme by using social media to solicit
potential investors; promoting impersonated Representatives and Defendants’
fictitious trading platforms online; and managing an email address used to
communicate with victim investors.
57. During their fraudulent scheme, Defendants impersonated at least 22
Representatives and stole at least $2.9 million from at least 28 investors, at least 23
of whom reside in the U.S.
58. The examples below detail Defendants’ fraudulent scheme with
respect to five of these U.S. investors.

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II. ONYEACHONAM IMPERSONATED A REGISTERED
REPRESENTATIVE FROM WISCONSIN AND DEFENDANTS
STOLE MORE THAN $500,000 FROM A CALIFORNIA INVESTOR.

A. Onyeachonam Impersonated a Wisconsin Representative Online.

59. In November 2019, Onyeachonam set up a website impersonating a
Wisconsin-based registered Representative and investment adviser Representative
(“Representative A”), who was employed by a large, dually registered broker-
dealer and investment adviser firm that is a household name.
60. In 2019, Representative A had 19 years of experience as a broker-
dealer representative and/or investment adviser representative.
61. In 2019, an email address attributable to Onyeachonam registered a
domain name with Representative A’s actual first and last name.
62. Onyeachonam then created a website on that domain that advertised
the Representative’s financial services.
63. The website displayed the real credentials and employment history of
Representative A and linked to Representative A’s actual FINRA BrokerCheck
website page.
64. Onyeachonam’s phony website also listed an email address with
Representative A’s name as a contact method.
65. That email address, which Onyeachonam used to communicate with
investors, had been set up using another email address attributable to

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Onyeachonam.
66. In May 2020, Onyeachonam registered an LLC in the name of
Representative A in the state of Colorado.
B. Defendants Promoted Representative A Online.
67. Onyeachonam, Asiegbu, and Nweke-Eze promoted Representative A
using Google Ads, YouTube, and LinkedIn accounts, all of which directed
potential investors to the Representative A website Onyeachonam had created.
68. On November 28, 2019, Onyeachonam opened a Google Ads account
in the name of Representative A and listed   his own name—“Chibuzo
Onyeachonam”—as the contact person and his Nigerian address at the time as the
postal address.
69. That day, email addresses attributable to Onyeachonam and Asiegbu
began running ads on Google for Representative A stating, “[Representative A] is a
Professional Investment Adviser, Expert Trader, Crypto Analyst, and a Financial
Consultant.”
70. The language in the Google ads was similar to the representations
made on the phony Representative A website Onyeachonam had created.
71. The Google ads also linked to the phony Representative A website.
72. Email addresses attributable to Onyeachonam, Asiegbu, and Nweke-
Eze also used fake identities to promote Representative A’s trading and investment

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services in comments to YouTube videos.
73. The comments took the form of a fictitious online conversation
between strangers, one mentioning their investment success with Representative A
and the other following up with questions about Representative A, concluding with
an instruction from the purported Representative A client to look Representative A
up on the Internet and call, email, or send a message.
74. The fictitious YouTube comments were scripted, and in emails
between and among themselves (and others), Onyeachonam, Asiegbu, and Nweke-
Eze emailed similar scripts used for another Representative Defendants
impersonated.
75. An email address attributable to Onyeachonam also opened a
LinkedIn account for Representative A that touted Representative A as a Financial
Consultant at the firm for which Representative A genuinely worked.
C. A California Investor Found Representative A Online
and Invested More Than $500,000.
76. An investor who at all relevant times has resided in California
(“Investor A”) learned about Representative A when someone in a Signal investor
group chat circulated a link to YouTube comments touting Representative A’s
services.
2

2
 Signal is an encrypted messaging app.

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77. Investor A then found Representative A’s fake website, reviewed
Representative A’s qualifications and licenses, and emailed the person Investor A
thought was Representative A in August 2020 at the email address listed on the
fake website   that Onyeachonam had created.
78. On August 7, 2020, Onyeachonam sent an introductory email—
purportedly from Representative A but actually from Onyeachonam—to Investor
A asking where Investor A was located, what Investor A’s experience was
investing in financial markets, what his financial goals were, and how much
Investor A had “set aside to achieve that financial goal.”
79. In his email in response, Investor A said that he was a beginner in the
financial market, he had only traded in foreign exchange, he had invested in other
vehicles that provided a high annual yield, had about $40,000 to invest, and his
goal was to obtain at least a 20% return on investment.
80. On August 14, 2020, Onyeachonam, again posing as Representative
A, emailed Investor A and explained   that Representative A traded across three
major financial markets—the stock, foreign exchange, and digital currency
markets—to maximize profit generation and that Representative A used a “copy
trading” tool.
81. Onyeachonam’s email further claimed that, after downloading and
installing a list of trading apps, the client would create a trading account which the

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trader would sync with a copy-trading tool to ensure that the client would be able
to transparently view trading activity.
82. This email was identical to one that Onyeachonam sent to other
potential investors who sought to invest through Representative A.
83. In August 2020, Onyeachonam, posing as Representative A, emailed
Investor A a client investment form and a contract agreement.
84. The client investment form required Investor A to provide contact and
background information, as well as information about his investing experience,
financial assets, and investments.
85. The form claimed  : “[Representative A] is a licensed Broker/Financial
Adviser, regulated and accredited by the Financial Industry Regulatory Authority
(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative A] is
therefore operating within the boundaries of [Representative A’s] profession and
the data you will provide below will be used for only investment purposes.”
86. The contract agreement further represented that Investor A was
required to pay a “10% commission fee” and a “one time payment of 5% insurance
premium to protect your investment against any loss ascribable to market crash or
fluctuation.”
87. The contract agreement also promised that “the investment accounts
would accrue a minimum of 15% profits monthly.”

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88. Investor A filled out the client investment form, signed the contract
agreement, and returned both to Onyeachonam through the email address
Onyeachonam had created and that purported to be Representative A’s    email
address.
89. In August 2020, Onyeachonam, posing as Representative A,
instructed Investor A to download and sign up for accounts at an SEC-registered
broker-dealer, a platform for trading currency, and two crypto asset trading
platforms and to set up a call so that Representative A could sync Investor A’s
accounts with Representative A’s copy trading tool and discuss funding and
investments.
90. On August 23, 2020, Onyeachonam, posing as Representative A,
initiated a WhatsApp text conversation with Investor A.
91. Onyeachonam, posing as Representative A, and Investor A thereafter
communicated primarily through WhatsApp messages.
3

92. On August 26, 2020, Onyeachonam, posing as Representative A,
messaged Investor A through WhatsApp and claimed that, to maximize profit
realization, Investor A’s capital would be split between the stock market and
crypto asset market at a   “11:89 ratio”   for the first three weeks of trading due to the
bullish state of the crypto asset market.

3
 WhatsApp is an encrypted messaging service.

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93. On August 26, 2020, Onyeachonam, posing as Representative A,
instructed Investor A to make an initial deposit of $1,200 in Investor A’s newly-
opened (genuine) brokerage account and $8,800 in Investor A’s crypto asset
account, to use the funds in the crypto asset account to purchase bitcoin, and to
transfer the bitcoin to an address Investor A had set up at a crypto-asset trading
platform pursuant to Onyeachonam’s instructions.
94. In September 2020, following the instructions of Onyeachonam
posing as Representative A, Investor A purchased bitcoin in his crypto asset
account and transferred approximately $10,108.92 to an address Investor A had set
up at a crypto-asset trading platform.
95. Investor A then told Onyeachonam, whom Investor A understood to
be Representative A, that Investor A had sent the bitcoin to his address at a crypto-
asset trading platform.
96. Onyeachonam, posing as Representative A, responded that she would
start trading as soon as possible.
97. After transferring the initial investment, Investor A asked whether
Representative A would be trading the funds in Investor A’s (genuine) brokerage
account, and Onyeachonam, posing as Representative A, replied affirmatively.
98. Onyeachonam, posing as Representative A, then emailed Investor A
that his funds had been “uploaded to [Representative A’s] copy trading system”—

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the CopyTradeApp Onyeachonam had created, where Investor A could see his
purported investment returns—and provided a link and login credentials to
LumenTrades.com, the fake investment account platform Onyeachonam had also
created.
99. The LumenTrades.com website displayed Investor A’s investment and
the purported trading returns, which appeared to be substantial.
100. After Onyeachonam secured Investor A’s initial investment and
Investor A saw the significant fictitious profits that Representative A was
purportedly generating, Onyeachonam, posing as Representative A, succeeded in
getting Investor A to transfer an additional $518,923.07, including funds gathered
from friends and a loan from a financial institution, in purported investment funds
over the next four months.
101. Onyeachonam, posing as Representative A, used various techniques to
extract additional funds from Investor A in addition to the fake returns on
LumenTrades: Onyeachonam (1) promoted new trading strategies that required
additional funds to garner high returns; (2) repeatedly reminded   Investor A that the
crypto asset market was doing well; (3) touted Representative A’s expertise,
service, and trading success; and (4) encouraged Investor A to shift assets away
from another investment adviser.
102. By the end of December 2020, the LumenTrades.com website showed

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that Investor A’s $518,299 net investment (after purported transaction fees) had
purportedly earned $1,893,378 in net trading profits—a purported return of more
than 250% in approximately four months.
103. Those earnings were fake, as Defendants had never actually invested
Investor A’s money as promised but had instead misappropriated it.
D. Onyeachonam Gave Investor A the Runaround When He
Attempted   to Withdraw Funds.

104. By late December 2020, Investor A’s bitcoin had been moved from
Investor A’s crypto-asset trading platform address through several other addresses,
and Defendants had thereby stolen the bitcoin.
105. On December 29, 2020, Investor A instructed Representative A (in
reality, Onyeachonam)  to withdraw his entire portfolio on January 1, 2021, and
asked for withdrawal instructions, because he needed to pay back the individuals
who had given Investor A money to invest.
106. The same day, Onyeachonam, posing as Representative A, responded,
“Got it, [Investor A].”
107. Between December 29, 2020, and January 2, 2021, Investor A
repeatedly messaged Representative A (in reality, Onyeachonam) on WhatsApp
regarding Investor A’s funds.
108. On January 2, 2021, Investor A stated, “[Representative A] I haven’t
heard back from you, I don’t know where you are but please respond ASAP.  I

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need to move out the funds.  I’m already late and they expected it Jan 1[.]”
109. On January 3, 2021, Onyeachonam, posing as Representative A,
finally responded, “Hi [Investor A], Happy new year[.] I’m here.”
110. On January 3, 2021, Investor A and Onyeachonam, posing as
Representative A, messaged back and forth for approximately an hour.  Investor A
reiterated that he needed to withdraw his funds, and Onyeachonam, posing as
Representative A, responded, “I will start processing it tomorrow.”
111. When Investor A asked how many days it would take, Onyeachonam,
posing as Representative A, responded, “3 business days.”
112. Investor A and Onyeachonam, posing as Representative A, then
turned their messages to the crypto market and the price of bitcoin.
113. Onyeachonam, posing as Representative A, reminded Investor A of
Representative A’s prediction that the price of bitcoin would “hit at least 25k
before the last days of 2020,” and Investor A responded, “You were right.”
114. On January 6, 2021, Investor A asked Onyeachonam, posing as
Representative A, whether the withdrawal had been processed.
115. On January 7, 2021, Onyeachonam, posing as Representative A,
responded, “[Y]our funds are now available for withdrawal.  Go to the investment
page at Lumentrades and click withdraw.”
116. Later the same day, Investor A asked how long it would take for the

` 26
funds to go from LumenTrades to Investor A’s address once Investor A hit the
withdraw button.
117. Onyeachonam, posing as Representative A, responded, “By the end of
business day.”
118. On January 8, 2021, Investor A messaged Representative A (in
reality, Onyeachonam) stating that Investor A had not received his funds and that
the LumenTrades website was down.
119. That   day, Onyeachonam, posing as Representative A, responded  ,
“You just placed a withdrawal yesterday, it will take 3 business days to complete,”
“I just saw that their site is down for maintenance,”   and “[t]hey will process your
withdrawal.”
120. Investor A reminded Representative A (in reality, Onyeachonam),
“Oh you told me by the end of the business day.”
121. Onyeachonam did not respond to that message.
122. On January 11, 2021, Onyeachonam, posing as Representative A,
messaged Investor A that “Lumentrades is working on some features[;] that’s why
there is a little delay in withdrawal.”
123. Investor A responded, “Ok thank you so much,” and asked how long
Representative A thought it would take.
124. Onyeachonam did not respond.

` 27
125. The same day, Investor A informed Representative A (in reality,
Onyeachonam) that several people were upset with him, he was worried and
anxious, his life would be destroyed, and his family and friends were close to
killing him because he had not returned their money.
126. Onyeachonam, posing as Representative A, responded that Investor A
would receive his funds soon and everything was going well.
127. Later the same day, Onyeachonam, posing as Representative A, told
Investor A that his funds would be available two days later—by Wednesday,
January 13, 2021.
128. On January 13, 2021, Investor A did not receive his funds.
129. Investor A messaged Representative A (in reality, Onyeachonam)
regarding withdrawal.
130. On January 14, 2021, Onyeachonam, posing as Representative A, told
Investor A that LumenTrades is on it, “[t]hey are updating their services,”   and that
Investor A’s funds would be available the next day.
131. On or around January 18, 2021, someone purporting to be from
LumenTrades contacted Investor A and told him to pay additional money to
receive a bonus.
132. On January 18, 2021, Investor A informed Representative A (in
reality, Onyeachonam) about the LumenTrades call and said that he did not have

` 28
any more money and was “drained” and “basically bankrupt.”
133. Onyeachonam, posing as Representative A, responded, “[P]lease
follow the instruction on Lumentrades[.] . . . I did my best for you and you don’t
want to follow simple instruction[ ] to withdraw your funds[?]”
134. Investor A replied, “Lumentrades has no location, no real phone
number, it’s not a real exchange anywhere.  They got my name spelled wrong in
most of their emails . . . it’s not legitimate.”
135. On January 18, 2021, in Investor A’s final WhatsApp message to
Onyeachonam, Investor A stated, “Be honest with me.  I figured it out by now that
you are not who you pose to be on the website.”
136. Investor A then posed one final question: “How do you sleep at night
knowing you’re destroying the lives of people who trust you[?]”
137. Investor A received no response to his message.
138. Nor did Investor A ever receive any funds or other assets back from
Defendants.
139. Between August and December 2022, Defendants stole $529,031.99
from Investor A.

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III. ONYEACHONAM AND ASIEGBU IMPERSONATED A FORMER
REGISTERED REPRESENTATIVE FROM TEXAS, AND
DEFENDANTS STOLE MORE THAN $55,000 FROM AN ARIZONA
INVESTOR.

A. Onyeachonam and Asiegbu Impersonated a Former Texas
Representative Online.

140. In April 2020, an unknown individual or individuals set up a website
impersonating a former Texas-based broker-dealer and investment adviser
Representative (“Representative B”) previously employed by a large, dually
registered broker-dealer and investment adviser firm that was a household name.
141. By 2020, Representative B had had 36 years of experience as a
broker-dealer representative and/or investment adviser representative during his
career.
142. In April 2020, an unknown individual or individuals registered a
domain name with Representative B’s actual first and last names.
143. An unknown individual or individuals also created a website on that
domain that advertised Representative B’s financial services.
144. The website displayed the real credentials and employment history of
Representative B and linked to Representative B’s actual FINRA BrokerCheck
website page.
145. The phony website also listed an email address with Representative
B’s name as a contact method.

` 30
146. As early as May 2020, email account information indicates that
Asiegbu and Onyeachonam controlled that email address, which was used to
communicate with their investor victims.
147. Additionally, Asiegbu maintained a Google Search Console account, a
tool that helps website owners and developers understand how their site appears in
Google Search results, for the phony website.
148. In February 2021, Onyeachonam and/or Asiegbu purchased via an
email address attributable to both of them a SSL certificate, a digital file that
verifies a website’s identity and encrypts communication between a web browser
and a web server, for the phony website.
149. In June 2021, Onyeachonam registered an LLC in the name of
Representative B in the state of Delaware.
B. Nweke-Eze Promoted Representative B Online.
150. Starting in at least July 2020, an email address attributable to Nweke-
Eze used fake identities to promote Representative B’s trading and investment
services in comments to YouTube videos.
151. The comments took the form of a fictitious online conversation
between strangers, one mentioning their investment success with Representative B
and the other following up with questions about Representative B, concluding with
an instruction from the purported Representative B client to look Representative B

` 31
up on the Internet and call, email, or send a message.
152. The fictitious YouTube comments were scripted, and in emails sent to
himself and others potentially involved in the fraud, Nweke-Eze emailed similar
scripts used for another representative Defendants impersonated.
C. An Arizona Investor Found Representative B Online
and Invested More Than $55,000.
153. An investor who at all relevant times has resided in Arizona
(“Investor B”) learned about Representative B through comments made on
YouTube touting Representative B’s services.
154. Investor B then found Representative B’s fake website, controlled by
Asiegbu, and emailed Representative B in August 2020 using the email address
listed on the fake website.
155. Investor B noted in his email that he had “heard good reviews about
the services you provided to others.”
156. On August 11, 2020, Onyeachonam and/or Asiegbu, posing as
Representative B, sent an introductory email—purportedly from Representative B
but actually from an email address attributable to Onyeachonam and Asiegbu—to
Investor B asking where Investor B was located, what Investor B’s experience was
investing in financial markets, what his financial goals were, and how much
Investor B had “set aside to achieve that financial goal.”
157. In response, Investor B said that he was a beginner in the financial

` 32
market, he had made some trades and investments that had turned out poorly, he
had about $130,000 in savings but did not want to invest all of it, and his goal was
to earn enough to buy a property or invest in a business.
158. On August 13, 2020, Onyeachonam and/or Asiegbu, again posing as
Representative B, emailed Investor B and claimed that Representative B traded
across three major financial markets—the stock, foreign exchange, and digital
currency markets—to maximize profit generation and that Representative B used a
“copy-trading” tool.
159. The email from Onyeachonam and/or Asiegbu further claimed that,
after downloading and installing a list of trading apps, the client would create a
trading account which the trader would sync with a copy-trading tool to ensure that
the client would be able to transparently view trading activity.

160. In August 2020, Onyeachonam and/or Asiegbu, posing as
Representative B, emailed Investor B a client investment form and a contract
agreement.
161. Both the client investment form and the contract agreement included
seals for the SEC and FINRA BrokerCheck.
162. The client investment form required Investor B to provide contact and
background information, as well as information about his investing experience,
financial assets, and investments.

` 33
163. The form claimed: “[Representative B] is a licensed Broker/Financial
Adviser, regulated and accredited by the Financial Industry Regulatory Authority
(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative B] is
therefore operating within the boundaries of [Representative B’s] profession and
the data you will provide below will be used for only investment purposes.”

164. The contract agreement further represented that Investor B was
required to pay a “10% commission fee” and a “one time payment of insurance
premium to protect your investment against any loss ascribable to market crash or
fluctuation.”
165. The contract agreement also promised that “the investment accounts
would accrue a minimum of 15% profits monthly.”

166. Investor B filled out the client investment form, signed the contract
agreement, and returned both to Onyeachonam and/or Asiegbu through the email
address they controlled that purported to be Representative B’s address.
167. In August 2020, Onyeachonam and/or Asiegbu, again posing as
Representative B, instructed Investor B via email to download and sign up for
accounts at two SEC-registered broker-dealers, a platform for trading currency,
and two crypto asset trading platforms, and to set up a call so that Representative B
could sync Investor B’s accounts with Representative B’s copy trading tool and
discuss funding and investments.

` 34
168. In September 2020, Onyeachonam and/or Asiegbu, posing as
Representative B, emailed Investor B a strategy document regarding a “bitcoin
pump opportunity.”
169. An email address Onyeachonam and Asiegbu controlled contained a
Google Drive file with a similar document, dated March 24, 2021, with identical
letterhead and Representative B’s fake contact information.
170. On September 1, 2020, Onyeachonam and/or Asiegbu, posing as
Representative B, emailed Investor B and claimed that, to maximize profit
realization, Investor B’s capital would be split between the stock market and crypto
asset market at a “19:81 ratio” for the first three weeks of trading due to the bullish
state of the crypto asset market.
171. Representative B instructed Investor B to make an initial deposit of
$5,700 in Investor B’s newly-opened (genuine) brokerage account and $24,300 in
Investor B’s crypto asset account.
172. On September 14, 2020, Onyeachonam, posing as Representative B,
initiated a WhatsApp text conversation with Investor B.
173. Onyeachonam, posing as Representative B, and Investor B thereafter
communicated primarily through WhatsApp messages.
174. In September 2020, following the instructions from Onyeachonam,
posing as Representative B, Investor B purchased bitcoin in his crypto asset

` 35
account and transferred approximately $20,382.97 in bitcoin to an address Investor
B had set up at a crypto-asset trading platform.
175. Investor B was unable to set up the (genuine) brokerage account
Onyeachonam, posing as Representative B, had instructed him to set up because
Investor B needed additional documentation.
176. Onyeachonam and/or Asiegbu, posing as Representative B, then
emailed Investor B that his funds had been “uploaded to [Representative B’s] copy
trading system”—the CopyTradeApp Onyeachonam had created, where Investor B
could see his purported investment returns—and provided a link and login
credentials to LumenTrades.com, the fake investment account platform
Onyeachonam had also created.
177. The LumenTrades.com website displayed Investor B’s investment and
the purported trading returns from Representative B.
178. After Onyeachonam and/or Asiegbu secured Investor B’s initial
investment and Investor B saw the significant fictitious profits that Representative
B was purportedly generating, Onyeachonam and/or Asiegbu, posing as
Representative B, succeeded in getting Investor B to transfer an additional
$37,811.92.
179. Onyeachonam and/or Asiegbu, posing as Representative B, used
various techniques to extract additional funds from Investor B in addition to the

` 36
fake returns on LumenTrades:  Onyeachonam and/or Asiegbu (1) promoted new
trading strategies, which they informed Investor B required additional funds to
garner high returns; (2) repeatedly reminded Investor B that the crypto asset
market was doing well; (3) touted Representative B’s expertise, service, and
trading success; and (4) reminded Investor B of his financial goals (buying real
property).
180. Defendants never invested Investor B’s money as promised but
instead misappropriated it.
D. Onyeachonam Gave Investor B the Runaround When He
Attempted to Withdraw Funds.

181. By October 27, 2020, Investor B’s bitcoin had been moved from
Investor B’s crypto-asset trading platform address through several addresses, and
Defendants thereby stole it.
182. Starting on November 29, 2020, Investor B informed Representative
B (in reality, Onyeachonam) via WhatsApp that he wanted to withdraw $30,000
and asked how to make a withdrawal.
183. Onyeachonam, posing as Representative B, messaged Investor B and
asked when he planned to make the withdrawal.
184. Investor B responded, “In the next week or two, if possible.  I got
pretty sick and racked up some medical bills.”
185. Representative B (in reality, Onyeachonam) replied, “Okay.  Let me

` 37
know when you’re ready.”

186. On December 5, 2020, Investor B messaged the person he thought
was Representative B:  “I tried making a withdrawal from the lumentrades
[website] and it wasn’t working for me.  What’s the best route to go to get some
[of] that profit out.”
187. Onyeachonam, posing as Representative B, responded, “I will contact
them and have it processed soon.”
188. Between December 6, 2020, and December 21, 2020, Investor B
repeatedly messaged Representative B (in reality, Onyeachonam) on WhatsApp
regarding withdrawing Investor B’s funds.
189. At various times in December 2020, Onyeachonam, posing as
Representative B, told Investor B, “I’m trying to close some position[s] so I can
process your withdrawal;” “You can withdraw it from Lumentrades but I still hold
some positions that I need to liquidate.  By Monday your funds will be available
for withdrawal;” “You will be able [] to withdraw today.  The funds are available;”
and “go ahead and withdraw from your account at Lumentrades.”
190. Investor B was never able to withdraw any of his funds from
LumenTrades.
191. On January 2, 2021, Investor B messaged Representative B, “Whats
the deal with withdrawals.  Submitted it the 21
st
 and its still pending.”

` 38
192. Onyeachonam, posing as Representative B, replied, “I will contact
them and get back to you.”
193. On January 4, 2021, the purported “Lumentrades Billing Team”
emailed Investor B from an email address created and controlled by Onyeachonam,
“We sincerely apologise [sic] for the delay in withdrawal.  We are updating our
terms and functionalities.  Your funds will be available tomorrow.”
194. On January 15, 2021, the same email address emailed Investor B
writing, “We have fully updated our terms and functionalities.  You can now
withdraw your investment and have it available in your account today.”
195. Investor B never received any funds or other assets back from
Defendants.
196. Between September and October 2020, Defendants stole $58,194,89
from Investor B.
IV.     DEFENDANTS IMPERSONATED A REGISTERED
REPRESENTATIVE FROM MINNESOTA AND STOLE MORE
THAN $105,000 FROM A CALIFORNIA INVESTOR.

A. Asiegbu and Nweke-Eze Impersonated a Minnesota
Representative Online.
197. In October 2020, an unknown individual or individuals set up a
website impersonating a Minnesota-based broker-dealer and investment adviser
Representative (“Representative C”) employed by a large, dually registered broker-
dealer and investment adviser firm that was a household name.

` 39
198. In 2020, Representative C had 13 years of experience as a broker-
dealer representative and/or investment adviser representative.
199. In October 2020, an unknown individual or individuals registered a
domain name with Representative C’s actual first and last names.
200. An unknown individual or individuals created a website on that
domain that advertised Representative C’s financial services.
201. The website displayed the real credentials and employment history of
Representative C and linked to Representative C’s actual FINRA BrokerCheck
website page.
202. The phony website also listed an email address with Representative
C’s name as a contact method.
203. That email address, used to communicate with Defendants’ investor
victims, was controlled by Asiegbu starting in at least November 2020 and by
Nweke-Eze starting in at least June 2021.
204. Starting at least the day after the phony website’s domain name was
registered, Asiegbu controlled the website.  For example, he set up and maintained
through at least September 2021 a   webhosting account for the domain—a service
that stores and maintains a website's files and applications on a server so that it can
be accessed on the internet.  Webhosts are responsible for the technical aspects of a
website's operation, including keeping the server running, implementing security

` 40
measures, and ensuring that files are transferred to visitors’ browsers.
205. In June 2021, Onyeachonam registered an LLC in the name of
Representative C in the state of Delaware.
B. Nweke-Eze Promoted Representative C Online.
206. Nweke-Eze promoted Representative C using YouTube, which
directed potential investors to research Representative C.
207. Starting in at least November 2020, an email address attributable to
Nweke-Eze used fake identities to promote Representative C’s trading and
investment services in comments to YouTube videos.
208. The comments took the form of a fictitious online conversation
between strangers, one mentioning their investment success with Representative C
and the other following up with questions about Representative C, concluding with
an instruction from the purported Representative C client to look Representative C
up on the Internet and call, email, or send a message.
209. The fictitious YouTube comments were scripted, and in emails sent to
himself and others, Nweke-Eze emailed similar scripts used for another
representative Defendants impersonated.
C. A California Investor Found Representative C Online
and Invested More Than $105,000.
210. An investor who at all relevant times has resided in California
(“Investor C”) learned about Representative C through comments made on

` 41
YouTube touting Representative C’s services.
211. Investor C then found Representative C’s fake website, which
Asiegbu controlled, and sent Representative C a message in June 2021 using the
form on the website.
212. On June 23, 2021, Asiegbu and/or Nweke-Eze sent an introductory
email—purportedly from Representative C but actually from an email address
attributable to Asiegbu and Nweke-Eze—to Investor C asking where Investor C
was located, what Investor C’s experience was investing in financial markets, what
her financial goals were, and how much Investor C had “set aside to achieve that
financial goal.”  Asiegbu and/or Nweke-Eze used the email address they controlled
that purported to be Representative C’s address.
213. In response, Investor C said that she was a beginner in the financial
market, she was interested in a balanced portfolio that provided monthly cashflow
as well as long term growth, and she had $30,000 to invest and would like to
increase the amount over time.
214. On June 28, 2021, Asiegbu and/or Nweke-Eze, again posing as
Representative C, emailed Investor C and claimed that Representative C traded
across three major financial markets—the stock, foreign exchange, and digital
currency markets—to maximize profit generation and that Representative C used a
“copy trading” tool.

` 42
215. The email further claimed that, after downloading and installing a list
of trading apps, the client would create a trading account which the trader would
sync with a copy-trading tool to ensure that the client would be able to
transparently view trading activity.
216. Attached to the email was a document titled, “Portfolio Management
Business Model.”
217. The Portfolio Management Business Model included the seals for the
SEC and FINRA BrokerCheck.
218. The Portfolio Management Business Model claimed, “[Representative
C] is a licensed and regulated broker/portfolio manager with over 20 years of
experience working with notable financial/investment firms in the United States.”
219. The document also claimed that Representative C “guaranteed [a]
monthly capital gain of 15-25%” and charged a 5-10% “performance fee or trade
commission” and a 5% “insurance premium” to “insure investor’s funds against
losses.”
220. In July 2021, Asiegbu and/or Nweke-Eze, posing as Representative C,
emailed Investor C a client investment form and a contract agreement.

221. Both the client investment form and contract agreement included the
seals for the SEC and FINRA BrokerCheck.
222. The client investment form was identical to one that an email address

` 43
associated with Onyeachonam and Asiegbu had emailed to
[email protected] three months earlier, on March 24, 2021.
223. The client investment form required Investor C to provide contact and
background information, as well as information about her investing experience,
financial assets, and investments.
224. The form claimed: “[Representative C] is a licensed Broker/Financial
Adviser, regulated and accredited by the Financial Industry Regulatory Authority
(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative C] is
therefore operating within the boundaries of [Representative C’s] profession and
the data you will provide below will be used for only investment purposes.”
225. The contract agreement further represented that Investor C was
required to pay a “5% commission fee” and a “one-time payment of insurance
premium to protect your investment against any loss ascribable to market crash or
fluctuation.”
226. The contract agreement also promised that “the investment accounts
would accrue a minimum of 15% profits monthly.”
227. Investor C filled out the client investment form, signed the contract
agreement, and returned both to Asiegbu and/or Nweke-Eze through the email
address that they controlled and that purported to be Representative C’s email
address.

` 44
228. In July 2021, Asiegbu and/or Nweke-Eze, posing as Representative C,
instructed Investor C to download and sign up for accounts at two SEC-registered
broker-dealers, a platform for trading currency, and two crypto asset trading
platforms and to set up a call so that Representative C could sync Investor C’s
accounts with Representative C’s copy trading tool and discuss funding and
investments.
229. On July 8, 2021, Onyeachonam, posing as Representative C, initiated
a WhatsApp text conversation with Investor C.
230. Representative C and Investor C thereafter communicated primarily
through WhatsApp messages.
231. On July 19, 2021, Asiegbu and/or Nweke-Eze, posing as
Representative C, emailed Investor C and claimed that, to maximize profit
realization, Investor C’s capital would be split between the stock market and crypto
asset market at a “10:90 ratio” for the first three weeks of trading due to the bullish
state of the crypto asset market.
232. Representative C (in reality, Asiegbu and/or Nweke-Eze) instructed
Investor C to make an initial deposit of $2,000 in Investor C’s newly-opened
(genuine) brokerage account and $18,000 in Investor C’s crypto asset account.
233. In July 2021, following these instructions, Investor C purchased
bitcoin in her crypto asset account and transferred $19,005.17 in bitcoin to an

` 45
address Investor C had set up at a crypto-asset trading platform.
234. Investor C also deposited $2,000 into her (genuine) brokerage
account.
235. On July 24, 2021, Onyeachonam, posing as Representative C,
messaged Investor C claiming that Representative C would “start trading in your
account today.”
236. Asiegbu and/or Nweke-Eze, posing as Representative C, then emailed
Investor C that her funds had been “uploaded to [Representative C’s] copy trading
system”—the CopyTradeApp Onyeachonam had created, where Investor C could
see his purported investment returns—and provided a link and login credentials to
LumenTrades.com, the fake investment account platform Onyeachonam had also
created.
237. The LumenTrades.com website displayed Investor C’s investment and
the purported trading returns from Representative C, which appeared to be
substantial.
238. Onyeachonam, posing as Representative C, and Investor C arranged a
call via WhatsApp for August 19, 2021, at 9 a.m. Pacific Time to discuss a “new
strategy” for investment.
239. Indeed, Onyeachonam’s scheduling app listed a call on August 19,
2021, at 9 a.m. Pacific Time and described “Chibuzo [Onyeachonam]’s task” as to

` 46
“Call [Investor C’s first name] • [Representative C’s first name] Project.”
240. After Defendants secured Investor C’s initial investment and Investor
C saw the significant fictitious profits that Representative C was purportedly
generating, Defendants, posing as Representative C, succeeded in getting Investor
C to transfer an additional $82,011.90 in purported investment funds over the next
five months.
241. Defendants, posing as Representative C, used various techniques to
extract additional funds from Investor C in addition to the fake returns on
LumenTrades: Defendants (1) promoted new trading strategies that required
additional funds to garner high returns; and (2) promised Investor C that, if she
invested additional funds, she would be able to take monthly withdrawals without
affecting the trading strategy.
242. Defendants never invested Investor C’s money as promised but
instead misappropriated it.
243. On December 2, 2021, Investor C asked Representative C for an
“alternate contact” in case Investor C was unable to get a hold of Representative C.
244. Onyeachonam, posing as Representative C, responded that the firm
would have its assistant “Susan” reach out.
245. On December 3, 2021, someone posing as “Susan Olsen,” a fictitious
individual with a LumenTrades.com email address, reached out to Investor C,

` 47
stating “You can reach out to me whenever you have any questions or difficulty
with your account.”
246. The same day, an email address attributable to Onyeachonam received
identical draft correspondence from “Susan Olsen.”
247. Investor C and Onyeachonam, posing as Representative C, discussed
investing in the stock market.
248. On December 15, 2021, Onyeachonam, posing as Representative C,
messaged Investor C, “I will start trading the funds [in Investor C’s genuine
brokerage account] as soon as possible.”
249. Investor C responded, “awesome thanks for confirming.”
250. Defendants never traded the funds in Investor C’s genuine brokerage
account.
D. Onyeachonam Gave Investor C the Runaround and Charged
Additional Fees When She Attempted to Withdraw Funds.

251. By March 1, 2022, Investor C’s bitcoin had been moved from Investor
C’s crypto-asset trading platform address through several addresses, and
Defendants had stolen the bitcoin.
252. On March 1, 2022, Investor C messaged Representative C, “How do I
withdraw my monthly gain?”
253. Representative C did not respond.
254. Investor C messaged Representative C several times throughout

` 48
March 2022, noted   that her emails to Representative C were “getting bounced,”
and yet did not receive a response.
255. On June 29, 2022, Onyeachonam, posing as Representative C,
messaged Investor C, claiming that Representative C had been sick the last few
months and therefore had not responded to any of Investor C’s messages.
256. Later in the conversation, Onyeachonam claimed that Investor C
“needed to buy ethereum to pay the processing fee,” and after doing so “[Investor
C’s] funds will be available to [withdraw].”
257. Investor C responded, “[A]re you sure they will release funds after I
give processing fees?”
258. Representative C replied, “Yes, that’s how it work[s].”
259. Following instructions from Onyeachonam, posing as Representative
C, Investor C used funds in her crypto asset account to purchase ethereum and
transferred $2,222.16 in ethereum to an address displayed for Investor C on
Secawallet.com, which Onyeachonam set up, controlled, and operated.
260. Indeed, the address displayed for Investor C on Secawallet.com
appeared several times in Onyeachonam’s emails.
261. The next day, June 30, 2022, Investor C reported to Representative C
that LumenTrades was now stating she needed to pay an advisory fee of
approximately $8,000 to “unlock [her] funds.”

` 49
262. Onyeachonam, posing as Representative C, told Investor C that “It’s
included in the contract.”
263. Investor C responded, “in any case I don’t have that kind of funds
right now....”
264. On September 16, 2022, Investor C asked Representative C, “Is there
any other fees after [the processing fees already paid] and your fees?”

265. Onyeachonam, posing as Representative C, responded, “Hi [Investor
C], there is no other fees....  Once the pending payment is cleared, your funds will
be automatically available.”
266. On September 16, 2022, Investor C used funds in her crypto asset
account to purchase ethereum and transferred $3,161.31 in ethereum to the same
Secawallet.com address for Investor C previously described in paragraph 259
ab  ove.
267. On September 19, 2022, Onyeachonam, posing as Representative C,
messaged Investor C, “[T]he payment has been confirmed.  You can login to
secawallet to withdraw your funds.”

268. Investor C was still unable to withdraw her   funds, and on September
26, 2022, Investor C messaged Representative C, “[Lumentrades] support is saying
it’s stuck because there is [not] enough processing fees.  Did you know about it?”
269. The next day, Onyeachonam, posing as Representative C, responded,

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“[P]lease follow the instruction from Lumentrades.  I can’t change anything at this
point.”
270. On September 29, 2022, Investor C received an email from
[email protected] informing Investor C that Secawallet had “started
processing [Investor C’s] stuck transaction.”
271. On September 30, 2022, Investor C messaged Representative C, “I am
worried and stressed.”
272. Onyeachonam, posing as Representative C, responded, “I’m sorry
about the stress.  Everything should be settled today.”

273. Investor C received no further communications from Representative
C.
274. Investor C continued communicating with [email protected]
between September 2022 and February 2023.
275. During that period, Onyeachonam, posing as a support representative
from Secawallet, instructed Investor C to provide certain documents to complete
an “identity verification” process, citing “many unusual activities on your
account.”
276. Investor C complied by providing [email protected] with
scans of Investor C’s driver’s license, utility bill, and United States passport.
277. On October 14, 2022, Onyeachonam, posing as a support

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representative with Secawallet, emailed Investor C, “For security reasons, we
won’t be able to release the funds to the provided [crypto] address.”
278. The purported support representative with Secawallet (in reality,
Onyeachonam) directed Investor C to purchase a hardware wallet, a physical
device that stores crypto assets offline, from shop.secawallet.com and told Investor
C that this hardware wallet would be mailed to her physical address.
279. Two days later, Investor C responded, “Kindly please release the
funds, this looks more like a scam to me now.”
280. On November 7, 2022, Onyeachonam, posing as a support
representative with Secawallet, emailed Investor C a formal invoice for the
hardware wallet that listed its   price as $899.99.
281. Investor C continued exchanging emails regarding the hardware
wallet with Onyeachonam, while he was posing as a support representative with
Secawallet, until February 22, 2023.
282. On that date, Onyeachonam, still posing as the Secawallet support
representative, sent Investor C an email stating, “Once we receive your payment,
your hardware wallet will be shipped to your location.”
283. Investor C received no further communications from
[email protected].
284. Nor did Investor C ever receive any funds or other assets back from

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Defendants.
285. Between July 2021 and September 2022, Defendants stole $106,400
from Investor C.
V. ONYEACHONAM AND ASIEGBU IMPERSONATED A
REGISTERED REPRESENTATIVE FROM CALIFORNIA AND
STOLE MORE THAN $45,000 FROM A NEW JERSEY INVESTOR.

A. Onyeachonam and Asiegbu Impersonated a California
Representative Online.

286. In October 2020, an unknown individual or individuals set up a
website impersonating a California-based broker-dealer and investment adviser
representative (“Representative D”) employed by a large, dually registered broker-
dealer and investment adviser firm that was a household name.
287. In 2020, Representative D had 22 years of experience as a broker-
dealer representative and/or investment adviser representative.
288. In October 2020, an unknown individual or individuals registered a
domain name with Representative D’s actual first and last names.
289. An unknown individual or individuals then created a website on that
domain that advertised Representative D’s financial services.

290. Asiegbu controlled the phony website starting in at least October
2020, and Onyeachonam controlled it starting in at least August 2021.  For
example, Asiegbu maintained hosting accounts for the phony website, and
Onyeachonam maintained an account at an email delivery service that allowed

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email messages to be generated from the phony website.
291. The phony website displayed the real credentials and employment
history of Representative D and linked to Representative D’s actual FINRA
BrokerCheck website page.
292. The phony website also listed an email address with Representative
D’s name as a contact method.
293. That email address, used to communicate with investor victims, was
controlled by Asiegbu since at least March 2021 and by Onyeachonam since at
least April 2022.
294. In June 2021, Onyeachonam registered an LLC in the name of
Representative D in the state of Delaware.
B. Onyeachonam and Asiegbu Promoted Representative D Online.
295. As of March 2022, an email address attributable to Onyeachonam and
Asiegbu used fake identities to promote Representative D’s trading and investment
services in comments to YouTube videos.
296. The comments took the form of a fictitious online conversation
between strangers, one mentioning their investment success with Representative D
and the other following up with questions about Representative D, concluding with
an instruction from the purported Representative D client to look Representative D
up on the Internet and call, email, or send a message.

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297. The fictitious YouTube comments were scripted, and in emails
between and among themselves and others, Onyeachonam and Asiegbu emailed
similar scripts used for another representative Defendants impersonated.
C. A New Jersey Investor Found Representative D Online
and Invested More Than $45,000.
298. An investor who at all relevant times has resided in New Jersey
(“Investor D”) learned about Representative D through comments made on
YouTube touting Representative D’s services.
299. Investor D then found Representative D’s fake website (in reality,
controlled by Asiegbu and Onyeachonam) and sent Representative D a message in
February 2022 using the form on the website.
300. On February 9, 2022, Asiegbu and/or Onyeachonam sent an
introductory email—purportedly from Representative D but actually from Asiegbu
and/or Onyeachonam—to Investor D asking where Investor D was located, what
Investor D’s experience was investing in financial markets, what his financial
goals were, and how much Investor D had “set aside to achieve that financial
goal.”

301. To send the email, Asiegbu and/or Onyeachonam used the email
address they controlled that purported to be Representative D’s address, and
Representative D’s purported email signature block included the seals for both the
SEC and FINRA BrokerCheck.

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302. In response, Investor D said that he had been investing for the last five
years, had $25,000 to invest, and that his goal was to have steady monthly side
income.
303. On February 10, 2022, Asiegbu and/or Onyeachonam, again posing as
Representative D, emailed Investor D and claimed that Representative D traded
across three major financial markets—the stock, foreign exchange, and digital
currency markets—to maximize profit generation and that Representative D used a
“copy trading” tool.
304. The email further claimed that, after downloading and installing a list
of trading apps, the client would create a trading account which the trader would
sync with a copy-trading tool to ensure that the client would be able to
transparently view trading activity.

305. This email was identical to one that Asiegbu and/or Onyeachonam
sent to other potential investors who sought to invest through Representative D.
306. In February 2022, Asiegbu and/or Onyeachonam, posing as
Representative D, emailed Investor D a client investment form and a contract
agreement.

307. The client investment form required Investor D to provide contact and
background information, as well as information about his investing experience,
financial assets, and investments.

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308. The form claimed:  “[Representative D] is a licensed Broker/Financial
Adviser, regulated and accredited by the Financial Industry Regulatory Authority
(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative D] is
therefore operating within the boundaries of [Representative D’s] profession and
the data you will provide below will be used for only investment purposes.”
309. Investor D filled out the client investment form, signed the contract
agreement, and returned both to the email address that purported to be
Representative D’s email address.
310. In February 2022, Asiegbu and/or Onyeachonam, posing as
Representative D, instructed Investor D to download and sign up for accounts at
two SEC-registered broker-dealers, a platform for trading currency, two crypto
asset trading platforms, and LumenTrades.com and to set up a call so that
Representative D could sync Investor D’s accounts with Representative D’s copy
trading tool and discuss funding and investments.
311. On February 19, 2022, Onyeachonam, posing as Representative D,
initiated a WhatsApp text conversation with Investor D.
312. Onyeachonam, posing as Representative D, and Investor D thereafter
communicated primarily through WhatsApp messages.
313. On February 24, 2022, Asiegbu and/or Onyeachonam, posing as
Representative D, emailed Investor D; claimed that, to maximize profit realization,

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Investor D’s capital would be split between the stock market and crypto asset
market at a “9:91 ratio” for the first three weeks of trading due to the bullish state
of the crypto asset market; and instructed Investor D to make an initial deposit of
$2,250 in Investor D’s newly-opened (genuine) brokerage account and $22,750 in
Investor D’s crypto asset account.

314. In February and March 2022, following these instructions, Investor D
purchased bitcoin in his crypto asset account and transferred $21,539.25 in bitcoin
to an address Investor D had set up at a crypto-asset trading platform pursuant to
instructions from Onyeachonam, posing as Representative D.

315. Investor D also deposited $2,500 into his (genuine) brokerage
account.
316. On March 2, 2022, Investor D messaged Representative D (in reality,
Onyeachonam) and asked, “[W]hat about [the genuine brokerage account]?  I have
$2,500 [in] it.”
317. Onyeachonam, posing as Representative D, responded, “Yes, I will
start trading the accounts at once.”
318. Onyeachonam and Asiegbu never placed any trades in Investor D’s
genuine brokerage account.
319. On March 10, 2022, Onyeachonam, posing as Representative D,
messaged Investor D, “I’m executing my first trade on your [crypto asset] account

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today.”
320. Investor D responded, “Awesome.”
321. The LumenTrades.com website displayed Investor D’s investment and
the purported trading returns from Representative D.
322. On March 19, 2022, Investor D messaged Representative D, “I just
logged [] into Lumentrades and saw you did trading yesterday and was able to
make 17% profit in one day!  That is awesome!”
323. After Onyeachonam secured Investor D’s initial investment and
Investor D saw the significant fictitious profits that Representative D was
purportedly generating, Onyeachonam, posing as Representative D, succeeded in
getting Investor D to transfer an additional $24,954.60 in purported investment
funds in March 2022.
324. Onyeachonam and Asiegbu never invested Investor D’s money as
promised but instead misappropriated it.
325. On March 28, 2022, Investor D asked Representative D (in reality,
Onyeachonam) if LumenTrades.com was “legit,” because Investor D had sent an
email to [email protected] and the email bounced back.
326. Onyeachonam, posing as Representative D, messaged Investor D,
“They are doing scheduled maintenance.  That’s the reason for the delay....  Don’t
be worried, I got you as your investment advisor.  You have to trust me as

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investment advisor.  I have your best interest at heart.”
D. Onyeachonam and Asiegbu Gave Investor D the Runaround
When He Attempted to Withdraw Funds.

327. By the end of March 2022, Investor D’s bitcoin had been moved
through several addresses, and Onyeachonam and Asiegbu had stolen it.
328. On March 28, 2022, Investor D asked Representative D (in reality,
Onyeachonam) how to withdraw funds.
329. Onyeachonam, posing as Representative D, responded, “Let me know
when [] you’re ready to make a withdrawal.  I have to close all the open positions
in your account.  And the funds will be available for withdrawal.”
330. On March 30, 2022, Investor D messaged Representative D (in
reality, Onyeachonam), “I would like to withdraw the profit at the end of the day
tomorrow, Mar 31
st
.”
331. Onyeachonam, posing as Representative D, did not respond.
332. Investor D sent Representative D (in reality, Onyeachonam)  many
messages over the next few days and did not receive a response.
333. On April 2, 2022, Investor D emailed Representative D (in reality,
Onyeachonam), “I have tried to reach out on all possible ways.  I don’t understand
why you don’t reply to my messages?  I’m again getting worried about the
investment.  I have also bought new home in Dallas and will need some profit we
make for down payment.”

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334. Neither Onyeachonam nor Asiegbu, posing as Representative D,
responded  .
335. On April 6, 2022, Investor D messaged Representative D (in reality
Onyeachonam), “[P]lease reply to me so that I don’t doubt this to be a Fraud.”

336. The next day, Onyeachonam, posing as Representative D, responded,
“Please calm down.  I’m working currently.  I’m not 100% available to chat all the
time but I will always make out time to communicate with my clients.”
337. Investor D responded, “I understand you may have lots of clients.  I
just want you to understand my situation as it changed after we spoke.  I bought a
house in Dallas and counting on some profit I can take out for down payment.”

338. Onyeachonam, posing as Representative D responded, “I will make
the funds available for withdrawal.  How much do you want to withdraw?”
339. Investor D responded, “[C]urrently it is showing me profit of $6,398.
I just want to withdraw profit.”

340. Onyeachonam, posing as Representative D, replied, “If you withdraw
that amount it will halt my trading strategy but I can proceed to process the
withdrawal if that’s what you want.”
341. Investor D asked follow up questions but received no response from
Representative D.
342. Investor D messaged Representative D (in reality, Onyeachonam)

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many times over the next two weeks asking about withdrawing his funds but
received no response.
343. On April 21, 2022, Investor D messaged Representative D (in reality,
Onyeachonam), “[D]on’t make me believe it’s a Fraud.  I also called
[Representative D’s genuine employer].  I spoke to [another employee] and she
told me you were just a Sales Associate.”
344. Onyeachonam, posing as Representative D, replied, “I don’t know
why you’re being insecure.  I don’t know why you called [Representative D’s
employer].  You’re working with me independently....”
345. Investor D responded, “Because you are not replying to me.  I want to
take out profit as per our agreement.  If I can’t, then I want to just withdraw all my
investment.”

346. Onyeachonam, posing as Representative D, messaged back, “Alright,
the funds will be available tomorrow.”
347. The next day Investor D was unable to withdraw any money from his
LumenTrades account, and his messages to Representative D that day and over the
next six days went unanswered.
348. On April 29, 2022, Onyeachonam, posing as Representative D,
messaged Investor D, “I’m trading.  Relax, allow me to do my job.”
349. Onyeachonam, posing as Representative D, then failed to respond to

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any of Investor D’s messages between April 29, 2022, and June 28, 2022, when
Onyeachonam, posing as Representative D, messaged Investor D in part, “Your
funds are ready,” and instructed Investor D to create an account with
Secawallet.com, which Onyeachonam set up, controlled, and operated.
350. After Investor D set up a   Secawallet account, he messaged
Representative D (in reality, Onyeachonam), “[I]t is asking me to send 2
[ethereum] to someone.  Is that you?”
351. Onyeachonam, posing as Representative D, responded, “No, [it’s]
Lumentrades withdrawal processing fee.”
352. Investor D did not pay the “processing fee.”
353. On September 7, 2022, Investor D wrote to Representative D, “I don’t
want to pay anymore fees, you help me with the withdrawal.  Let me know how I
can withdraw.”
354. Onyeachonam, posing as Representative D, responded (in his final
WhatsApp message to Investor D), “[Y]ou need to pay the processing fee.”
355. Investor D wrote back, “I will pay the fees when [investor D’s money
was withdrawn to a particular crypto asset platform].  I don’t want to pay fees on
any other sites.  Please move the funds into [a particular crypto asset platform] and
let me know when it’s available.”

356. Investor D received no response to his message.

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357. Nor did Investor D ever receive any funds or other assets back from
Onyeachonam and Asiegbu.
358. Onyeachonam and Asiegbu stole $46,493.95 from Investor D.
VI. ONYEACHONAM IMPERSONATED A REGISTERED
REPRESENTATIVE FROM GEORGIA, AND ONYEACHONAM
AND NWEKE-EZE STOLE MORE THAN $500,000 FROM A
CALIFORNIA INVESTOR.

A. Onyeachonam Impersonated a Georgia Representative Online.

359. In November 2021, an unknown individual or individuals set up a
website impersonating a broker-dealer and investment adviser Representative
based in the State of Georgia (“Representative E”) who was employed by a large,
dually registered broker-dealer and investment adviser firm that is a household
name.
360. In 2021, Representative E had 37 years of experience as a registered
representative and/or investment adviser representative.
361. In November 2021, an unknown individual or individuals registered a
domain name with Representative E’s actual first and last names.
362. An unknown individual or individuals also created a website on that
domain that advertised Representative E’s financial services.
363. The phony website displayed the real credentials and employment
history of Representative E and linked to Representative E’s actual FINRA
BrokerCheck website page.

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364. The phony website listed an email address with Representative E’s
name as a contact method.

365. Onyeachonam controlled this    email address, used to communicate
with Defendants’ investor victims, by at least February 2022.
366. The phony website also touted the legal registration of an LLC in the
name of Representative E, claiming that Representative E offered   financial
planning services through that LLC.
367. In June 2021, Onyeachonam registered the LLC listed on the phony
website in the name of Representative E in the state of Delaware.
368. Onyeachonam controlled the phony website starting in at least
January 2022, as alleged in the paragraphs below.
369. Among other things, Onyeachonam received a test communication
from the phony website’s cpanel, a web-based interface that allows website owners
to manage their websites and hosting accounts, in January 2022.
370. From September to December 2023, Onyeachonam accessed the
cpanel page for the phony website six times.
371. Starting by at least September 2023, Onyeachonam maintained an
account for the phony website with a web analytics tool that helps website owners
analyze visitor behavior, track traffic, and optimize their websites.

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B. Onyeachonam and Nweke-Eze Promoted Representative E
Online.

372. Starting in at least June 2022, an email address attributable to Nweke-
Eze used fake identities to promote Representative E’s trading and investment
services in comments to YouTube videos.
373. The comments took the form of a fictitious online conversation
between strangers, one mentioning their investment success with Representative E
and the other following up with questions about Representative E, concluding with
an instruction from the purported Representative E client to look Representative E
up on the Internet and call, email, or send a message.
374. The fictitious YouTube comments were scripted, and in emails sent to
himself and others potentially involved in the fraud, Nweke-Eze emailed similar
scripts used for another representative Defendants impersonated.
375. An email address attributable to Onyeachonam opened a LinkedIn
account for Representative E that touted Representative E as a financial advisor at
the LLC Onyeachonam had registered in Representative E’s name with the state of
Delaware.
C. A California Investor Found Representative E Online
and Invested More Than $500,000.
376. An investor who at all relevant times has resided in California
(“Investor E”) found Representative E’s fake website and sent Representative E (in

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reality, Onyeachonam) a message in December 2022 using the form on the
website.
377. On December 5, 2022, Onyeachonam sent an introductory email—
purportedly from Representative E but actually from Onyeachonam—to Investor E
asking where Investor E was located, what Investor E’s experience was investing
in financial markets, what his financial goals were, and how much Investor E had
“set aside to achieve that financial goal.”

378. Onyeachonam sent the email using the email address that purported to
be Representative E’s address, and Representative E’s purported email signature
block included the seals for both the SEC and FINRA BrokerCheck.
379. In response, Investor E said that he had average knowledge of the
financial markets, his goal was to increase his net worth to $7-8 million in five
years, and that he had properties and stocks worth $5.5 million.
380. On December 7, 2022, Onyeachonam, again posing as Representative
E, emailed Investor E and claimed that Representative E traded across three major
financial markets—the stock, foreign exchange, and digital currency markets—to
maximize profit generation.
381. In December 2022 and January 2023, Onyeachonam, posing as
Representative E, emailed Investor E a client investment form and a contract
agreement.

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382. The client investment form included the seals for both the SEC and
FINRA Brokercheck.
383. The client investment form required Investor E to provide contact and
background information, as well as information about his investing experience,
financial assets, and investments.

384. The form claimed:  “[Representative E] is a licensed Broker/Financial
Adviser, regulated and accredited by the Financial Industry Regulatory Authority
(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative E] is
therefore operating within the boundaries of [Representative E’s] profession and
the data you will provide below will be used for only investment purposes.”
385. The contract agreement claimed that Investor E was required to pay
“10% of the profit accrued by the portfolio under the management.”
386. The contract agreement also promised that “the investment accounts
of [Investor E] under the management of [Representative E] would accrue a
minimum of 5% profits monthly.”
387. Investor E filled out the client investment form, signed the contract
agreement, and returned both to Onyeachonam through the email address he
controlled, which purported to be Representative E’s address.
388. On December 23, 2022, Onyeachonam, posing as Representative E,
sent an email to Investor E instructing him to download and sign up for accounts at

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two SEC-registered broker-dealers, a platform for trading currency, one crypto
asset trading platform, and Secawallet and to set up a call so that Representative E
could sync Investor E’s accounts with Representative E’s copy trading tool and
discuss funding and investments.
389. On January 13, 2023, Onyeachonam, posing as Representative E,
initiated a WhatsApp text conversation with Investor E.
390. Onyeachonam, posing as Representative E, and Investor E thereafter
communicated primarily through WhatsApp messages.
391. On January 13, 2023, Onyeachonam, posing as Representative E,
instructed Investor E through a   WhatsApp message to sign up for Representative
E’s copy trading system and provided a link to a purported copy-trading tool to
purportedly ensure that the client would be able to transparently view trading
activity.
392. On January 16, 2023, Onyeachonam, posing as Representative E,
emailed Investor E and claimed that, to maximize profit realization, Investor E’s
capital would be split between the stock market and crypto asset market at a “40:60
ratio” for the first three weeks of trading due to the bullish state of the crypto asset
market.
393. In the same email, Onyeachonam instructed Investor E to make an
initial deposit of $20,000 in Investor E’s (genuine) brokerage account and $30,000

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in Investor E’s crypto asset account.
394. In January and February 2023, following these instructions, Investor E
purchased bitcoin in his crypto asset accounts and transferred $33,997.54 in bitcoin
to addresses displayed by the Secawallet website.
395. Investor E also deposited $20,000 in his (genuine) brokerage account.
396. On January 31, 2023, Onyeachonam, posing as Representative E, told
Investor E that she had started trading Investor E’s crypto asset account and
provided a link and login credentials to LumenTrades.com, the fake investment
account platform Onyeachonam had created.
397. The LumenTrades.com website displayed Investor E’s investment and
the purported trading returns from Representative E, which appeared to be
substantial.
398. After Onyeachonam secured Investor E’s initial investment and
Investor E saw the significant fictitious profits that Representative E was
purportedly generating, Onyeachonam, posing as Representative E, succeeded in
getting Investor E to transfer an additional $209,879.04 in purported investment
funds over the next three months.
399. Onyeachonam, posing as Representative E, used various techniques to
extract additional funds from Investor E in addition to the fake returns on
LumenTrades:  Onyeachonam (1) promoted new trading strategies that required

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additional funds to garner high returns; (2) repeatedly reminded Investor E that the
crypto asset market was doing well; (3) touted Representative E’s expertise,
service, and trading success; and (4) promised Investor E that, if his account
reached $200,000, he would be able to “withdraw $3,000 monthly without
affecting the investment” using Representative E’s “passive income strategy.”
400. On June 1, 2023, Onyeachonam, posing as Representative E, emailed
Investor E about an “exceptional investment opportunity” called the Alpha Crypto
Private Fund and attached a Prospectus for the Fund.
401. The Prospectus touted Alpha Crypto Private Fund as having
“consistently achieved a 6% monthly ROI [return on investment]” and having a
“current valuation of $29 million.”
402. The Prospectus also claimed that “we only charge a nominal fee of
10% on the profit generated,” and that the “minimum investment amount” was
$600,000.
403. On June 9, 2023, Onyeachonam, posing as Representative E, emailed
Investor E, attaching a document titled “Tax-Loss Harvesting,” and, in his cover
email, wrote, “I strongly urge you to consider the new investment
recommendation, as it flawlessly aligns with your financial goal.  Thank you for
your trust, [Investor E].  As your financial advisor, I have your best interests at
heart.”

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404. The “Tax-Loss Harvesting” document purported to explain various
tax aspects of investments and recommended the Alpha Crypto Private Fund
because it “balances regular withdrawals and long-term capital growth potential”
and “implements an advanced Tax-loss harvesting strategy, which adds an extra
layer of benefit.”
405. The “Tax-Loss Harvesting” document also claimed that, if Investor E
rolled over his LumenTrades account and invested approximately $82,000 in
additional funds, he would “achieve a harmonious balance between regular
withdrawal of $3,000 and the potential for longer-term capital growth.”

406. On June 14, 2023, Onyeachonam, posing as Representative E,
emailed Investor E an   investment application form and subscription agreement for
the Alpha Crypto Private Fund.
407. The Alpha Crypto Private Fund investment application form required
Investor E to provide contact and background information, as well as information
about his investing experience, financial assets, and investments.
408. The Alpha Crypto Private Fund subscription agreement claimed that
the Alpha Crypto Private Fund “shall generate a monthly profit of 6%,” and “shall
charge a performance fee of 10% of the Profit earned by the Subscriber.”
409. Investor E filled out the client investment form, signed the
subscription agreement, and returned both to Representative E (in reality,

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Onyeachonam).
410. On June 16, 2023, Investor E purchased bitcoin in his crypto asset
account and transferred $35,185.11 in bitcoin to an address displayed by the
Secawallet website.
411. Four days later, Onyeachonam, posing as Representative E, messaged
Investor E via WhatsApp that it would be “advantageous” to increase his current
portfolio of $358,965.78 to $400,000 to “ensure seamless integration with our
fund’s investment and tax strategy.”
412. Investor E responded, “So 42k more....  Ok I will arrange that.”
413. Onyeachonam, posing as Representative E, replied, “Ok, once your
portfolio reaches $400,000, it will transitioned [sic] to the fund.”
414. On June 21, 2023, Investor E purchased bitcoin in his crypto asset
account and transferred $39,258.74 in bitcoin to an address displayed by the
Secawallet website.
415. On July 12, 2023, Onyeachonam, posing as Representative E,
provided a link and log-in credentials to portal.alphacryptofund.com, the fake
investment account platform Onyeachonam had created and controlled.
416. On July 26, 2023, Onyeachonam, posing as Representative E,
provided a link and log-in credentials to portal.alphacryptofund.io, which he called
“the backup domain” and which Onyeachonam also created and controlled.

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417. Both the portal.alphacryptofund.com and portal.alphacryptofund.io
websites displayed Investor E’s investment and the purported trading returns from
Representative E’s work with the purported Alpha Crypto Private Fund, and the
trading returns appeared to be substantial.
418. Between August 7 and August 23, 2023, Investor E and
Onyeachonam, posing as Representative E, discussed via WhatsApp messages
Investor E beginning monthly withdrawals of $3,000 at the end of the month.
419. On August 23, 2023, Onyeachonam, posing as Representative E,
purported to explain to Investor E via WhatsApp how to make a withdrawal    from
the Alpha Crypto Fund investor portal.
420. Investor E then wrote to Representative E (in reality, Onyeachonam),
“So for my investment, we will solely focus on crypto.”
421. Onyeachonam, posing as Representative E, replied, “Yes for now.
We will transition to other markets when I see opportunity for high returns.”
422. Investor E responded, “sounds good thx.”

423. Later that day, Investor E submitted a request to withdraw funds from
his Alpha Crypto Fund account.
424. On August 25, 2023, Investor E confirmed via WhatsApp messages
with Representative E (in reality, Onyeachonam) that he had received the $3,000
withdrawal in his crypto asset account and was able to transfer the money to his

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bank account.
425. On September 12, 2023, email addresses attributable to Onyeachonam
exchanged with others a draft of an email to a purported investor regarding a
purported capital call, and the draft email had two attachments.
426. On September 13, 2023, Onyeachonam, posing as Representative E,
sent Investor E an email attaching two documents regarding a purported capital
call by the Alpha Crypto Private Fund—the same email and attachments
Onyeachonam had emailed in draft form the day before.
427. The first attachment, the capital call notice, purported to require
Investor E to make a capital contribution of $197,220.57 to the Alpha Crypto
Private Fund to reach a total commitment of $600,000 “as per the Subscription
Agreement dated 06/14/2023.”
428. The capital call notice warned that, if Investor E failed to make the
payments by September 29, 2023, he would be “subject to late fees,” and would be
charged interest on the unpaid amount and/or suffer a reduction in his percentage
interest in the Fund.
429. The second attachment, titled “ALPHA CRYPTO PRIVAGE FUND:
New Investment Strategy,”   claimed that the capital call was necessary to take
significant positions, to invest in blockchain infrastructure projects and diversity
investments, and to create a tax-loss harvesting solution.

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430. On September 13, 2023, Investor E messaged Representative E (in
reality, Onyeachonam), “I think I committed to 400k on my initial sign up, 600k
would be high investment for me.”
431. In response, Onyeachonam, posing as Representative E, messaged
Investor E that investing in the Alpha Crypto Private Fund aligned with his goals
of a passive income stream, continued wealth accumulation, and an optimized tax
strategy.
432. Representative E (in reality, Onyeachonam) also offered Investor E an
“upgrade to Tier 2, designed for investors who hold a full stake in the fund and
receive the exact percentage the fund earns each month.”
433. On September 15, 2023, Investor E messaged Representative E, “I
will send 100k first and remaining later.”
434. Onyeachonam, posing as Representative E, responded, “Ok.”
435. On September 29, 2023, Investor E purchased bitcoin in his crypto
asset account and transferred an additional $99,089.28 to an address displayed by
Secwallet.com.
436. As Investor E was working on transferring the funds, Onyeachonam,
posing as Representative E, messaged him, “[Investor E], just a friendly reminder:
please ensure that you move the funds to your secawallet account by 11:59 pm
today to avoid incurring late fees.”

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437. Investor E responded, “yes working on it.”
438. On October 9, 2023, Onyeachonam, posing as Representative E, sent
Investor E an email attaching the Alpha Crypto Private Fund’s purported
September 2023 performance report.
439. The purported performance report claimed “total assets under
management” of $35.5 million, a September opening balance of $29.2 million,
“September Performance” of 6.42% and “YTD Performance” of 58.7%.
440. The report included a purported “Fund Manager’s Commentary” from
Representative E.
441. On October 13, 2023, Investor E asked Representative E (in reality,
Onyeachonam) via WhatsApp why Investor E’s account on the Alpha Crypto Fund
investor portal showed a return of 4.08%, while the September newsletter stated a
return of 6.42%.
442. Onyeachonam, posing as Representative E, responded that if Investor
E invested an additional $96,000, he would “receive the actual percentage that the
fund earns,” and that Investor E would begin “to receive a stable cash flow of
$3,000 every month.”
443. Investor E responded that he would work on selling a rental property
to cover the additional funds.
444. On November 3, 3023, Onyeachonam posing as Representative E,

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sent Investor E an email attaching the Alpha Crypto Private Fund’s purported
October 2023 performance update.
445. The purported performance update listed monthly returns of 6.72%,
year-to date returns of 59.5%, and year-to-date asset growth of 23.5%.
446. The purported performance update appeared to be signed by
Representative E as the Fund Manager of the Alpha Crypto Private Fund.
447. On November 3, 2023, Onyeachonam, posing as Representative E,
messaged Investor E that he needed to invest additional funds to utilize a tax
saving strategy that “could potentially lessen [Investor E’s] tax liabilities by up to
45%,” noting that “timing is crucial,” and that the additional funds needed to be
invested soon for the strategy to be available.
448. On November 10, 2023, Investor E purchased bitcoin in his crypto
asset account, transferred an additional $59,127.54 in bitcoin to an address
displayed by the Secawallet website, and told Representative E (in reality,
Onyeachonam) via WhatsApp that this investment “should fulfill the 600k
requirement principle + profit rollover.”
449. On November 10, 2023, Onyeachonam, posing as Representative E,
messaged Investor E that he was approximately $35,000 short of the “required
principal target” because rolling over profits to meet funding requirements was not
“feasible” to “avoid a potentially complex tax situation.”

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450. On November 27, 2023, Investor E purchased bitcoin in his crypto
asset account, transferred an additional $36,601.13 in bitcoin to an address
displayed on the Secawallet website, and messaged Representative E (in reality,
Onyeachonam), “I just deposited the final funding to the Secawallet.”
451. Investor E also asked, “That should fulfill the capital requirement for
the fund right?”
452. Onyeachonam, posing as Representative E, responded, “Yes.”
453. In reality, Onyeachonam and Nweke-Eze never invested Investor E’s
money as promised but instead misappropriated it.
D. Onyeachonam Gave Investor E the Runaround When He
Attempted to Withdraw Additional Funds.

454. By late November 2023, Investor E’s bitcoin had been moved through
several addresses, and Onyeachonam and Nweke-Eze had stolen it .
455. On November 28, 2023, Investor E wrote to Representative E (in
reality, Onyeachonam), “I will start my monthly withdrawal in Jan [2024].”
456. Onyeachonam, posing as Representative E, responded, “I got it,
January 2024.”
457. On January 11, 2024, Investor E emailed Representative E (in reality,
Onyeachonam), “I am trying to contact you, can you either reply back to this email
or send me message on whatsapp.  thx.”
458. Onyeachonam, posing as Representative E, responded, “I will get

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back to you on WhatsApp as soon as possible.”
459. Onyeachonam did not respond on WhatsApp.
460.  Investor E emailed Representative E (in reality, Onyeachonam)
multiple times in January 2024 about being unable to make withdrawal  s from the
Alpha Crypto Fund portal or the Secawallet website and about his emails to the
support address for these websites being returned, having failed to deliver.
461. On January 26, 2024, Investor E emailed the support email address for
Secawallet and received a notice that the email was unable to be delivered.
462. Onyeachonam, posing as Representative E, and Investor E spoke on
the phone on February 2, 2024.
463. After the phone call, Investor E emailed Representative E (in reality,
Onyeachonam) three times in February 2024 without a response.
464. On February 20, 2024, Onyeachonam, posing as Representative E,
sent a final email to Investor E, noting that Investor E’s portfolio had accrued more
than $220,000 in profit and suggesting that Investor E either move the invested
funds to “a more conservative stock portfolio” or invest additional bitcoin into the
current portfolio to ensure Investor E could meet his goal of withdrawing $3,000
monthly.
465. Investor E did not respond to this email.
466. Investor E did not receive any additional funds or other assets back

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from Onyeachonam or Nweke-Eze other than the single $3,000 payment described
above.
467. Between January and November 2023, Onyeachonam and Nweke-Eze
stole $510,138.38 from Investor E.
FIRST CLAIM FOR RELIEF
Violations of Securities Act Sections 17(a)(1) and (3)
(All Defendants)

468. The Commission re-alleges and incorporates by reference here the
allegations in paragraphs 1 through 467.
469. Defendants, directly or indirectly, singly or in concert, in the offer or
sale of securities and by the use of the means or instruments of transportation or
communication in interstate commerce or the mails, (i) knowingly or recklessly
have employed one or more devices, schemes or artifices to defraud, and/or (ii)
knowingly, recklessly, or negligently have engaged in one or more transactions,
practices, or courses of business which operated or would operate as a fraud or
deceit upon the purchaser.
470. By reason of the foregoing, Defendants, directly or indirectly, singly
or in concert, have violated and, unless enjoined, will again violate Securities Act
Sections 17(a)(1) and (3) [15 U.S.C. §§ 77q(a)(1) and 77q(a)(3)].

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SECOND CLAIM FOR RELIEF
Violations of Securities Act Section 17(a)(2)
(Onyeachonam)

471. The Commission re-alleges and incorporates by reference here the
allegations in paragraphs 1 through 54, 57 through 149, 153 through 196, 205, 210
through 371, and 375 through 467.
472. Onyeachonam, directly or indirectly, singly or in concert, in the offer
or sale of securities and by the use of the means or instruments of transportation or
communication in interstate commerce or the mails, knowingly, recklessly, or
negligently has obtained money or property by means of one or more untrue
statements of a material fact or omissions of a material fact necessary in order to
make the statements made, in light of the circumstances under which they were
made, not misleading.
473. By reason of the foregoing, Onyeachonam, directly or indirectly,
singly or in concert, has violated and, unless enjoined, will again violate Securities
Act Section 17(a)(2) [15 U.S.C. § 77q(a)(2)].
THIRD CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rules 10b-5(a) and (c)
Thereunder
(All Defendants)

474. The Commission re-alleges and incorporates by reference here the
allegations in paragraphs 1 through 467.
475. Defendants, directly or indirectly, singly or in concert, in connection

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with the purchase or sale of securities and by the use of means or instrumentalities
of interstate commerce, or the mails, or the facilities of a national securities
exchange, knowingly or recklessly have (i ) employed one or more devices,
schemes, or artifices to defraud, and/or (ii) engaged in one or more acts, practices,
or courses of business which operated or would operate as a fraud or deceit upon
other persons.
476. By reason of the foregoing, Defendants, directly or indirectly, singly
or in concert, have violated and, unless enjoined, will again violate Exchange Act
Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) thereunder [17
C.F.R. §§ 240.10b-5(a) and 240.10b-5(c)].
FOURTH CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5(b)
(Onyeachonam)

477. The Commission re-alleges and incorporates by reference here the
allegations in paragraphs 1 through 54, 57 through 149, 153 through 196, 205, 210
through 371, and 375 through 467.
478. Onyeachonam, directly or indirectly, singly or in concert, in
connection with the purchase or sale of securities and by the use of means or
instrumentalities of interstate commerce, or the mails, or the facilities of a national
securities exchange, knowingly or recklessly has made one or more untrue
statements of a material fact or omitted to state one or more material facts

` 83
necessary in order to make the statements made, in light of the circumstances
under which they were made, not misleading.
479. By reason of the foregoing, Onyeachonam, directly or indirectly,
singly or in concert, has violated and, unless enjoined, will again violate Exchange
Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5(b) thereunder [17 C.F.R.
§ 240.10b-5(b)].
FIFTH CLAIM FOR RELIEF
Violations of Advisers Act Sections 206(1) and (2)
(Onyeachonam and Asiegbu)

480. The Commission re-alleges and incorporates by reference here the
allegations in paragraphs 1 through 55, 57 through 149, 153 through 205, 210
through 371, and 375 through 467.
481. At all relevant times, Onyeachonam and Asiegbu were investment
advisers, under Advisers Act Section 202(11) [15 U.S.C. § 80b-2(11)].
482. Onyeachonam and Asiegbu, by use of the mails or any means or
instrumentality of interstate commerce, directly or indirectly have (i) knowingly or
recklessly employed one or more devices, schemes, or artifices to defraud any
client or prospective client, and/or (ii) knowingly, recklessly, or negligently
engaged in one or more transactions, practices, and courses of business which
operated or would operate as a fraud or deceit upon any client or prospective client.
483. By reason of the foregoing, Onyeachonam and Asiegbu, directly or

` 84
indirectly, singly or in concert, have violated and, unless enjoined, will again
violate Advisers Act Sections 206(1)  and (2) [15 U.S.C. §§ 80b-6(1)  and 80b-6(2)].
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that the Court enter a
Final Judgment:
I.
Permanently enjoining Defendants and their agents, servants, employees and
attorneys and all persons in active concert or participation with any of them from
violating, directly or indirectly, Section 17(a) of the Securities Act [15 U.S.C.
§ 77q(a)], Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5
thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1)  and (2) of the Advisers
Act [15 U.S.C. §§ 80b-6(1) and 80b-6(2)];
II.
Permanently enjoining Defendants from directly or indirectly, including, but
not limited to, through any entity controlled by each Defendant: (i) participating in
the issuance, purchase, offer, or sale of any security on behalf of someone else; or
(ii) engaging in activities for purposes of inducing or attempting to induce the
purchase or sale of any security, including holding themselves out as industry
professionals; provided, however, that such injunction shall not prevent each
Defendant from purchasing or selling securities for his own personal account;

` 85
III.
Ordering Defendants to disgorge all ill-gotten gains they received directly or
indirectly, with pre-judgment interest thereon, as a result of the alleged violations,
pursuant to Exchange Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C.
§§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];
IV.
Ordering Defendants to pay civil monetary penalties under Securities Act
Section 20(d) [15 U.S.C. § 77t(d)], Exchange Act Section 21(d)(3) [15 U.S.C.
§ 78u(d)(3)], and Advisers Act Section 209(e) [15 U.S.C. § 80b-9(e)]; and
V.
Granting any other and further relief this Court may deem just and proper.
JURY DEMAND
 The Commission demands a trial by jury.

` 86
Dated: New York, New York
 December 11, 2024

/s/ Antonia M. Apps
ANTONIA M. APPS
REGIONAL DIRECTOR
Tejal Shah
Adam S. Grace
Travis Hill
Rhonda Jung
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-9135 (Hill)
[email protected]

     Deborah A. Tarasevich
     Elizabeth Doisy
     Martin Zerwitz
Securities and Exchange Commission
100 F Street N.E. / Mail Stop 5631
Washington, D.C. 20549-5631

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

SECURITIES AND EXCHANGE
COMMISSION,

                                             Plaintiff,

                        -against-

CHIBUZO AUGUSTINE
ONYEACHONAM, STANLEY
CHIDUBEM ASIEGBU, and
CHUKWUEBUKA MARTIN NWEKE-
EZE,

                                             Defendants.

24-CV-11026

DESIGNATION OF
AGENT FOR SERVICE

Pursuant to Local Rule 101.1(f), because the Securities and Exchange
Commission (the “Commission”) does not have an office in this district, the United
States Attorney for the District of New Jersey is hereby designated as eligible as an
alternative to the Commission to receive service of all notices or papers in the
captioned action.

2
 Therefore, service upon the United States or its authorized designee, David
Dauenheimer, Deputy Chief, Health Care Fraud Unit, United States Attorney’s
Office for the District of New Jersey, 970 Broad Street, Suite 700, Newark, NY
07102, shall constitute service upon the Commission for purposes of this action.

     Respectfully submitted,

/s/ Antonia M. Apps
ANTONIA M. APPS
REGIONAL DIRECTOR
Tejal Shah
Adam S. Grace
Travis Hill
Rhonda Jung
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street
Suite 20-100
New York, NY 10004-2616
212-336-9135 (Hill)
[email protected]

     Deborah A. Tarasevich
     Elizabeth Doisy
     Martin Zerwitz
Securities and Exchange Commission
100 F Street N.E. / Mail Stop 5631
Washington, D.C. 20549-5631

Attorneys for Plaintiff
Securities and Exchange Commission

ANTONIA M. APPS 
REGIONAL DIRECTOR 
Tejal Shah 
Adam S. Grace 
Travis Hill 
Rhonda Jung 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-9135 (Hill) 
[email protected] 
Deborah A. Tarasevich 
Elizabeth Doisy 
Martin Zerwitz 
SECURITIES AND EXCHANGE COMMISSION 
100 F Street N.E. / Mail Stop 5631 
Washington, D.C. 20549-5631 
Attorneys for Plaintiff 
 

UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
                                             Plaintiff, 
 
                        -against- 
 
CHIBUZO AUGUSTINE 
ONYEACHONAM, STANLEY 
CHIDUBEM ASIEGBU, and 
CHUKWUEBUKA MARTIN NWEKE-
EZE, 
  
                                             Defendants.  
 

 
 
COMPLAINT  
 
24-CV-11026 

 
   

JURY TRIAL        
DEMANDED 
  

           
          

 
Plaintiff Securities and Exchange Commission (“Commission”), located at 

Case 2:24-cv-11026     Document 1     Filed 12/11/24     Page 1 of 88 PageID: 1



  

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100 Pearl Street, Suite 20-100, New York, New York 10004-2616, for its 

Complaint against Defendants Chibuzo Augustine Onyeachonam 

(“Onyeachonam”), whose last known address is No. 15 Sir Clement Ezeodili 

Street, Ifite Awka, Anambra State, Nigeria; Stanley Chidubem Asiegbu 

(“Asiegbu”), whose last known address is No. 15 Mission Road, Awka, Anambra 

State, Nigeria; and Chukwuebuka Martin Nweke-Eze (“Nweke-Eze”), whose last 

known address is No. 4 Ashawo Street, Akwai, Adamawa State, Nigeria, (together, 

“Defendants”) alleges as follows: 

SUMMARY 

1. Defendants, none of whom is an actual securities industry 

professional, impersonated real-life United States securities broker and investment 

adviser representatives online and by telephone and fraudulently obtained at least 

$2.9 million from mostly U.S.-based investors, who never knew Defendants’ true 

identities. 

2. Since at least 2019 through the date of this Complaint’s filing (the 

“Relevant Period”), Defendants—Nigerian nationals living in Nigeria—created 

websites impersonating at least 22 actual securities broker and investment adviser 

representatives (collectively, “Representatives”) at prominent U.S. securities firms 

and touted the representatives’ purported securities industry experience in a 

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fraudulent scheme to lure potential U.S. investors into investing funds with 

Defendants.   

3. In addition to posing as representatives, Defendants made repeated 

misrepresentations—including promises of monthly investment returns of 15% to 

25%—to potential investors to persuade them to invest.  

4. Defendants, posing as Representatives, instructed investors to open 

accounts at broker-dealers and crypto-asset trading platforms and purchase crypto 

assets, which Defendants then misappropriated. 

5. Defendants also directed investors to fake online investment platforms 

Defendants created, where Defendants showed investors fictitious high returns.  

These fake returns and Defendants’ purportedly successful trading skills led many 

investors to invest additional funds that Defendants also misappropriated.   

6. When investors ultimately sought to withdraw their funds, Defendants 

informed investors that they were required to pay additional fees before funds 

would be released to them—holding investors’ funds ransom.  

7. In all, Defendants—and/or others working with them—stole at least 

$2.9 million from at least 28 investors, most of whom reside in the U.S. 

VIOLATIONS 

8. By virtue of the foregoing conduct and as alleged further herein, 

Defendants violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) 

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[15 U.S.C. § 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 

(“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. 

§ 240.10b-5], and Sections 206(1) and (2) of the Investment Advisers Act of 1940 

(“Advisers Act”) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)].   

9. Unless Defendants are restrained and enjoined, they will engage in the 

acts, practices, transactions, and courses of business set forth in this Complaint or 

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

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

10. The Commission brings this action pursuant to the authority conferred 

upon it by Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 

77t(d)], Exchange Act Section 21(d) [15 U.S.C. § 78u(d)], and Advisers Act 

Sections 209(d) and 209(e) [15 U.S.C. §§ 80b-9(d) and 80b-9(e)].  

11. The Commission seeks a final judgment: (a) permanently enjoining 

Defendants from violating the federal securities laws and rules this Complaint 

alleges they violated; (b) permanently enjoining Defendants from directly or 

indirectly, including, but not limited to, through any entity controlled by each 

Defendant: (i) participating in the issuance, purchase, offer, or sale of any security 

on behalf of someone else; or (ii) engaging in activities for purposes of inducing or 

attempting to induce the purchase or sale of any security, including holding 

themselves out as industry professionals; provided, however, that such injunction 

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shall not prevent each Defendant from purchasing or selling securities for his own 

personal account; (c) ordering Defendants to disgorge all ill-gotten gains they 

received as a result of the violations alleged here and to pay prejudgment interest 

thereon, pursuant to Exchange Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 

U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; (d) ordering Defendants to pay 

civil money penalties pursuant to Securities Act Section 20(d) [15 U.S.C. § 77t(d)], 

Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], and Advisers Act Section 

209(e) [15 U.S.C. § 80b-9(e)]; and (e) ordering any other and further relief the 

Court may deem just and proper.  

JURISDICTION AND VENUE 

12. This Court has jurisdiction over this action pursuant to Securities Act 

Section 22(a) [15 U.S.C. § 77v(a)], Exchange Act Section 27 [15 U.S.C. § 78aa], 

and Advisers Act Section 214 [15 U.S.C. § 80b-14].  

13. Defendants, directly and indirectly, have made use of the means or 

instrumentalities of interstate commerce or of the mails in connection with the 

transactions, acts, practices, and courses of business alleged herein. 

14. Venue lies in this District under Securities Act Section 22(a) [15 

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

Section 214 [15 U.S.C. § 80b-14].  Certain of the acts, practices, transactions, and 

courses of business alleged in this Complaint occurred within this District.  At least 

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one of Defendants’ investor victims resides in New Jersey and communicated with 

Defendants from New Jersey. 

DEFENDANTS 

15. Onyeachonam, age 30, resides in Awka, Nigeria.  He has never been 

associated with any entity registered with the Commission.  According to social 

media, Onyeachonam purports to be a web developer with Nicrotech.com, a web 

design and development business that uses Onyeachonam’s personal cell phone 

number and address. 

16. Asiegbu, age 27, resides in Awka, Nigeria.  He has never been 

associated with any entity registered with the Commission. 

17. Nweke-Eze, age 29, resides in Akwai, Nigeria.  He has never been 

associated with any entity registered with the Commission. 

DEFENDANTS’ FICTITIOUS ENTITIES 

18. Alpha Crypto Fund is a fake investment fund at least Onyeachonam 

pitched by impersonating a financial professional.  The associated website was 

visible to users in the U.S. and included an investor portal that was used to provide 

false information to investors regarding the performance of their investment.  

Onyeachonam set up, controlled, and operated The Alpha Crypto Fund domains 

(alphacryptofund.com and alphacryptofund.io).  An email address attributable to 

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Onyeachonam registered the alphacryptofund.com domain in May 2023 and the 

alphacryptofund.io domain in July 2023.  

19. CopyTradeApp is a fake internet platform visible to users in the U.S. 

and abroad that was used to make investors think that impersonated financial 

professionals were engaging in “copy trading,” a portfolio management strategy by 

which the financial professional would trade the investor’s assets in sync with 

other trading activity being conducted by the professional.  Both CopyTradeApp 

domains (CopyTradeApp.io and CopyTradeApp.com) were set up by 

Onyeachonam.  An email address attributable to Onyeachonam registered the 

Copytradeapp.io domain in August 2020 and the Copytradeapp.com domain in 

September 2022.  

20. InstaForex Service, with a website visible to users in the U.S. and 

abroad, purported to hold investors’ funds for the duration of their investment. 

When investors attempted to withdraw their funds, InstaForex Service purported to 

require various costs and fees before any funds would be released to investors.  A 

credit card in Nweke-Eze’s name was used to deposit funds into the domain 

registrar account through which instaforexservice.com was registered.  Those 

funds were used to renew the hosting plan for instaforexservice.com.  

21. LumenTrades is a fake investment account platform visible to users 

in the U.S. and abroad, where investors were shown their initial investment and 

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often substantial, fictitious trading returns.  Onyeachonam set up, controlled, and 

operated LumenTrades.  Email addresses attributable to Onyeachonam were used 

to register the LumenTrades.com domain in August 2018 and incorporate 

LumenTrades Financial Incorporated in Oregon in March 2019.  Email addresses 

attributable to Onyeachonam also show that he paid to incorporate LumenTrades 

as a legal entity in the United Kingdom.  An email address attributable to Asiegbu 

shows that he assisted with the operation and control of LumenTrades.com by: (1) 

emailing code for displaying stock and trading information to 

[email protected], an email address controlled by Onyeachonam; (2) 

creating a business profile for LumenTrades so that LumenTrades could be found 

on Google Search and Maps; and (3) testing the stock purchasing and live chat 

functions for LumenTrades.com. 

22. Nuvoak is a fictitious investment adviser firm purported to be 

associated with an impersonated representative in Defendants’ scheme.  One of 

Nuvoak’s web domains (MyNuvoakOnline.com), visible to users in the U.S. and 

abroad, contained an investor portal used to provide false information to investors 

regarding their investment performance.  Onyeachonam set up, controlled, and 

operated MyNuvoakOnline.com.  An email address attributable to Onyeachonam 

registered the MyNuvoakOnline.com domain in November 2023. 

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23. Secawallet, with a website visible to users in the U.S. and abroad, 

displayed blockchain addresses to which investors were instructed to send their 

crypto assets.  The website was used to give investors the false impression that 

crypto assets were “stored” with Secawallet for investment on their behalf.  In 

reality, the investors’ crypto assets were stolen once they were sent to the 

addresses displayed by the Secawallet website.  Onyeachonam set up, controlled, 

and operated Secawallet.com.  An email address attributable to both Onyeachonam 

and Asiegbu registered the Secawallet.com domain in June 2022.  An email 

address attributable to Onyeachonam took ownership of the domain in September 

2023. 

24. Wealthwindow is a fake investment account platform visible to users 

in the U.S. and abroad, where investors were shown their initial investment and 

fictitious trading returns, which were often substantial.  An email address 

attributable to Onyeachonam was used to register the wealthwindow.io domain in 

April 2024. 

FACTS 

I. THE GENERAL STRUCTURE OF DEFENDANTS’ FRAUDULENT  
CYBER INVESTMENT SCHEME 

25. Defendants’ scheme involved registering internet domain names with 

the real first and last names of actual U.S.-based securities brokerage or investment 

adviser representatives—for example, “johndoe.com”—whom Defendants planned 

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to impersonate.  

26. Most of the Representatives were employed at prominent U.S. 

investment firms. 

27. Defendants similarly formed limited liability companies (“LLCs”) 

using the names of the professionals they were impersonating to make it look like 

the professionals had their own investment-related firms. 

28. Defendants then created websites that copied the real Representatives’ 

genuine employment history and credentials from the Financial Industry 

Regulatory Authority’s (“FINRA”) BrokerCheck or the Commission’s Investment 

Adviser Public Disclosure websites.1  

29. The websites Defendants created touted the Representatives’ 

investment advisory, trading, and crypto expertise.   

30. The websites also sometimes provided the names of the LLCs 

Defendants had created using the names of the professionals they were 

impersonating. 

31. To lure potential investors to the websites, Defendants (and possibly 

others working with them) created profiles on YouTube and placed fictitious 

 
1 FINRA is a self-regulatory organization, and BrokerCheck is a publicly-

available, online tool listing employment history, certifications, licenses, and any 
legal violations for brokerage firm representatives and investment advisers, 
available at https://brokercheck.finra.org. 

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comments from purported advisory clients and brokerage customers (collectively, 

“Fake Clients”) underneath investment-themed YouTube videos.   

32. The Fake Clients’ purported comments praised the Representatives’  

investment services and trading success.   

33. Defendants used fake LinkedIn personas and participated in 

investment group chats in encrypted messaging apps to reach out to potential 

victims and encourage them to research the Representative whose identity 

Defendants had stolen.   

34. Defendants, who impersonated mostly female financial professionals 

in the U.S., also purchased voice-changing software. 

35. When potential investors, thinking Defendants were the impersonated 

Representatives, contacted Defendants, Defendants sent emails claiming that the 

Representatives would trade on each investor’s behalf across three markets—the 

U.S. stock market, the foreign exchange market, and the crypto asset market—and 

recommended an investment allocation strategy that Defendants claimed would 

generate profits of 15% to 25% monthly.   

36. Defendants’ emails to potential investors claimed that the 

Representatives used a “copy trading” program that linked each investor’s and 

Representative’s trading accounts to ensure that each investor could see all of the 

representative’s trades on the investor’s behalf.   

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37. The potential investor then completed a client investment form and 

contract agreement and returned them by email to Defendants.   

38. Next, Defendants typically instructed each investor to download 

legitimate trading apps and open accounts at specific, genuine broker-dealers and 

crypto-asset trading platforms and then provide their login credentials to 

Defendants so that Defendants could sync the investor’s real accounts to the 

impersonated Representative’s purported copy trading program—Defendants’ 

CopyTradeApp.   

39. Defendants—still impersonating real financial professionals—then 

typically told each investor that, for the first three weeks, they would 

predominantly trade the investor’s funds in the crypto market to take advantage of 

its bullish state.   

40. Defendants typically instructed each investor to fund specific, genuine 

brokerage accounts and crypto accounts at approximately a “20:80 ratio” or “10:90 

ratio”—meaning to put one quarter or one ninth the amount of funds in brokerage 

accounts as in crypto accounts.   

41. Defendants typically further instructed each investor to purchase 

bitcoin with the funds in the crypto account and send the bitcoin to a specified 

address to “fund” the investment.  In some cases, the receiving address was set up 

by investors at Defendants’ instruction.  In other cases, the address was provided 

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by Defendants who claimed that the address was held by third-party entities which 

stored the investors’ bitcoin for the duration of their investment.  In reality, the 

purported third-party entities—e.g., Secawallet and InstaForex Service—were 

controlled by Defendants.   

42. When investors purchased and transferred the bitcoin, they incurred 

third-party fees associated with the purchase and transfer of crypto assets—

payments that increased their ultimate losses from Defendants’ scheme.  

43. Once the bitcoin was in the address Defendants had specified, the 

bitcoin was moved through multiple addresses, often ultimately landing in 

addresses controlled by Defendants or their associates.  

44. Defendants then stole each investor’s bitcoin instead of investing it.  

45. Investors’ funds in their real brokerage accounts remained mostly 

untouched by Defendants.  

46. However, some of the brokerage account funds were subsequently 

used to further “fund” the investors’ crypto asset investments, which were 

accessible to Defendants.   

47. Defendants informed investors that they could view their account 

balance on an investment platform website—one of Defendants’ fake platforms 

such as LumenTrades, Wealthwindow, or MyNuvoakOnline.com—which showed 

investors’ purported returns on their investments.   

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48. After investors saw their investment accounts grow substantially, as 

fictitiously depicted in Defendants’ fake investment platforms, Defendants—still 

posing as the real Representatives—often offered new trading strategies that 

Defendants claimed required investors to put in additional funds to maximize their 

returns.  

49. Many investors, believing their initial investments had been 

successful, invested additional funds.   

50. When investors requested to withdraw their funds, Defendants 

typically demanded that the investors pay commissions, performance, or other 

purported fees to access their funds.   

51. Some investors paid these purported fees.  

52. Investors did not know that they were actually investing with 

Defendants and not the Representatives whose identities Defendants had stolen. 

53. Onyeachonam participated in the scheme by setting up the 

impersonated Representatives’ websites; incorporating entities in the names of at 

least six impersonated Representatives; promoting impersonated Representatives 

online; setting up and operating fake investment account platforms; purchasing 

products and services used in the scheme; and impersonating Representatives to 

communicate with victim investors. 

54. According to Onyeachonam’s public Goodreads profile, fifteen days 

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after Onyeachonam registered the Lumentrades.com domain in 2018, 

Onyeachonam read The Confidence Game: Why We Fall for It . . . Every Time 

(Penguin Books 2017), a book written by Maria Konnikova and described by The 

Washington Post as an “unnerving manual for conning and getting conned.” 

55. Asiegbu participated in the scheme by assisting in setting up websites 

used in the scheme; promoting the impersonated Representatives and fake 

investment account platforms to the investing public; and managing email 

addresses used to communicate with victim investors. 

56. Nweke-Eze participated in the scheme by using social media to solicit 

potential investors; promoting impersonated Representatives and Defendants’ 

fictitious trading platforms online; and managing an email address used to 

communicate with victim investors. 

57. During their fraudulent scheme, Defendants impersonated at least 22 

Representatives and stole at least $2.9 million from at least 28 investors, at least 23 

of whom reside in the U.S. 

58. The examples below detail Defendants’ fraudulent scheme with 

respect to five of these U.S. investors. 

 

 

 

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II. ONYEACHONAM IMPERSONATED A REGISTERED 
REPRESENTATIVE FROM WISCONSIN AND DEFENDANTS 
STOLE MORE THAN $500,000 FROM A CALIFORNIA INVESTOR.  

 
A. Onyeachonam Impersonated a Wisconsin Representative Online.  

 
59. In November 2019, Onyeachonam set up a website impersonating a 

Wisconsin-based registered Representative and investment adviser Representative 

(“Representative A”), who was employed by a large, dually registered broker-

dealer and investment adviser firm that is a household name.  

60. In 2019, Representative A had 19 years of experience as a broker-

dealer representative and/or investment adviser representative. 

61. In 2019, an email address attributable to Onyeachonam registered a 

domain name with Representative A’s actual first and last name.  

62. Onyeachonam then created a website on that domain that advertised 

the Representative’s financial services.   

63. The website displayed the real credentials and employment history of 

Representative A and linked to Representative A’s actual FINRA BrokerCheck 

website page.   

64. Onyeachonam’s phony website also listed an email address with 

Representative A’s name as a contact method.   

65. That email address, which Onyeachonam used to communicate with 

investors, had been set up using another email address attributable to 

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Onyeachonam. 

66. In May 2020, Onyeachonam registered an LLC in the name of 

Representative A in the state of Colorado. 

B. Defendants Promoted Representative A Online.  

67. Onyeachonam, Asiegbu, and Nweke-Eze promoted Representative A 

using Google Ads, YouTube, and LinkedIn accounts, all of which directed 

potential investors to the Representative A website Onyeachonam had created.   

68. On November 28, 2019, Onyeachonam opened a Google Ads account 

in the name of Representative A and listed his own name—“Chibuzo 

Onyeachonam”—as the contact person and his Nigerian address at the time as the 

postal address.   

69. That day, email addresses attributable to Onyeachonam and Asiegbu 

began running ads on Google for Representative A stating, “[Representative A] is a 

Professional Investment Adviser, Expert Trader, Crypto Analyst, and a Financial 

Consultant.”   

70. The language in the Google ads was similar to the representations 

made on the phony Representative A website Onyeachonam had created.   

71. The Google ads also linked to the phony Representative A website.   

72. Email addresses attributable to Onyeachonam, Asiegbu, and Nweke-

Eze also used fake identities to promote Representative A’s trading and investment 

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services in comments to YouTube videos.   

73. The comments took the form of a fictitious online conversation 

between strangers, one mentioning their investment success with Representative A 

and the other following up with questions about Representative A, concluding with 

an instruction from the purported Representative A client to look Representative A 

up on the Internet and call, email, or send a message.   

74. The fictitious YouTube comments were scripted, and in emails 

between and among themselves (and others), Onyeachonam, Asiegbu, and Nweke-

Eze emailed similar scripts used for another Representative Defendants 

impersonated.  

75. An email address attributable to Onyeachonam also opened a 

LinkedIn account for Representative A that touted Representative A as a Financial 

Consultant at the firm for which Representative A genuinely worked.  

C. A California Investor Found Representative A Online  
and Invested More Than $500,000. 

76. An investor who at all relevant times has resided in California 

(“Investor A”) learned about Representative A when someone in a Signal investor 

group chat circulated a link to YouTube comments touting Representative A’s 

services.2   

 
2 Signal is an encrypted messaging app. 

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77. Investor A then found Representative A’s fake website, reviewed 

Representative A’s qualifications and licenses, and emailed the person Investor A 

thought was Representative A in August 2020 at the email address listed on the 

fake website that Onyeachonam had created.   

78. On August 7, 2020, Onyeachonam sent an introductory email—

purportedly from Representative A but actually from Onyeachonam—to Investor 

A asking where Investor A was located, what Investor A’s experience was 

investing in financial markets, what his financial goals were, and how much 

Investor A had “set aside to achieve that financial goal.”   

79. In his email in response, Investor A said that he was a beginner in the 

financial market, he had only traded in foreign exchange, he had invested in other 

vehicles that provided a high annual yield, had about $40,000 to invest, and his 

goal was to obtain at least a 20% return on investment.   

80. On August 14, 2020, Onyeachonam, again posing as Representative 

A, emailed Investor A and explained that Representative A traded across three 

major financial markets—the stock, foreign exchange, and digital currency 

markets—to maximize profit generation and that Representative A used a “copy 

trading” tool.   

81. Onyeachonam’s email further claimed that, after downloading and 

installing a list of trading apps, the client would create a trading account which the 

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trader would sync with a copy-trading tool to ensure that the client would be able 

to transparently view trading activity.   

82. This email was identical to one that Onyeachonam sent to other 

potential investors who sought to invest through Representative A. 

83. In August 2020, Onyeachonam, posing as Representative A, emailed 

Investor A a client investment form and a contract agreement.  

84. The client investment form required Investor A to provide contact and 

background information, as well as information about his investing experience, 

financial assets, and investments.   

85. The form claimed: “[Representative A] is a licensed Broker/Financial 

Adviser, regulated and accredited by the Financial Industry Regulatory Authority 

(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative A] is 

therefore operating within the boundaries of [Representative A’s] profession and 

the data you will provide below will be used for only investment purposes.” 

86. The contract agreement further represented that Investor A was 

required to pay a “10% commission fee” and a “one time payment of 5% insurance 

premium to protect your investment against any loss ascribable to market crash or 

fluctuation.”  

87. The contract agreement also promised that “the investment accounts 

would accrue a minimum of 15% profits monthly.” 

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88. Investor A filled out the client investment form, signed the contract 

agreement, and returned both to Onyeachonam through the email address 

Onyeachonam had created and that purported to be Representative A’s email 

address. 

89. In August 2020, Onyeachonam, posing as Representative A, 

instructed Investor A to download and sign up for accounts at an SEC-registered 

broker-dealer, a platform for trading currency, and two crypto asset trading 

platforms and to set up a call so that Representative A could sync Investor A’s  

accounts with Representative A’s copy trading tool and discuss funding and 

investments.   

90. On August 23, 2020, Onyeachonam, posing as Representative A, 

initiated a WhatsApp text conversation with Investor A.   

91. Onyeachonam, posing as Representative A, and Investor A thereafter 

communicated primarily through WhatsApp messages.3 

92. On August 26, 2020, Onyeachonam, posing as Representative A, 

messaged Investor A through WhatsApp and claimed that, to maximize profit 

realization, Investor A’s capital would be split between the stock market and 

crypto asset market at a “11:89 ratio” for the first three weeks of trading due to the 

bullish state of the crypto asset market.   

 
3 WhatsApp is an encrypted messaging service. 

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93. On August 26, 2020, Onyeachonam, posing as Representative A, 

instructed Investor A to make an initial deposit of $1,200 in Investor A’s newly-

opened (genuine) brokerage account and $8,800 in Investor A’s crypto asset 

account, to use the funds in the crypto asset account to purchase bitcoin, and to 

transfer the bitcoin to an address Investor A had set up at a crypto-asset trading 

platform pursuant to Onyeachonam’s instructions.   

94. In September 2020, following the instructions of Onyeachonam 

posing as Representative A, Investor A purchased bitcoin in his crypto asset 

account and transferred approximately $10,108.92 to an address Investor A had set 

up at a crypto-asset trading platform.   

95. Investor A then told Onyeachonam, whom Investor A understood to 

be Representative A, that Investor A had sent the bitcoin to his address at a crypto-

asset trading platform.  

96. Onyeachonam, posing as Representative A, responded that she would 

start trading as soon as possible.   

97. After transferring the initial investment, Investor A asked whether 

Representative A would be trading the funds in Investor A’s (genuine) brokerage 

account, and Onyeachonam, posing as Representative A, replied affirmatively.   

98. Onyeachonam, posing as Representative A, then emailed Investor A 

that his funds had been “uploaded to [Representative A’s] copy trading system”—

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the CopyTradeApp Onyeachonam had created, where Investor A could see his 

purported investment returns—and provided a link and login credentials to 

LumenTrades.com, the fake investment account platform Onyeachonam had also 

created.  

99. The LumenTrades.com website displayed Investor A’s investment and 

the purported trading returns, which appeared to be substantial. 

100. After Onyeachonam secured Investor A’s initial investment and 

Investor A saw the significant fictitious profits that Representative A was 

purportedly generating, Onyeachonam, posing as Representative A, succeeded in 

getting Investor A to transfer an additional $518,923.07, including funds gathered 

from friends and a loan from a financial institution, in purported investment funds 

over the next four months. 

101. Onyeachonam, posing as Representative A, used various techniques to 

extract additional funds from Investor A in addition to the fake returns on 

LumenTrades: Onyeachonam (1) promoted new trading strategies that required 

additional funds to garner high returns; (2) repeatedly reminded Investor A that the 

crypto asset market was doing well; (3) touted Representative A’s expertise, 

service, and trading success; and (4) encouraged Investor A to shift assets away 

from another investment adviser.   

102. By the end of December 2020, the LumenTrades.com website showed 

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that Investor A’s $518,299 net investment (after purported transaction fees) had 

purportedly earned $1,893,378 in net trading profits—a purported return of more 

than 250% in approximately four months. 

103. Those earnings were fake, as Defendants had never actually invested 

Investor A’s money as promised but had instead misappropriated it. 

D. Onyeachonam Gave Investor A the Runaround When He 
Attempted to Withdraw Funds. 

 
104. By late December 2020, Investor A’s bitcoin had been moved from 

Investor A’s crypto-asset trading platform address through several other addresses, 

and Defendants had thereby stolen the bitcoin.     

105. On December 29, 2020, Investor A instructed Representative A (in 

reality, Onyeachonam) to withdraw his entire portfolio on January 1, 2021, and 

asked for withdrawal instructions, because he needed to pay back the individuals 

who had given Investor A money to invest.   

106. The same day, Onyeachonam, posing as Representative A, responded, 

“Got it, [Investor A].” 

107. Between December 29, 2020, and January 2, 2021, Investor A 

repeatedly messaged Representative A (in reality, Onyeachonam) on WhatsApp 

regarding Investor A’s funds.   

108. On January 2, 2021, Investor A stated, “[Representative A] I haven’t 

heard back from you, I don’t know where you are but please respond ASAP.  I 

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need to move out the funds.  I’m already late and they expected it Jan 1[.]” 

109. On January 3, 2021, Onyeachonam, posing as Representative A, 

finally responded, “Hi [Investor A], Happy new year[.] I’m here.” 

110. On January 3, 2021, Investor A and Onyeachonam, posing as 

Representative A, messaged back and forth for approximately an hour.  Investor A 

reiterated that he needed to withdraw his funds, and Onyeachonam, posing as 

Representative A, responded, “I will start processing it tomorrow.” 

111. When Investor A asked how many days it would take, Onyeachonam, 

posing as Representative A, responded, “3 business days.” 

112. Investor A and Onyeachonam, posing as Representative A, then 

turned their messages to the crypto market and the price of bitcoin.   

113. Onyeachonam, posing as Representative A, reminded Investor A of 

Representative A’s prediction that the price of bitcoin would “hit at least 25k 

before the last days of 2020,” and Investor A responded, “You were right.” 

114. On January 6, 2021, Investor A asked Onyeachonam, posing as 

Representative A, whether the withdrawal had been processed. 

115. On January 7, 2021, Onyeachonam, posing as Representative A, 

responded, “[Y]our funds are now available for withdrawal.  Go to the investment 

page at Lumentrades and click withdraw.” 

116. Later the same day, Investor A asked how long it would take for the 

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funds to go from LumenTrades to Investor A’s address once Investor A hit the 

withdraw button.   

117. Onyeachonam, posing as Representative A, responded, “By the end of 

business day.” 

118. On January 8, 2021, Investor A messaged Representative A (in 

reality, Onyeachonam) stating that Investor A had not received his funds and that 

the LumenTrades website was down. 

119. That day, Onyeachonam, posing as Representative A, responded, 

“You just placed a withdrawal yesterday, it will take 3 business days to complete,” 

“I just saw that their site is down for maintenance,” and “[t]hey will process your 

withdrawal.” 

120. Investor A reminded Representative A (in reality, Onyeachonam), 

“Oh you told me by the end of the business day.”   

121. Onyeachonam did not respond to that message. 

122. On January 11, 2021, Onyeachonam, posing as Representative A, 

messaged Investor A that “Lumentrades is working on some features[;] that’s why 

there is a little delay in withdrawal.” 

123. Investor A responded, “Ok thank you so much,” and asked how long 

Representative A thought it would take.   

124. Onyeachonam did not respond. 

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125. The same day, Investor A informed Representative A (in reality, 

Onyeachonam) that several people were upset with him, he was worried and 

anxious, his life would be destroyed, and his family and friends were close to 

killing him because he had not returned their money.   

126. Onyeachonam, posing as Representative A, responded that Investor A 

would receive his funds soon and everything was going well.   

127. Later the same day, Onyeachonam, posing as Representative A, told 

Investor A that his funds would be available two days later—by Wednesday, 

January 13, 2021. 

128. On January 13, 2021, Investor A did not receive his funds.   

129. Investor A messaged Representative A (in reality, Onyeachonam) 

regarding withdrawal. 

130. On January 14, 2021, Onyeachonam, posing as Representative A, told 

Investor A that LumenTrades is on it, “[t]hey are updating their services,” and that 

Investor A’s funds would be available the next day. 

131. On or around January 18, 2021, someone purporting to be from 

LumenTrades contacted Investor A and told him to pay additional money to 

receive a bonus.  

132. On January 18, 2021, Investor A informed Representative A (in 

reality, Onyeachonam) about the LumenTrades call and said that he did not have 

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any more money and was “drained” and “basically bankrupt.”   

133. Onyeachonam, posing as Representative A, responded, “[P]lease 

follow the instruction on Lumentrades[.] . . . I did my best for you and you don’t 

want to follow simple instruction[ ] to withdraw your funds[?]”   

134. Investor A replied, “Lumentrades has no location, no real phone 

number, it’s not a real exchange anywhere.  They got my name spelled wrong in 

most of their emails . . . it’s not legitimate.” 

135. On January 18, 2021, in Investor A’s final WhatsApp message to 

Onyeachonam, Investor A stated, “Be honest with me.  I figured it out by now that 

you are not who you pose to be on the website.”   

136. Investor A then posed one final question: “How do you sleep at night 

knowing you’re destroying the lives of people who trust you[?]” 

137. Investor A received no response to his message.  

138. Nor did Investor A ever receive any funds or other assets back from 

Defendants. 

139. Between August and December 2022, Defendants stole $529,031.99 

from Investor A. 

  

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III. ONYEACHONAM AND ASIEGBU IMPERSONATED A FORMER 
REGISTERED REPRESENTATIVE FROM TEXAS, AND 
DEFENDANTS STOLE MORE THAN $55,000 FROM AN ARIZONA 
INVESTOR. 

 
A. Onyeachonam and Asiegbu Impersonated a Former Texas 

Representative Online.  
 

140. In April 2020, an unknown individual or individuals set up a website 

impersonating a former Texas-based broker-dealer and investment adviser 

Representative (“Representative B”) previously employed by a large, dually 

registered broker-dealer and investment adviser firm that was a household name.   

141. By 2020, Representative B had had 36 years of experience as a 

broker-dealer representative and/or investment adviser representative during his 

career. 

142. In April 2020, an unknown individual or individuals registered a 

domain name with Representative B’s actual first and last names.  

143. An unknown individual or individuals also created a website on that 

domain that advertised Representative B’s financial services. 

144. The website displayed the real credentials and employment history of 

Representative B and linked to Representative B’s actual FINRA BrokerCheck 

website page.   

145. The phony website also listed an email address with Representative 

B’s name as a contact method.    

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146. As early as May 2020, email account information indicates that 

Asiegbu and Onyeachonam controlled that email address, which was used to 

communicate with their investor victims. 

147. Additionally, Asiegbu maintained a Google Search Console account, a 

tool that helps website owners and developers understand how their site appears in 

Google Search results, for the phony website. 

148. In February 2021, Onyeachonam and/or Asiegbu purchased via an 

email address attributable to both of them a SSL certificate, a digital file that 

verifies a website’s identity and encrypts communication between a web browser 

and a web server, for the phony website.  

149. In June 2021, Onyeachonam registered an LLC in the name of 

Representative B in the state of Delaware. 

B. Nweke-Eze Promoted Representative B Online.  

150. Starting in at least July 2020, an email address attributable to Nweke-

Eze used fake identities to promote Representative B’s trading and investment 

services in comments to YouTube videos. 

151. The comments took the form of a fictitious online conversation 

between strangers, one mentioning their investment success with Representative B 

and the other following up with questions about Representative B, concluding with 

an instruction from the purported Representative B client to look Representative B 

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up on the Internet and call, email, or send a message. 

152. The fictitious YouTube comments were scripted, and in emails sent to 

himself and others potentially involved in the fraud, Nweke-Eze emailed similar 

scripts used for another representative Defendants impersonated. 

C. An Arizona Investor Found Representative B Online  
and Invested More Than $55,000. 

153. An investor who at all relevant times has resided in Arizona 

(“Investor B”) learned about Representative B through comments made on 

YouTube touting Representative B’s services.   

154. Investor B then found Representative B’s fake website, controlled by 

Asiegbu, and emailed Representative B in August 2020 using the email address 

listed on the fake website.   

155. Investor B noted in his email that he had “heard good reviews about 

the services you provided to others.” 

156. On August 11, 2020, Onyeachonam and/or Asiegbu, posing as 

Representative B, sent an introductory email—purportedly from Representative B 

but actually from an email address attributable to Onyeachonam and Asiegbu—to 

Investor B asking where Investor B was located, what Investor B’s experience was 

investing in financial markets, what his financial goals were, and how much 

Investor B had “set aside to achieve that financial goal.”   

157. In response, Investor B said that he was a beginner in the financial 

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market, he had made some trades and investments that had turned out poorly, he 

had about $130,000 in savings but did not want to invest all of it, and his goal was 

to earn enough to buy a property or invest in a business. 

158. On August 13, 2020, Onyeachonam and/or Asiegbu, again posing as 

Representative B, emailed Investor B and claimed that Representative B traded 

across three major financial markets—the stock, foreign exchange, and digital 

currency markets—to maximize profit generation and that Representative B used a 

“copy-trading” tool. 

159. The email from Onyeachonam and/or Asiegbu further claimed that, 

after downloading and installing a list of trading apps, the client would create a 

trading account which the trader would sync with a copy-trading tool to ensure that 

the client would be able to transparently view trading activity.  

160. In August 2020, Onyeachonam and/or Asiegbu, posing as 

Representative B, emailed Investor B a client investment form and a contract 

agreement.  

161. Both the client investment form and the contract agreement included 

seals for the SEC and FINRA BrokerCheck. 

162. The client investment form required Investor B to provide contact and 

background information, as well as information about his investing experience, 

financial assets, and investments.  

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163. The form claimed: “[Representative B] is a licensed Broker/Financial 

Adviser, regulated and accredited by the Financial Industry Regulatory Authority 

(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative B] is 

therefore operating within the boundaries of [Representative B’s] profession and 

the data you will provide below will be used for only investment purposes.”  

164. The contract agreement further represented that Investor B was 

required to pay a “10% commission fee” and a “one time payment of insurance 

premium to protect your investment against any loss ascribable to market crash or 

fluctuation.” 

165. The contract agreement also promised that “the investment accounts 

would accrue a minimum of 15% profits monthly.”  

166. Investor B filled out the client investment form, signed the contract 

agreement, and returned both to Onyeachonam and/or Asiegbu through the email 

address they controlled that purported to be Representative B’s address. 

167. In August 2020, Onyeachonam and/or Asiegbu, again posing as 

Representative B, instructed Investor B via email to download and sign up for 

accounts at two SEC-registered broker-dealers, a platform for trading currency, 

and two crypto asset trading platforms, and to set up a call so that Representative B 

could sync Investor B’s accounts with Representative B’s copy trading tool and 

discuss funding and investments. 

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168. In September 2020, Onyeachonam and/or Asiegbu, posing as 

Representative B, emailed Investor B a strategy document regarding a “bitcoin 

pump opportunity.” 

169. An email address Onyeachonam and Asiegbu controlled contained a 

Google Drive file with a similar document, dated March 24, 2021, with identical 

letterhead and Representative B’s fake contact information. 

170. On September 1, 2020, Onyeachonam and/or Asiegbu, posing as 

Representative B, emailed Investor B and claimed that, to maximize profit 

realization, Investor B’s capital would be split between the stock market and crypto 

asset market at a “19:81 ratio” for the first three weeks of trading due to the bullish 

state of the crypto asset market.  

171. Representative B instructed Investor B to make an initial deposit of 

$5,700 in Investor B’s newly-opened (genuine) brokerage account and $24,300 in 

Investor B’s crypto asset account. 

172. On September 14, 2020, Onyeachonam, posing as Representative B, 

initiated a WhatsApp text conversation with Investor B. 

173. Onyeachonam, posing as Representative B, and Investor B thereafter 

communicated primarily through WhatsApp messages. 

174. In September 2020, following the instructions from Onyeachonam, 

posing as Representative B, Investor B purchased bitcoin in his crypto asset 

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account and transferred approximately $20,382.97 in bitcoin to an address Investor 

B had set up at a crypto-asset trading platform.   

175. Investor B was unable to set up the (genuine) brokerage account 

Onyeachonam, posing as Representative B, had instructed him to set up because 

Investor B needed additional documentation. 

176. Onyeachonam and/or Asiegbu, posing as Representative B, then 

emailed Investor B that his funds had been “uploaded to [Representative B’s] copy 

trading system”—the CopyTradeApp Onyeachonam had created, where Investor B 

could see his purported investment returns—and provided a link and login 

credentials to LumenTrades.com, the fake investment account platform 

Onyeachonam had also created. 

177. The LumenTrades.com website displayed Investor B’s investment and 

the purported trading returns from Representative B. 

178. After Onyeachonam and/or Asiegbu secured Investor B’s initial 

investment and Investor B saw the significant fictitious profits that Representative 

B was purportedly generating, Onyeachonam and/or Asiegbu, posing as 

Representative B, succeeded in getting Investor B to transfer an additional 

$37,811.92. 

179. Onyeachonam and/or Asiegbu, posing as Representative B, used 

various techniques to extract additional funds from Investor B in addition to the 

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fake returns on LumenTrades:  Onyeachonam and/or Asiegbu (1) promoted new 

trading strategies, which they informed Investor B required additional funds to 

garner high returns; (2) repeatedly reminded Investor B that the crypto asset 

market was doing well; (3) touted Representative B’s expertise, service, and 

trading success; and (4) reminded Investor B of his financial goals (buying real 

property). 

180. Defendants never invested Investor B’s money as promised but 

instead misappropriated it. 

D. Onyeachonam Gave Investor B the Runaround When He 
Attempted to Withdraw Funds. 

 
181. By October 27, 2020, Investor B’s bitcoin had been moved from 

Investor B’s crypto-asset trading platform address through several addresses, and 

Defendants thereby stole it. 

182. Starting on November 29, 2020, Investor B informed Representative 

B (in reality, Onyeachonam) via WhatsApp that he wanted to withdraw $30,000 

and asked how to make a withdrawal. 

183. Onyeachonam, posing as Representative B, messaged Investor B and 

asked when he planned to make the withdrawal.   

184. Investor B responded, “In the next week or two, if possible.  I got 

pretty sick and racked up some medical bills.”   

185. Representative B (in reality, Onyeachonam) replied, “Okay.  Let me 

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know when you’re ready.”  

186. On December 5, 2020, Investor B messaged the person he thought 

was Representative B:  “I tried making a withdrawal from the lumentrades 

[website] and it wasn’t working for me.  What’s the best route to go to get some 

[of] that profit out.”   

187. Onyeachonam, posing as Representative B, responded, “I will contact 

them and have it processed soon.”  

188. Between December 6, 2020, and December 21, 2020, Investor B 

repeatedly messaged Representative B (in reality, Onyeachonam) on WhatsApp 

regarding withdrawing Investor B’s funds.   

189. At various times in December 2020, Onyeachonam, posing as 

Representative B, told Investor B, “I’m trying to close some position[s] so I can 

process your withdrawal;” “You can withdraw it from Lumentrades but I still hold 

some positions that I need to liquidate.  By Monday your funds will be available 

for withdrawal;” “You will be able [] to withdraw today.  The funds are available;” 

and “go ahead and withdraw from your account at Lumentrades.”   

190. Investor B was never able to withdraw any of his funds from 

LumenTrades. 

191. On January 2, 2021, Investor B messaged Representative B, “Whats 

the deal with withdrawals.  Submitted it the 21st and its still pending.”   

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192. Onyeachonam, posing as Representative B, replied, “I will contact 

them and get back to you.”  

193. On January 4, 2021, the purported “Lumentrades Billing Team” 

emailed Investor B from an email address created and controlled by Onyeachonam, 

“We sincerely apologise [sic] for the delay in withdrawal.  We are updating our 

terms and functionalities.  Your funds will be available tomorrow.” 

194. On January 15, 2021, the same email address emailed Investor B 

writing, “We have fully updated our terms and functionalities.  You can now 

withdraw your investment and have it available in your account today.” 

195. Investor B never received any funds or other assets back from 

Defendants. 

196. Between September and October 2020, Defendants stole $58,194,89 

from Investor B. 

IV.  DEFENDANTS IMPERSONATED A REGISTERED 
REPRESENTATIVE FROM MINNESOTA AND STOLE MORE 
THAN $105,000 FROM A CALIFORNIA INVESTOR. 

   
A. Asiegbu and Nweke-Eze Impersonated a Minnesota 

Representative Online.  

197. In October 2020, an unknown individual or individuals set up a 

website impersonating a Minnesota-based broker-dealer and investment adviser 

Representative (“Representative C”) employed by a large, dually registered broker-

dealer and investment adviser firm that was a household name.  

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198. In 2020, Representative C had 13 years of experience as a broker-

dealer representative and/or investment adviser representative. 

199. In October 2020, an unknown individual or individuals registered a 

domain name with Representative C’s actual first and last names. 

200. An unknown individual or individuals created a website on that 

domain that advertised Representative C’s financial services. 

201. The website displayed the real credentials and employment history of 

Representative C and linked to Representative C’s actual FINRA BrokerCheck 

website page. 

202. The phony website also listed an email address with Representative 

C’s name as a contact method. 

203. That email address, used to communicate with Defendants’ investor 

victims, was controlled by Asiegbu starting in at least November 2020 and by 

Nweke-Eze starting in at least June 2021. 

204. Starting at least the day after the phony website’s domain name was 

registered, Asiegbu controlled the website.  For example, he set up and maintained 

through at least September 2021 a webhosting account for the domain—a service 

that stores and maintains a website's files and applications on a server so that it can 

be accessed on the internet.  Webhosts are responsible for the technical aspects of a 

website's operation, including keeping the server running, implementing security 

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measures, and ensuring that files are transferred to visitors’ browsers. 

205. In June 2021, Onyeachonam registered an LLC in the name of 

Representative C in the state of Delaware. 

B. Nweke-Eze Promoted Representative C Online.  

206. Nweke-Eze promoted Representative C using YouTube, which 

directed potential investors to research Representative C. 

207. Starting in at least November 2020, an email address attributable to 

Nweke-Eze used fake identities to promote Representative C’s trading and 

investment services in comments to YouTube videos. 

208. The comments took the form of a fictitious online conversation 

between strangers, one mentioning their investment success with Representative C 

and the other following up with questions about Representative C, concluding with 

an instruction from the purported Representative C client to look Representative C 

up on the Internet and call, email, or send a message.   

209. The fictitious YouTube comments were scripted, and in emails sent to 

himself and others, Nweke-Eze emailed similar scripts used for another 

representative Defendants impersonated. 

C. A California Investor Found Representative C Online  
and Invested More Than $105,000. 

210. An investor who at all relevant times has resided in California 

(“Investor C”) learned about Representative C through comments made on 

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YouTube touting Representative C’s services. 

211. Investor C then found Representative C’s fake website, which 

Asiegbu controlled, and sent Representative C a message in June 2021 using the 

form on the website. 

212. On June 23, 2021, Asiegbu and/or Nweke-Eze sent an introductory 

email—purportedly from Representative C but actually from an email address 

attributable to Asiegbu and Nweke-Eze—to Investor C asking where Investor C 

was located, what Investor C’s experience was investing in financial markets, what 

her financial goals were, and how much Investor C had “set aside to achieve that 

financial goal.”  Asiegbu and/or Nweke-Eze used the email address they controlled 

that purported to be Representative C’s address. 

213. In response, Investor C said that she was a beginner in the financial 

market, she was interested in a balanced portfolio that provided monthly cashflow 

as well as long term growth, and she had $30,000 to invest and would like to 

increase the amount over time. 

214. On June 28, 2021, Asiegbu and/or Nweke-Eze, again posing as 

Representative C, emailed Investor C and claimed that Representative C traded 

across three major financial markets—the stock, foreign exchange, and digital 

currency markets—to maximize profit generation and that Representative C used a 

“copy trading” tool.   

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215. The email further claimed that, after downloading and installing a list 

of trading apps, the client would create a trading account which the trader would 

sync with a copy-trading tool to ensure that the client would be able to 

transparently view trading activity. 

216. Attached to the email was a document titled, “Portfolio Management 

Business Model.”   

217. The Portfolio Management Business Model included the seals for the 

SEC and FINRA BrokerCheck. 

218. The Portfolio Management Business Model claimed, “[Representative 

C] is a licensed and regulated broker/portfolio manager with over 20 years of 

experience working with notable financial/investment firms in the United States.”   

219. The document also claimed that Representative C “guaranteed [a] 

monthly capital gain of 15-25%” and charged a 5-10% “performance fee or trade 

commission” and a 5% “insurance premium” to “insure investor’s funds against 

losses.” 

220. In July 2021, Asiegbu and/or Nweke-Eze, posing as Representative C, 

emailed Investor C a client investment form and a contract agreement.  

221. Both the client investment form and contract agreement included the 

seals for the SEC and FINRA BrokerCheck. 

222. The client investment form was identical to one that an email address 

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associated with Onyeachonam and Asiegbu had emailed to 

[email protected] three months earlier, on March 24, 2021. 

223. The client investment form required Investor C to provide contact and 

background information, as well as information about her investing experience, 

financial assets, and investments. 

224. The form claimed: “[Representative C] is a licensed Broker/Financial 

Adviser, regulated and accredited by the Financial Industry Regulatory Authority 

(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative C] is 

therefore operating within the boundaries of [Representative C’s] profession and 

the data you will provide below will be used for only investment purposes.” 

225. The contract agreement further represented that Investor C was 

required to pay a “5% commission fee” and a “one-time payment of insurance 

premium to protect your investment against any loss ascribable to market crash or 

fluctuation.” 

226. The contract agreement also promised that “the investment accounts 

would accrue a minimum of 15% profits monthly.” 

227. Investor C filled out the client investment form, signed the contract 

agreement, and returned both to Asiegbu and/or Nweke-Eze through the email 

address that they controlled and that purported to be Representative C’s email 

address. 

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228. In July 2021, Asiegbu and/or Nweke-Eze, posing as Representative C, 

instructed Investor C to download and sign up for accounts at two SEC-registered 

broker-dealers, a platform for trading currency, and two crypto asset trading 

platforms and to set up a call so that Representative C could sync Investor C’s 

accounts with Representative C’s copy trading tool and discuss funding and 

investments. 

229. On July 8, 2021, Onyeachonam, posing as Representative C, initiated 

a WhatsApp text conversation with Investor C. 

230. Representative C and Investor C thereafter communicated primarily 

through WhatsApp messages. 

231. On July 19, 2021, Asiegbu and/or Nweke-Eze, posing as 

Representative C, emailed Investor C and claimed that, to maximize profit 

realization, Investor C’s capital would be split between the stock market and crypto 

asset market at a “10:90 ratio” for the first three weeks of trading due to the bullish 

state of the crypto asset market.  

232. Representative C (in reality, Asiegbu and/or Nweke-Eze) instructed 

Investor C to make an initial deposit of $2,000 in Investor C’s newly-opened 

(genuine) brokerage account and $18,000 in Investor C’s crypto asset account. 

233. In July 2021, following these instructions, Investor C purchased 

bitcoin in her crypto asset account and transferred $19,005.17 in bitcoin to an 

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address Investor C had set up at a crypto-asset trading platform.  

234. Investor C also deposited $2,000 into her (genuine) brokerage 

account. 

235. On July 24, 2021, Onyeachonam, posing as Representative C, 

messaged Investor C claiming that Representative C would “start trading in your 

account today.” 

236. Asiegbu and/or Nweke-Eze, posing as Representative C, then emailed 

Investor C that her funds had been “uploaded to [Representative C’s] copy trading 

system”—the CopyTradeApp Onyeachonam had created, where Investor C could 

see his purported investment returns—and provided a link and login credentials to 

LumenTrades.com, the fake investment account platform Onyeachonam had also 

created. 

237. The LumenTrades.com website displayed Investor C’s investment and 

the purported trading returns from Representative C, which appeared to be 

substantial. 

238. Onyeachonam, posing as Representative C, and Investor C arranged a 

call via WhatsApp for August 19, 2021, at 9 a.m. Pacific Time to discuss a “new 

strategy” for investment. 

239. Indeed, Onyeachonam’s scheduling app listed a call on August 19, 

2021, at 9 a.m. Pacific Time and described “Chibuzo [Onyeachonam]’s task” as to 

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“Call [Investor C’s first name] • [Representative C’s first name] Project.” 

240. After Defendants secured Investor C’s initial investment and Investor 

C saw the significant fictitious profits that Representative C was purportedly 

generating, Defendants, posing as Representative C, succeeded in getting Investor 

C to transfer an additional $82,011.90 in purported investment funds over the next 

five months. 

241. Defendants, posing as Representative C, used various techniques to 

extract additional funds from Investor C in addition to the fake returns on 

LumenTrades: Defendants (1) promoted new trading strategies that required 

additional funds to garner high returns; and (2) promised Investor C that, if she 

invested additional funds, she would be able to take monthly withdrawals without 

affecting the trading strategy. 

242. Defendants never invested Investor C’s money as promised but 

instead misappropriated it.  

243. On December 2, 2021, Investor C asked Representative C for an 

“alternate contact” in case Investor C was unable to get a hold of Representative C.   

244. Onyeachonam, posing as Representative C, responded that the firm 

would have its assistant “Susan” reach out. 

245. On December 3, 2021, someone posing as “Susan Olsen,” a fictitious 

individual with a LumenTrades.com email address, reached out to Investor C, 

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stating “You can reach out to me whenever you have any questions or difficulty 

with your account.” 

246. The same day, an email address attributable to Onyeachonam received 

identical draft correspondence from “Susan Olsen.” 

247. Investor C and Onyeachonam, posing as Representative C, discussed 

investing in the stock market.   

248. On December 15, 2021, Onyeachonam, posing as Representative C, 

messaged Investor C, “I will start trading the funds [in Investor C’s genuine 

brokerage account] as soon as possible.”   

249. Investor C responded, “awesome thanks for confirming.”  

250. Defendants never traded the funds in Investor C’s genuine brokerage 

account. 

D. Onyeachonam Gave Investor C the Runaround and Charged 
Additional Fees When She Attempted to Withdraw Funds. 

 
251. By March 1, 2022, Investor C’s bitcoin had been moved from Investor 

C’s crypto-asset trading platform address through several addresses, and 

Defendants had stolen the bitcoin. 

252. On March 1, 2022, Investor C messaged Representative C, “How do I 

withdraw my monthly gain?”  

253. Representative C did not respond.   

254. Investor C messaged Representative C several times throughout 

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March 2022, noted that her emails to Representative C were “getting bounced,” 

and yet did not receive a response. 

255. On June 29, 2022, Onyeachonam, posing as Representative C, 

messaged Investor C, claiming that Representative C had been sick the last few 

months and therefore had not responded to any of Investor C’s messages.  

256. Later in the conversation, Onyeachonam claimed that Investor C 

“needed to buy ethereum to pay the processing fee,” and after doing so “[Investor 

C’s] funds will be available to [withdraw].”   

257. Investor C responded, “[A]re you sure they will release funds after I 

give processing fees?”   

258. Representative C replied, “Yes, that’s how it work[s].” 

259. Following instructions from Onyeachonam, posing as Representative 

C, Investor C used funds in her crypto asset account to purchase ethereum and 

transferred $2,222.16 in ethereum to an address displayed for Investor C on 

Secawallet.com, which Onyeachonam set up, controlled, and operated.  

260. Indeed, the address displayed for Investor C on Secawallet.com 

appeared several times in Onyeachonam’s emails. 

261. The next day, June 30, 2022, Investor C reported to Representative C 

that LumenTrades was now stating she needed to pay an advisory fee of 

approximately $8,000 to “unlock [her] funds.”   

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262. Onyeachonam, posing as Representative C, told Investor C that “It’s 

included in the contract.”   

263. Investor C responded, “in any case I don’t have that kind of funds 

right now.…” 

264. On September 16, 2022, Investor C asked Representative C, “Is there 

any other fees after [the processing fees already paid] and your fees?”  

265. Onyeachonam, posing as Representative C, responded, “Hi [Investor 

C], there is no other fees….  Once the pending payment is cleared, your funds will 

be automatically available.” 

266. On September 16, 2022, Investor C used funds in her crypto asset 

account to purchase ethereum and transferred $3,161.31 in ethereum to the same 

Secawallet.com address for Investor C previously described in paragraph 259 

above. 

267. On September 19, 2022, Onyeachonam, posing as Representative C, 

messaged Investor C, “[T]he payment has been confirmed.  You can login to 

secawallet to withdraw your funds.”  

268. Investor C was still unable to withdraw her funds, and on September 

26, 2022, Investor C messaged Representative C, “[Lumentrades] support is saying 

it’s stuck because there is [not] enough processing fees.  Did you know about it?” 

269. The next day, Onyeachonam, posing as Representative C, responded, 

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“[P]lease follow the instruction from Lumentrades.  I can’t change anything at this 

point.” 

270. On September 29, 2022, Investor C received an email from 

[email protected] informing Investor C that Secawallet had “started 

processing [Investor C’s] stuck transaction.”  

271. On September 30, 2022, Investor C messaged Representative C, “I am 

worried and stressed.”   

272. Onyeachonam, posing as Representative C, responded, “I’m sorry 

about the stress.  Everything should be settled today.”  

273. Investor C received no further communications from Representative 

C. 

274. Investor C continued communicating with [email protected] 

between September 2022 and February 2023.   

275. During that period, Onyeachonam, posing as a support representative 

from Secawallet, instructed Investor C to provide certain documents to complete 

an “identity verification” process, citing “many unusual activities on your 

account.”   

276. Investor C complied by providing [email protected] with 

scans of Investor C’s driver’s license, utility bill, and United States passport.  

277. On October 14, 2022, Onyeachonam, posing as a support 

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representative with Secawallet, emailed Investor C, “For security reasons, we 

won’t be able to release the funds to the provided [crypto] address.”   

278. The purported support representative with Secawallet (in reality, 

Onyeachonam) directed Investor C to purchase a hardware wallet, a physical 

device that stores crypto assets offline, from shop.secawallet.com and told Investor 

C that this hardware wallet would be mailed to her physical address.   

279. Two days later, Investor C responded, “Kindly please release the 

funds, this looks more like a scam to me now.”  

280. On November 7, 2022, Onyeachonam, posing as a support 

representative with Secawallet, emailed Investor C a formal invoice for the 

hardware wallet that listed its price as $899.99. 

281. Investor C continued exchanging emails regarding the hardware 

wallet with Onyeachonam, while he was posing as a support representative with 

Secawallet, until February 22, 2023.   

282. On that date, Onyeachonam, still posing as the Secawallet support 

representative, sent Investor C an email stating, “Once we receive your payment, 

your hardware wallet will be shipped to your location.”  

283. Investor C received no further communications from 

[email protected].  

284. Nor did Investor C ever receive any funds or other assets back from 

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Defendants. 

285. Between July 2021 and September 2022, Defendants stole $106,400 

from Investor C. 

V. ONYEACHONAM AND ASIEGBU IMPERSONATED A 
REGISTERED REPRESENTATIVE FROM CALIFORNIA AND 
STOLE MORE THAN $45,000 FROM A NEW JERSEY INVESTOR. 

 
A. Onyeachonam and Asiegbu Impersonated a California 

Representative Online.  
 

286. In October 2020, an unknown individual or individuals set up a 

website impersonating a California-based broker-dealer and investment adviser 

representative (“Representative D”) employed by a large, dually registered broker-

dealer and investment adviser firm that was a household name. 

287. In 2020, Representative D had 22 years of experience as a broker-

dealer representative and/or investment adviser representative. 

288. In October 2020, an unknown individual or individuals registered a 

domain name with Representative D’s actual first and last names. 

289. An unknown individual or individuals then created a website on that 

domain that advertised Representative D’s financial services.  

290. Asiegbu controlled the phony website starting in at least October 

2020, and Onyeachonam controlled it starting in at least August 2021.  For 

example, Asiegbu maintained hosting accounts for the phony website, and 

Onyeachonam maintained an account at an email delivery service that allowed 

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email messages to be generated from the phony website. 

291. The phony website displayed the real credentials and employment 

history of Representative D and linked to Representative D’s actual FINRA 

BrokerCheck website page. 

292. The phony website also listed an email address with Representative 

D’s name as a contact method. 

293. That email address, used to communicate with investor victims, was 

controlled by Asiegbu since at least March 2021 and by Onyeachonam since at 

least April 2022. 

294. In June 2021, Onyeachonam registered an LLC in the name of 

Representative D in the state of Delaware. 

B. Onyeachonam and Asiegbu Promoted Representative D Online.  

295. As of March 2022, an email address attributable to Onyeachonam and 

Asiegbu used fake identities to promote Representative D’s trading and investment 

services in comments to YouTube videos. 

296. The comments took the form of a fictitious online conversation 

between strangers, one mentioning their investment success with Representative D 

and the other following up with questions about Representative D, concluding with 

an instruction from the purported Representative D client to look Representative D 

up on the Internet and call, email, or send a message. 

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297. The fictitious YouTube comments were scripted, and in emails 

between and among themselves and others, Onyeachonam and Asiegbu emailed 

similar scripts used for another representative Defendants impersonated. 

C. A New Jersey Investor Found Representative D Online  
and Invested More Than $45,000. 

298. An investor who at all relevant times has resided in New Jersey 

(“Investor D”) learned about Representative D through comments made on 

YouTube touting Representative D’s services.   

299. Investor D then found Representative D’s fake website (in reality, 

controlled by Asiegbu and Onyeachonam) and sent Representative D a message in 

February 2022 using the form on the website. 

300. On February 9, 2022, Asiegbu and/or Onyeachonam sent an 

introductory email—purportedly from Representative D but actually from Asiegbu 

and/or Onyeachonam—to Investor D asking where Investor D was located, what 

Investor D’s experience was investing in financial markets, what his financial 

goals were, and how much Investor D had “set aside to achieve that financial 

goal.”  

301. To send the email, Asiegbu and/or Onyeachonam used the email 

address they controlled that purported to be Representative D’s address, and   

Representative D’s purported email signature block included the seals for both the 

SEC and FINRA BrokerCheck.  

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302. In response, Investor D said that he had been investing for the last five 

years, had $25,000 to invest, and that his goal was to have steady monthly side 

income. 

303. On February 10, 2022, Asiegbu and/or Onyeachonam, again posing as 

Representative D, emailed Investor D and claimed that Representative D traded 

across three major financial markets—the stock, foreign exchange, and digital 

currency markets—to maximize profit generation and that Representative D used a 

“copy trading” tool. 

304. The email further claimed that, after downloading and installing a list 

of trading apps, the client would create a trading account which the trader would 

sync with a copy-trading tool to ensure that the client would be able to 

transparently view trading activity.  

305. This email was identical to one that Asiegbu and/or Onyeachonam 

sent to other potential investors who sought to invest through Representative D. 

306. In February 2022, Asiegbu and/or Onyeachonam, posing as 

Representative D, emailed Investor D a client investment form and a contract 

agreement.  

307. The client investment form required Investor D to provide contact and 

background information, as well as information about his investing experience, 

financial assets, and investments. 

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308. The form claimed:  “[Representative D] is a licensed Broker/Financial 

Adviser, regulated and accredited by the Financial Industry Regulatory Authority 

(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative D] is 

therefore operating within the boundaries of [Representative D’s] profession and 

the data you will provide below will be used for only investment purposes.” 

309. Investor D filled out the client investment form, signed the contract 

agreement, and returned both to the email address that purported to be 

Representative D’s email address. 

310. In February 2022, Asiegbu and/or Onyeachonam, posing as 

Representative D, instructed Investor D to download and sign up for accounts at 

two SEC-registered broker-dealers, a platform for trading currency, two crypto 

asset trading platforms, and LumenTrades.com and to set up a call so that 

Representative D could sync Investor D’s accounts with Representative D’s copy 

trading tool and discuss funding and investments. 

311. On February 19, 2022, Onyeachonam, posing as Representative D, 

initiated a WhatsApp text conversation with Investor D. 

312. Onyeachonam, posing as Representative D, and Investor D thereafter 

communicated primarily through WhatsApp messages. 

313. On February 24, 2022, Asiegbu and/or Onyeachonam, posing as 

Representative D, emailed Investor D; claimed that, to maximize profit realization, 

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Investor D’s capital would be split between the stock market and crypto asset 

market at a “9:91 ratio” for the first three weeks of trading due to the bullish state 

of the crypto asset market; and instructed Investor D to make an initial deposit of 

$2,250 in Investor D’s newly-opened (genuine) brokerage account and $22,750 in 

Investor D’s crypto asset account.  

314. In February and March 2022, following these instructions, Investor D 

purchased bitcoin in his crypto asset account and transferred $21,539.25 in bitcoin 

to an address Investor D had set up at a crypto-asset trading platform pursuant to 

instructions from Onyeachonam, posing as Representative D.  

315. Investor D also deposited $2,500 into his (genuine) brokerage 

account. 

316. On March 2, 2022, Investor D messaged Representative D (in reality, 

Onyeachonam) and asked, “[W]hat about [the genuine brokerage account]?  I have 

$2,500 [in] it.”   

317. Onyeachonam, posing as Representative D, responded, “Yes, I will 

start trading the accounts at once.”   

318. Onyeachonam and Asiegbu never placed any trades in Investor D’s 

genuine brokerage account. 

319. On March 10, 2022, Onyeachonam, posing as Representative D, 

messaged Investor D, “I’m executing my first trade on your [crypto asset] account 

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today.”  

320. Investor D responded, “Awesome.” 

321. The LumenTrades.com website displayed Investor D’s investment and 

the purported trading returns from Representative D.   

322. On March 19, 2022, Investor D messaged Representative D, “I just 

logged [] into Lumentrades and saw you did trading yesterday and was able to 

make 17% profit in one day!  That is awesome!” 

323. After Onyeachonam secured Investor D’s initial investment and 

Investor D saw the significant fictitious profits that Representative D was 

purportedly generating, Onyeachonam, posing as Representative D, succeeded in 

getting Investor D to transfer an additional $24,954.60 in purported investment 

funds in March 2022. 

324. Onyeachonam and Asiegbu never invested Investor D’s money as 

promised but instead misappropriated it. 

325. On March 28, 2022, Investor D asked Representative D (in reality, 

Onyeachonam) if LumenTrades.com was “legit,” because Investor D had sent an 

email to [email protected] and the email bounced back.   

326. Onyeachonam, posing as Representative D, messaged Investor D, 

“They are doing scheduled maintenance.  That’s the reason for the delay….  Don’t 

be worried, I got you as your investment advisor.  You have to trust me as 

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investment advisor.  I have your best interest at heart.” 

D. Onyeachonam and Asiegbu Gave Investor D the Runaround 
When He Attempted to Withdraw Funds. 

 
327. By the end of March 2022, Investor D’s bitcoin had been moved 

through several addresses, and Onyeachonam and Asiegbu had stolen it. 

328. On March 28, 2022, Investor D asked Representative D (in reality, 

Onyeachonam) how to withdraw funds.   

329. Onyeachonam, posing as Representative D, responded, “Let me know 

when [] you’re ready to make a withdrawal.  I have to close all the open positions 

in your account.  And the funds will be available for withdrawal.” 

330. On March 30, 2022, Investor D messaged Representative D (in 

reality, Onyeachonam), “I would like to withdraw the profit at the end of the day 

tomorrow, Mar 31st.”   

331. Onyeachonam, posing as Representative D, did not respond.   

332. Investor D sent Representative D (in reality, Onyeachonam) many 

messages over the next few days and did not receive a response. 

333. On April 2, 2022, Investor D emailed Representative D (in reality, 

Onyeachonam), “I have tried to reach out on all possible ways.  I don’t understand 

why you don’t reply to my messages?  I’m again getting worried about the 

investment.  I have also bought new home in Dallas and will need some profit we 

make for down payment.” 

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334. Neither Onyeachonam nor Asiegbu, posing as Representative D, 

responded. 

335. On April 6, 2022, Investor D messaged Representative D (in reality 

Onyeachonam), “[P]lease reply to me so that I don’t doubt this to be a Fraud.”  

336. The next day, Onyeachonam, posing as Representative D, responded, 

“Please calm down.  I’m working currently.  I’m not 100% available to chat all the 

time but I will always make out time to communicate with my clients.”  

337. Investor D responded, “I understand you may have lots of clients.  I 

just want you to understand my situation as it changed after we spoke.  I bought a 

house in Dallas and counting on some profit I can take out for down payment.”  

338. Onyeachonam, posing as Representative D responded, “I will make 

the funds available for withdrawal.  How much do you want to withdraw?” 

339. Investor D responded, “[C]urrently it is showing me profit of $6,398.  

I just want to withdraw profit.”  

340. Onyeachonam, posing as Representative D, replied, “If you withdraw 

that amount it will halt my trading strategy but I can proceed to process the 

withdrawal if that’s what you want.”   

341. Investor D asked follow up questions but received no response from 

Representative D. 

342. Investor D messaged Representative D (in reality, Onyeachonam) 

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many times over the next two weeks asking about withdrawing his funds but 

received no response. 

343. On April 21, 2022, Investor D messaged Representative D (in reality, 

Onyeachonam), “[D]on’t make me believe it’s a Fraud.  I also called 

[Representative D’s genuine employer].  I spoke to [another employee] and she 

told me you were just a Sales Associate.”   

344. Onyeachonam, posing as Representative D, replied, “I don’t know 

why you’re being insecure.  I don’t know why you called [Representative D’s 

employer].  You’re working with me independently….” 

345. Investor D responded, “Because you are not replying to me.  I want to 

take out profit as per our agreement.  If I can’t, then I want to just withdraw all my 

investment.”  

346. Onyeachonam, posing as Representative D, messaged back, “Alright, 

the funds will be available tomorrow.” 

347. The next day Investor D was unable to withdraw any money from his 

LumenTrades account, and his messages to Representative D that day and over the 

next six days went unanswered. 

348. On April 29, 2022, Onyeachonam, posing as Representative D, 

messaged Investor D, “I’m trading.  Relax, allow me to do my job.”   

349. Onyeachonam, posing as Representative D, then failed to respond to 

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any of Investor D’s messages between April 29, 2022, and June 28, 2022, when 

Onyeachonam, posing as Representative D, messaged Investor D in part, “Your 

funds are ready,” and instructed Investor D to create an account with 

Secawallet.com, which Onyeachonam set up, controlled, and operated. 

350. After Investor D set up a Secawallet account, he messaged 

Representative D (in reality, Onyeachonam), “[I]t is asking me to send 2 

[ethereum] to someone.  Is that you?”   

351. Onyeachonam, posing as Representative D, responded, “No, [it’s] 

Lumentrades withdrawal processing fee.” 

352. Investor D did not pay the “processing fee.”   

353. On September 7, 2022, Investor D wrote to Representative D, “I don’t 

want to pay anymore fees, you help me with the withdrawal.  Let me know how I 

can withdraw.”   

354. Onyeachonam, posing as Representative D, responded (in his final 

WhatsApp message to Investor D), “[Y]ou need to pay the processing fee.” 

355. Investor D wrote back, “I will pay the fees when [investor D’s money 

was withdrawn to a particular crypto asset platform].  I don’t want to pay fees on 

any other sites.  Please move the funds into [a particular crypto asset platform] and 

let me know when it’s available.”  

356. Investor D received no response to his message. 

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357. Nor did Investor D ever receive any funds or other assets back from 

Onyeachonam and Asiegbu. 

358. Onyeachonam and Asiegbu stole $46,493.95 from Investor D. 

VI. ONYEACHONAM IMPERSONATED A REGISTERED 
REPRESENTATIVE FROM GEORGIA, AND ONYEACHONAM 
AND NWEKE-EZE STOLE MORE THAN $500,000 FROM A 
CALIFORNIA INVESTOR. 

 
A. Onyeachonam Impersonated a Georgia Representative Online.  

 
359. In November 2021, an unknown individual or individuals set up a 

website impersonating a broker-dealer and investment adviser Representative 

based in the State of Georgia (“Representative E”) who was employed by a large, 

dually registered broker-dealer and investment adviser firm that is a household 

name. 

360. In 2021, Representative E had 37 years of experience as a registered 

representative and/or investment adviser representative. 

361. In November 2021, an unknown individual or individuals registered a 

domain name with Representative E’s actual first and last names. 

362. An unknown individual or individuals also created a website on that 

domain that advertised Representative E’s financial services. 

363. The phony website displayed the real credentials and employment 

history of Representative E and linked to Representative E’s actual FINRA 

BrokerCheck website page. 

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364. The phony website listed an email address with Representative E’s 

name as a contact method.  

365. Onyeachonam controlled this email address, used to communicate 

with Defendants’ investor victims, by at least February 2022. 

366. The phony website also touted the legal registration of an LLC in the 

name of Representative E, claiming that Representative E offered financial 

planning services through that LLC. 

367. In June 2021, Onyeachonam registered the LLC listed on the phony 

website in the name of Representative E in the state of Delaware. 

368. Onyeachonam controlled the phony website starting in at least 

January 2022, as alleged in the paragraphs below.   

369. Among other things, Onyeachonam received a test communication 

from the phony website’s cpanel, a web-based interface that allows website owners 

to manage their websites and hosting accounts, in January 2022.   

370. From September to December 2023, Onyeachonam accessed the 

cpanel page for the phony website six times. 

371. Starting by at least September 2023, Onyeachonam maintained an 

account for the phony website with a web analytics tool that helps website owners 

analyze visitor behavior, track traffic, and optimize their websites.   

 

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B. Onyeachonam and Nweke-Eze Promoted Representative E 
Online.   
 

372. Starting in at least June 2022, an email address attributable to Nweke-

Eze used fake identities to promote Representative E’s trading and investment 

services in comments to YouTube videos. 

373. The comments took the form of a fictitious online conversation 

between strangers, one mentioning their investment success with Representative E 

and the other following up with questions about Representative E, concluding with 

an instruction from the purported Representative E client to look Representative E 

up on the Internet and call, email, or send a message.   

374. The fictitious YouTube comments were scripted, and in emails sent to 

himself and others potentially involved in the fraud, Nweke-Eze emailed similar 

scripts used for another representative Defendants impersonated. 

375. An email address attributable to Onyeachonam opened a LinkedIn 

account for Representative E that touted Representative E as a financial advisor at 

the LLC Onyeachonam had registered in Representative E’s name with the state of 

Delaware. 

C. A California Investor Found Representative E Online  
and Invested More Than $500,000. 

376. An investor who at all relevant times has resided in California 

(“Investor E”) found Representative E’s fake website and sent Representative E (in 

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reality, Onyeachonam) a message in December 2022 using the form on the 

website. 

377. On December 5, 2022, Onyeachonam sent an introductory email—

purportedly from Representative E but actually from Onyeachonam—to Investor E 

asking where Investor E was located, what Investor E’s experience was investing 

in financial markets, what his financial goals were, and how much Investor E had 

“set aside to achieve that financial goal.”  

378. Onyeachonam sent the email using the email address that purported to 

be Representative E’s address, and Representative E’s purported email signature 

block included the seals for both the SEC and FINRA BrokerCheck. 

379. In response, Investor E said that he had average knowledge of the 

financial markets, his goal was to increase his net worth to $7-8 million in five 

years, and that he had properties and stocks worth $5.5 million. 

380. On December 7, 2022, Onyeachonam, again posing as Representative 

E, emailed Investor E and claimed that Representative E traded across three major 

financial markets—the stock, foreign exchange, and digital currency markets—to 

maximize profit generation. 

381. In December 2022 and January 2023, Onyeachonam, posing as 

Representative E, emailed Investor E a client investment form and a contract 

agreement. 

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382. The client investment form included the seals for both the SEC and 

FINRA Brokercheck. 

383. The client investment form required Investor E to provide contact and 

background information, as well as information about his investing experience, 

financial assets, and investments.  

384. The form claimed:  “[Representative E] is a licensed Broker/Financial 

Adviser, regulated and accredited by the Financial Industry Regulatory Authority 

(FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative E] is 

therefore operating within the boundaries of [Representative E’s] profession and 

the data you will provide below will be used for only investment purposes.” 

385. The contract agreement claimed that Investor E was required to pay 

“10% of the profit accrued by the portfolio under the management.” 

386. The contract agreement also promised that “the investment accounts 

of [Investor E] under the management of [Representative E] would accrue a 

minimum of 5% profits monthly.” 

387. Investor E filled out the client investment form, signed the contract 

agreement, and returned both to Onyeachonam through the email address he 

controlled, which purported to be Representative E’s address. 

388. On December 23, 2022, Onyeachonam, posing as Representative E, 

sent an email to Investor E instructing him to download and sign up for accounts at 

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two SEC-registered broker-dealers, a platform for trading currency, one crypto 

asset trading platform, and Secawallet and to set up a call so that Representative E 

could sync Investor E’s accounts with Representative E’s copy trading tool and 

discuss funding and investments. 

389. On January 13, 2023, Onyeachonam, posing as Representative E, 

initiated a WhatsApp text conversation with Investor E. 

390. Onyeachonam, posing as Representative E, and Investor E thereafter 

communicated primarily through WhatsApp messages. 

391. On January 13, 2023, Onyeachonam, posing as Representative E, 

instructed Investor E through a WhatsApp message to sign up for Representative 

E’s copy trading system and provided a link to a purported copy-trading tool to 

purportedly ensure that the client would be able to transparently view trading 

activity.  

392. On January 16, 2023, Onyeachonam, posing as Representative E, 

emailed Investor E and claimed that, to maximize profit realization, Investor E’s 

capital would be split between the stock market and crypto asset market at a “40:60 

ratio” for the first three weeks of trading due to the bullish state of the crypto asset 

market.  

393. In the same email, Onyeachonam instructed Investor E to make an 

initial deposit of $20,000 in Investor E’s (genuine) brokerage account and $30,000 

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in Investor E’s crypto asset account. 

394. In January and February 2023, following these instructions, Investor E 

purchased bitcoin in his crypto asset accounts and transferred $33,997.54 in bitcoin 

to addresses displayed by the Secawallet website.   

395. Investor E also deposited $20,000 in his (genuine) brokerage account. 

396. On January 31, 2023, Onyeachonam, posing as Representative E, told 

Investor E that she had started trading Investor E’s crypto asset account and 

provided a link and login credentials to LumenTrades.com, the fake investment 

account platform Onyeachonam had created. 

397. The LumenTrades.com website displayed Investor E’s investment and 

the purported trading returns from Representative E, which appeared to be 

substantial. 

398. After Onyeachonam secured Investor E’s initial investment and 

Investor E saw the significant fictitious profits that Representative E was 

purportedly generating, Onyeachonam, posing as Representative E, succeeded in 

getting Investor E to transfer an additional $209,879.04 in purported investment 

funds over the next three months. 

399. Onyeachonam, posing as Representative E, used various techniques to 

extract additional funds from Investor E in addition to the fake returns on 

LumenTrades:  Onyeachonam (1) promoted new trading strategies that required 

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additional funds to garner high returns; (2) repeatedly reminded Investor E that the 

crypto asset market was doing well; (3) touted Representative E’s expertise, 

service, and trading success; and (4) promised Investor E that, if his account 

reached $200,000, he would be able to “withdraw $3,000 monthly without 

affecting the investment” using Representative E’s “passive income strategy.” 

400. On June 1, 2023, Onyeachonam, posing as Representative E, emailed 

Investor E about an “exceptional investment opportunity” called the Alpha Crypto 

Private Fund and attached a Prospectus for the Fund. 

401. The Prospectus touted Alpha Crypto Private Fund as having 

“consistently achieved a 6% monthly ROI [return on investment]” and having a 

“current valuation of $29 million.”   

402. The Prospectus also claimed that “we only charge a nominal fee of 

10% on the profit generated,” and that the “minimum investment amount” was 

$600,000. 

403. On June 9, 2023, Onyeachonam, posing as Representative E, emailed 

Investor E, attaching a document titled “Tax-Loss Harvesting,” and, in his cover 

email, wrote, “I strongly urge you to consider the new investment 

recommendation, as it flawlessly aligns with your financial goal.  Thank you for 

your trust, [Investor E].  As your financial advisor, I have your best interests at 

heart.” 

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404. The “Tax-Loss Harvesting” document purported to explain various 

tax aspects of investments and recommended the Alpha Crypto Private Fund 

because it “balances regular withdrawals and long-term capital growth potential” 

and “implements an advanced Tax-loss harvesting strategy, which adds an extra 

layer of benefit.”  

405. The “Tax-Loss Harvesting” document also claimed that, if Investor E 

rolled over his LumenTrades account and invested approximately $82,000 in 

additional funds, he would “achieve a harmonious balance between regular 

withdrawal of $3,000 and the potential for longer-term capital growth.”  

406. On June 14, 2023, Onyeachonam, posing as Representative E, 

emailed Investor E an investment application form and subscription agreement for 

the Alpha Crypto Private Fund.  

407. The Alpha Crypto Private Fund investment application form required 

Investor E to provide contact and background information, as well as information 

about his investing experience, financial assets, and investments. 

408. The Alpha Crypto Private Fund subscription agreement claimed that 

the Alpha Crypto Private Fund “shall generate a monthly profit of 6%,” and “shall 

charge a performance fee of 10% of the Profit earned by the Subscriber.” 

409. Investor E filled out the client investment form, signed the 

subscription agreement, and returned both to Representative E (in reality, 

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Onyeachonam). 

410. On June 16, 2023, Investor E purchased bitcoin in his crypto asset 

account and transferred $35,185.11 in bitcoin to an address displayed by the 

Secawallet website. 

411. Four days later, Onyeachonam, posing as Representative E, messaged 

Investor E via WhatsApp that it would be “advantageous” to increase his current 

portfolio of $358,965.78 to $400,000 to “ensure seamless integration with our 

fund’s investment and tax strategy.”  

412. Investor E responded, “So 42k more….  Ok I will arrange that.”  

413. Onyeachonam, posing as Representative E, replied, “Ok, once your 

portfolio reaches $400,000, it will transitioned [sic] to the fund.” 

414. On June 21, 2023, Investor E purchased bitcoin in his crypto asset 

account and transferred $39,258.74 in bitcoin to an address displayed by the 

Secawallet website. 

415. On July 12, 2023, Onyeachonam, posing as Representative E, 

provided a link and log-in credentials to portal.alphacryptofund.com, the fake 

investment account platform Onyeachonam had created and controlled.   

416. On July 26, 2023, Onyeachonam, posing as Representative E, 

provided a link and log-in credentials to portal.alphacryptofund.io, which he called 

“the backup domain” and which Onyeachonam also created and controlled. 

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417. Both the portal.alphacryptofund.com and portal.alphacryptofund.io 

websites displayed Investor E’s investment and the purported trading returns from 

Representative E’s work with the purported Alpha Crypto Private Fund, and the 

trading returns appeared to be substantial. 

418. Between August 7 and August 23, 2023, Investor E and 

Onyeachonam, posing as Representative E, discussed via WhatsApp messages 

Investor E beginning monthly withdrawals of $3,000 at the end of the month. 

419. On August 23, 2023, Onyeachonam, posing as Representative E, 

purported to explain to Investor E via WhatsApp how to make a withdrawal from 

the Alpha Crypto Fund investor portal. 

420. Investor E then wrote to Representative E (in reality, Onyeachonam), 

“So for my investment, we will solely focus on crypto.”   

421. Onyeachonam, posing as Representative E, replied, “Yes for now.  

We will transition to other markets when I see opportunity for high returns.”   

422. Investor E responded, “sounds good thx.”  

423. Later that day, Investor E submitted a request to withdraw funds from 

his Alpha Crypto Fund account. 

424. On August 25, 2023, Investor E confirmed via WhatsApp messages 

with Representative E (in reality, Onyeachonam) that he had received the $3,000 

withdrawal in his crypto asset account and was able to transfer the money to his 

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bank account. 

425. On September 12, 2023, email addresses attributable to Onyeachonam 

exchanged with others a draft of an email to a purported investor regarding a 

purported capital call, and the draft email had two attachments. 

426. On September 13, 2023, Onyeachonam, posing as Representative E, 

sent Investor E an email attaching two documents regarding a purported capital 

call by the Alpha Crypto Private Fund—the same email and attachments 

Onyeachonam had emailed in draft form the day before.  

427. The first attachment, the capital call notice, purported to require 

Investor E to make a capital contribution of $197,220.57 to the Alpha Crypto 

Private Fund to reach a total commitment of $600,000 “as per the Subscription 

Agreement dated 06/14/2023.”   

428. The capital call notice warned that, if Investor E failed to make the 

payments by September 29, 2023, he would be “subject to late fees,” and would be 

charged interest on the unpaid amount and/or suffer a reduction in his percentage 

interest in the Fund. 

429. The second attachment, titled “ALPHA CRYPTO PRIVAGE FUND:  

New Investment Strategy,” claimed that the capital call was necessary to take 

significant positions, to invest in blockchain infrastructure projects and diversity 

investments, and to create a tax-loss harvesting solution. 

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430. On September 13, 2023, Investor E messaged Representative E (in 

reality, Onyeachonam), “I think I committed to 400k on my initial sign up, 600k 

would be high investment for me.” 

431. In response, Onyeachonam, posing as Representative E, messaged 

Investor E that investing in the Alpha Crypto Private Fund aligned with his goals 

of a passive income stream, continued wealth accumulation, and an optimized tax 

strategy.   

432. Representative E (in reality, Onyeachonam) also offered Investor E an 

“upgrade to Tier 2, designed for investors who hold a full stake in the fund and 

receive the exact percentage the fund earns each month.” 

433. On September 15, 2023, Investor E messaged Representative E, “I 

will send 100k first and remaining later.”   

434. Onyeachonam, posing as Representative E, responded, “Ok.” 

435. On September 29, 2023, Investor E purchased bitcoin in his crypto 

asset account and transferred an additional $99,089.28 to an address displayed by 

Secwallet.com.   

436. As Investor E was working on transferring the funds, Onyeachonam, 

posing as Representative E, messaged him, “[Investor E], just a friendly reminder:  

please ensure that you move the funds to your secawallet account by 11:59 pm 

today to avoid incurring late fees.”   

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437. Investor E responded, “yes working on it.” 

438. On October 9, 2023, Onyeachonam, posing as Representative E, sent 

Investor E an email attaching the Alpha Crypto Private Fund’s purported 

September 2023 performance report.  

439. The purported performance report claimed “total assets under 

management” of $35.5 million, a September opening balance of $29.2 million, 

“September Performance” of 6.42% and “YTD Performance” of 58.7%.   

440. The report included a purported “Fund Manager’s Commentary” from 

Representative E. 

441. On October 13, 2023, Investor E asked Representative E (in reality, 

Onyeachonam) via WhatsApp why Investor E’s account on the Alpha Crypto Fund 

investor portal showed a return of 4.08%, while the September newsletter stated a 

return of 6.42%.   

442. Onyeachonam, posing as Representative E, responded that if Investor 

E invested an additional $96,000, he would “receive the actual percentage that the 

fund earns,” and that Investor E would begin “to receive a stable cash flow of 

$3,000 every month.”   

443. Investor E responded that he would work on selling a rental property 

to cover the additional funds. 

444. On November 3, 3023, Onyeachonam posing as Representative E, 

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sent Investor E an email attaching the Alpha Crypto Private Fund’s purported 

October 2023 performance update.   

445. The purported performance update listed monthly returns of 6.72%, 

year-to date returns of 59.5%, and year-to-date asset growth of 23.5%.   

446. The purported performance update appeared to be signed by 

Representative E as the Fund Manager of the Alpha Crypto Private Fund. 

447. On November 3, 2023, Onyeachonam, posing as Representative E, 

messaged Investor E that he needed to invest additional funds to utilize a tax 

saving strategy that “could potentially lessen [Investor E’s] tax liabilities by up to 

45%,” noting that “timing is crucial,” and that the additional funds needed to be 

invested soon for the strategy to be available.  

448. On November 10, 2023, Investor E purchased bitcoin in his crypto 

asset account, transferred an additional $59,127.54 in bitcoin to an address 

displayed by the Secawallet website, and told Representative E (in reality, 

Onyeachonam) via WhatsApp that this investment “should fulfill the 600k 

requirement principle + profit rollover.”  

449. On November 10, 2023, Onyeachonam, posing as Representative E, 

messaged Investor E that he was approximately $35,000 short of the “required 

principal target” because rolling over profits to meet funding requirements was not 

“feasible” to “avoid a potentially complex tax situation.”  

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450. On November 27, 2023, Investor E purchased bitcoin in his crypto 

asset account, transferred an additional $36,601.13 in bitcoin to an address 

displayed on the Secawallet website, and messaged Representative E (in reality, 

Onyeachonam), “I just deposited the final funding to the Secawallet.”  

451. Investor E also asked, “That should fulfill the capital requirement for 

the fund right?”   

452. Onyeachonam, posing as Representative E, responded, “Yes.” 

453. In reality, Onyeachonam and Nweke-Eze never invested Investor E’s 

money as promised but instead misappropriated it. 

D. Onyeachonam Gave Investor E the Runaround When He 
Attempted to Withdraw Additional Funds. 

 
454. By late November 2023, Investor E’s bitcoin had been moved through 

several addresses, and Onyeachonam and Nweke-Eze had stolen it. 

455. On November 28, 2023, Investor E wrote to Representative E (in 

reality, Onyeachonam), “I will start my monthly withdrawal in Jan [2024].”   

456. Onyeachonam, posing as Representative E, responded, “I got it, 

January 2024.” 

457. On January 11, 2024, Investor E emailed Representative E (in reality, 

Onyeachonam), “I am trying to contact you, can you either reply back to this email 

or send me message on whatsapp.  thx.”   

458. Onyeachonam, posing as Representative E, responded, “I will get 

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back to you on WhatsApp as soon as possible.” 

459. Onyeachonam did not respond on WhatsApp.  

460.  Investor E emailed Representative E (in reality, Onyeachonam) 

multiple times in January 2024 about being unable to make withdrawals from the 

Alpha Crypto Fund portal or the Secawallet website and about his emails to the 

support address for these websites being returned, having failed to deliver.  

461. On January 26, 2024, Investor E emailed the support email address for 

Secawallet and received a notice that the email was unable to be delivered. 

462. Onyeachonam, posing as Representative E, and Investor E spoke on 

the phone on February 2, 2024.  

463. After the phone call, Investor E emailed Representative E (in reality, 

Onyeachonam) three times in February 2024 without a response. 

464. On February 20, 2024, Onyeachonam, posing as Representative E, 

sent a final email to Investor E, noting that Investor E’s portfolio had accrued more 

than $220,000 in profit and suggesting that Investor E either move the invested 

funds to “a more conservative stock portfolio” or invest additional bitcoin into the 

current portfolio to ensure Investor E could meet his goal of withdrawing $3,000 

monthly. 

465. Investor E did not respond to this email.  

466. Investor E did not receive any additional funds or other assets back 

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from Onyeachonam or Nweke-Eze other than the single $3,000 payment described 

above. 

467. Between January and November 2023, Onyeachonam and Nweke-Eze 

stole $510,138.38 from Investor E. 

FIRST CLAIM FOR RELIEF 
Violations of Securities Act Sections 17(a)(1) and (3) 

(All Defendants) 
 

468. The Commission re-alleges and incorporates by reference here the 

allegations in paragraphs 1 through 467. 

469. Defendants, directly or indirectly, singly or in concert, in the offer or 

sale of securities and by the use of the means or instruments of transportation or 

communication in interstate commerce or the mails, (i) knowingly or recklessly 

have employed one or more devices, schemes or artifices to defraud, and/or (ii) 

knowingly, recklessly, or negligently have engaged in one or more transactions, 

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

deceit upon the purchaser. 

470. By reason of the foregoing, Defendants, directly or indirectly, singly 

or in concert, have violated and, unless enjoined, will again violate Securities Act 

Sections 17(a)(1) and (3) [15 U.S.C. §§ 77q(a)(1) and 77q(a)(3)]. 

 

 

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SECOND CLAIM FOR RELIEF 
Violations of Securities Act Section 17(a)(2)  

(Onyeachonam) 
 

471. The Commission re-alleges and incorporates by reference here the 

allegations in paragraphs 1 through 54, 57 through 149, 153 through 196, 205, 210 

through 371, and 375 through 467. 

472. Onyeachonam, directly or indirectly, singly or in concert, in the offer 

or sale of securities and by the use of the means or instruments of transportation or 

communication in interstate commerce or the mails, knowingly, recklessly, or 

negligently has obtained money or property by means of one or more untrue 

statements of a material fact or omissions of a material fact necessary in order to 

make the statements made, in light of the circumstances under which they were 

made, not misleading. 

473. By reason of the foregoing, Onyeachonam, directly or indirectly, 

singly or in concert, has violated and, unless enjoined, will again violate Securities 

Act Section 17(a)(2) [15 U.S.C. § 77q(a)(2)]. 

THIRD CLAIM FOR RELIEF 
Violations of Exchange Act Section 10(b) and Rules 10b-5(a) and (c) 

Thereunder 
(All Defendants) 

 
474. The Commission re-alleges and incorporates by reference here the 

allegations in paragraphs 1 through 467. 

475. Defendants, directly or indirectly, singly or in concert, in connection 

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with the purchase or sale of securities and by the use of means or instrumentalities 

of interstate commerce, or the mails, or the facilities of a national securities 

exchange, knowingly or recklessly have (i) employed one or more devices, 

schemes, or artifices to defraud, and/or (ii) engaged in one or more acts, practices, 

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

other persons. 

476. By reason of the foregoing, Defendants, directly or indirectly, singly 

or in concert, have violated and, unless enjoined, will again violate Exchange Act 

Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) thereunder [17 

C.F.R. §§ 240.10b-5(a) and 240.10b-5(c)]. 

FOURTH CLAIM FOR RELIEF 
Violations of Exchange Act Section 10(b) and Rule 10b-5(b) 

(Onyeachonam) 
 

477. The Commission re-alleges and incorporates by reference here the 

allegations in paragraphs 1 through 54, 57 through 149, 153 through 196, 205, 210 

through 371, and 375 through 467. 

478. Onyeachonam, directly or indirectly, singly or in concert, in 

connection with the purchase or sale of securities and by the use of means or 

instrumentalities of interstate commerce, or the mails, or the facilities of a national 

securities exchange, knowingly or recklessly has made one or more untrue 

statements of a material fact or omitted to state one or more material facts 

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

under which they were made, not misleading. 

479. By reason of the foregoing, Onyeachonam, directly or indirectly, 

singly or in concert, has violated and, unless enjoined, will again violate Exchange 

Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5(b) thereunder [17 C.F.R. 

§ 240.10b-5(b)]. 

FIFTH CLAIM FOR RELIEF 
Violations of Advisers Act Sections 206(1) and (2) 

(Onyeachonam and Asiegbu) 
 

480. The Commission re-alleges and incorporates by reference here the 

allegations in paragraphs 1 through 55, 57 through 149, 153 through 205, 210 

through 371, and 375 through 467. 

481. At all relevant times, Onyeachonam and Asiegbu were investment 

advisers, under Advisers Act Section 202(11) [15 U.S.C. § 80b-2(11)]. 

482. Onyeachonam and Asiegbu, by use of the mails or any means or 

instrumentality of interstate commerce, directly or indirectly have (i) knowingly or 

recklessly employed one or more devices, schemes, or artifices to defraud any 

client or prospective client, and/or (ii) knowingly, recklessly, or negligently 

engaged in one or more transactions, practices, and courses of business which 

operated or would operate as a fraud or deceit upon any client or prospective client. 

483. By reason of the foregoing, Onyeachonam and Asiegbu, directly or 

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indirectly, singly or in concert, have violated and, unless enjoined, will again 

violate Advisers Act Sections 206(1) and (2) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that the Court enter a 

Final Judgment: 

I. 

Permanently enjoining Defendants and their agents, servants, employees and 

attorneys and all persons in active concert or participation with any of them from 

violating, directly or indirectly, Section 17(a) of the Securities Act [15 U.S.C. 

§ 77q(a)], Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 

thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and (2) of the Advisers 

Act [15 U.S.C. §§ 80b-6(1) and 80b-6(2)];  

II. 

Permanently enjoining Defendants from directly or indirectly, including, but 

not limited to, through any entity controlled by each Defendant: (i) participating in 

the issuance, purchase, offer, or sale of any security on behalf of someone else; or 

(ii) engaging in activities for purposes of inducing or attempting to induce the 

purchase or sale of any security, including holding themselves out as industry 

professionals; provided, however, that such injunction shall not prevent each 

Defendant from purchasing or selling securities for his own personal account;   

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III. 

Ordering Defendants to disgorge all ill-gotten gains they received directly or 

indirectly, with pre-judgment interest thereon, as a result of the alleged violations, 

pursuant to Exchange Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C. 

§§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; 

IV. 

Ordering Defendants to pay civil monetary penalties under Securities Act 

Section 20(d) [15 U.S.C. § 77t(d)], Exchange Act Section 21(d)(3) [15 U.S.C. 

§ 78u(d)(3)], and Advisers Act Section 209(e) [15 U.S.C. § 80b-9(e)]; and  

V. 

Granting any other and further relief this Court may deem just and proper.  

JURY DEMAND 

 The Commission demands a trial by jury.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 

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Dated: New York, New York 
 December 11, 2024 
 
 

/s/ Antonia M. Apps              
ANTONIA M. APPS  
REGIONAL DIRECTOR  
Tejal Shah 
Adam S. Grace 
Travis Hill 
Rhonda Jung 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-9135 (Hill) 
[email protected] 
 

     Deborah A. Tarasevich 
     Elizabeth Doisy 
     Martin Zerwitz 

Securities and Exchange Commission 
100 F Street N.E. / Mail Stop 5631 
Washington, D.C. 20549-5631 
 
  

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UNITED STATES DISTRICT COURT 

DISTRICT OF NEW JERSEY 
 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
                                             Plaintiff, 
 
                        -against- 
 
CHIBUZO AUGUSTINE 
ONYEACHONAM, STANLEY 
CHIDUBEM ASIEGBU, and 
CHUKWUEBUKA MARTIN NWEKE-
EZE, 
  
                                             Defendants.  
 

 
 
24-CV-11026 

   
DESIGNATION OF     
AGENT FOR SERVICE 

 
   

 
  

           
          

 
Pursuant to Local Rule 101.1(f), because the Securities and Exchange 

Commission (the “Commission”) does not have an office in this district, the United 

States Attorney for the District of New Jersey is hereby designated as eligible as an 

alternative to the Commission to receive service of all notices or papers in the 

captioned action. 

 

 

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 2 

 Therefore, service upon the United States or its authorized designee, David 

Dauenheimer, Deputy Chief, Health Care Fraud Unit, United States Attorney’s 

Office for the District of New Jersey, 970 Broad Street, Suite 700, Newark, NY 

07102, shall constitute service upon the Commission for purposes of this action. 

 
 
 
     Respectfully submitted, 

 
/s/ Antonia M. Apps              
ANTONIA M. APPS  
REGIONAL DIRECTOR  
Tejal Shah 
Adam S. Grace 
Travis Hill 
Rhonda Jung 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
212-336-9135 (Hill) 
[email protected] 
 

     Deborah A. Tarasevich 
     Elizabeth Doisy 
     Martin Zerwitz 

Securities and Exchange Commission 
100 F Street N.E. / Mail Stop 5631 
Washington, D.C. 20549-5631 
 
Attorneys for Plaintiff 
Securities and Exchange Commission 
 
  

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	Onyeachonam Complaint 12.11.24
	antonia M. apps
	Regional Director
	Tejal Shah
	Adam S. Grace
	Travis Hill
	Rhonda Jung
	SECURITIES AND EXCHANGE COMMISSION
	New York Regional Office
	100 Pearl Street
	Suite 20-100
	212-336-9135 (Hill)
	[email protected]
	Attorneys for Plaintiff
	Plaintiff Securities and Exchange Commission (“Commission”), located at 100 Pearl Street, Suite 20-100, New York, New York 10004-2616, for its Complaint against Defendants Chibuzo Augustine Onyeachonam (“Onyeachonam”), whose last known address is No. ...
	SUMMARY
	1. Defendants, none of whom is an actual securities industry professional, impersonated real-life United States securities broker and investment adviser representatives online and by telephone and fraudulently obtained at least $2.9 million from mostl...
	2. Since at least 2019 through the date of this Complaint’s filing (the “Relevant Period”), Defendants—Nigerian nationals living in Nigeria—created websites impersonating at least 22 actual securities broker and investment adviser representatives (col...
	3. In addition to posing as representatives, Defendants made repeated misrepresentations—including promises of monthly investment returns of 15% to 25%—to potential investors to persuade them to invest.
	4. Defendants, posing as Representatives, instructed investors to open accounts at broker-dealers and crypto-asset trading platforms and purchase crypto assets, which Defendants then misappropriated.
	5. Defendants also directed investors to fake online investment platforms Defendants created, where Defendants showed investors fictitious high returns.  These fake returns and Defendants’ purportedly successful trading skills led many investors to in...
	6. When investors ultimately sought to withdraw their funds, Defendants informed investors that they were required to pay additional fees before funds would be released to them—holding investors’ funds ransom.
	7. In all, Defendants—and/or others working with them—stole at least $2.9 million from at least 28 investors, most of whom reside in the U.S.
	VIOLATIONS
	8. By virtue of the foregoing conduct and as alleged further herein, Defendants violated Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)], Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S...
	9. Unless Defendants are restrained and enjoined, they will engage in the acts, practices, transactions, and courses of business set forth in this Complaint or in acts, practices, transactions, and courses of business of similar type and object.
	NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
	10. The Commission brings this action pursuant to the authority conferred upon it by Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)], Exchange Act Section 21(d) [15 U.S.C. § 78u(d)], and Advisers Act Sections 209(d) and 209(e)...
	11. The Commission seeks a final judgment: (a) permanently enjoining Defendants from violating the federal securities laws and rules this Complaint alleges they violated; (b) permanently enjoining Defendants from directly or indirectly, including, but...
	JURISDICTION AND VENUE
	12. This Court has jurisdiction over this action pursuant to Securities Act Section 22(a) [15 U.S.C. § 77v(a)], Exchange Act Section 27 [15 U.S.C. § 78aa], and Advisers Act Section 214 [15 U.S.C. § 80b-14].
	13. Defendants, directly and indirectly, have made use of the means or instrumentalities of interstate commerce or of the mails in connection with the transactions, acts, practices, and courses of business alleged herein.
	14. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)], Exchange Act Section 27 [15 U.S.C. § 78aa], and Advisers Act Section 214 [15 U.S.C. § 80b-14].  Certain of the acts, practices, transactions, and courses of busin...
	DEFENDANTS
	15. Onyeachonam, age 30, resides in Awka, Nigeria.  He has never been associated with any entity registered with the Commission.  According to social media, Onyeachonam purports to be a web developer with Nicrotech.com, a web design and development bu...
	16. Asiegbu, age 27, resides in Awka, Nigeria.  He has never been associated with any entity registered with the Commission.
	17. Nweke-Eze, age 29, resides in Akwai, Nigeria.  He has never been associated with any entity registered with the Commission.
	DEFENDANTS’ FICTITIOUS ENTITIES
	18. Alpha Crypto Fund is a fake investment fund at least Onyeachonam pitched by impersonating a financial professional.  The associated website was visible to users in the U.S. and included an investor portal that was used to provide false information...
	19. CopyTradeApp is a fake internet platform visible to users in the U.S. and abroad that was used to make investors think that impersonated financial professionals were engaging in “copy trading,” a portfolio management strategy by which the financia...
	20. InstaForex Service, with a website visible to users in the U.S. and abroad, purported to hold investors’ funds for the duration of their investment. When investors attempted to withdraw their funds, InstaForex Service purported to require various ...
	21. LumenTrades is a fake investment account platform visible to users in the U.S. and abroad, where investors were shown their initial investment and often substantial, fictitious trading returns.  Onyeachonam set up, controlled, and operated LumenTr...
	22. Nuvoak is a fictitious investment adviser firm purported to be associated with an impersonated representative in Defendants’ scheme.  One of Nuvoak’s web domains (MyNuvoakOnline.com), visible to users in the U.S. and abroad, contained an investor ...
	23. Secawallet, with a website visible to users in the U.S. and abroad, displayed blockchain addresses to which investors were instructed to send their crypto assets.  The website was used to give investors the false impression that crypto assets were...
	24. Wealthwindow is a fake investment account platform visible to users in the U.S. and abroad, where investors were shown their initial investment and fictitious trading returns, which were often substantial.  An email address attributable to Onyeach...
	25. Defendants’ scheme involved registering internet domain names with the real first and last names of actual U.S.-based securities brokerage or investment adviser representatives—for example, “johndoe.com”—whom Defendants planned to impersonate.
	26. Most of the Representatives were employed at prominent U.S. investment firms.
	27. Defendants similarly formed limited liability companies (“LLCs”) using the names of the professionals they were impersonating to make it look like the professionals had their own investment-related firms.
	28. Defendants then created websites that copied the real Representatives’ genuine employment history and credentials from the Financial Industry Regulatory Authority’s (“FINRA”) BrokerCheck or the Commission’s Investment Adviser Public Disclosure web...
	29. The websites Defendants created touted the Representatives’ investment advisory, trading, and crypto expertise.
	30. The websites also sometimes provided the names of the LLCs Defendants had created using the names of the professionals they were impersonating.
	31. To lure potential investors to the websites, Defendants (and possibly others working with them) created profiles on YouTube and placed fictitious comments from purported advisory clients and brokerage customers (collectively, “Fake Clients”) under...
	32. The Fake Clients’ purported comments praised the Representatives’  investment services and trading success.
	33. Defendants used fake LinkedIn personas and participated in investment group chats in encrypted messaging apps to reach out to potential victims and encourage them to research the Representative whose identity Defendants had stolen.
	34. Defendants, who impersonated mostly female financial professionals in the U.S., also purchased voice-changing software.
	35. When potential investors, thinking Defendants were the impersonated Representatives, contacted Defendants, Defendants sent emails claiming that the Representatives would trade on each investor’s behalf across three markets—the U.S. stock market, t...
	36. Defendants’ emails to potential investors claimed that the Representatives used a “copy trading” program that linked each investor’s and Representative’s trading accounts to ensure that each investor could see all of the representative’s trades on...
	37. The potential investor then completed a client investment form and contract agreement and returned them by email to Defendants.
	38. Next, Defendants typically instructed each investor to download legitimate trading apps and open accounts at specific, genuine broker-dealers and crypto-asset trading platforms and then provide their login credentials to Defendants so that Defenda...
	39. Defendants—still impersonating real financial professionals—then typically told each investor that, for the first three weeks, they would predominantly trade the investor’s funds in the crypto market to take advantage of its bullish state.
	40. Defendants typically instructed each investor to fund specific, genuine brokerage accounts and crypto accounts at approximately a “20:80 ratio” or “10:90 ratio”—meaning to put one quarter or one ninth the amount of funds in brokerage accounts as i...
	41. Defendants typically further instructed each investor to purchase bitcoin with the funds in the crypto account and send the bitcoin to a specified address to “fund” the investment.  In some cases, the receiving address was set up by investors at D...
	42. When investors purchased and transferred the bitcoin, they incurred third-party fees associated with the purchase and transfer of crypto assets—payments that increased their ultimate losses from Defendants’ scheme.
	43. Once the bitcoin was in the address Defendants had specified, the bitcoin was moved through multiple addresses, often ultimately landing in addresses controlled by Defendants or their associates.
	44. Defendants then stole each investor’s bitcoin instead of investing it.
	45. Investors’ funds in their real brokerage accounts remained mostly untouched by Defendants.
	46. However, some of the brokerage account funds were subsequently used to further “fund” the investors’ crypto asset investments, which were accessible to Defendants.
	47. Defendants informed investors that they could view their account balance on an investment platform website—one of Defendants’ fake platforms such as LumenTrades, Wealthwindow, or MyNuvoakOnline.com—which showed investors’ purported returns on thei...
	48. After investors saw their investment accounts grow substantially, as fictitiously depicted in Defendants’ fake investment platforms, Defendants—still posing as the real Representatives—often offered new trading strategies that Defendants claimed r...
	49. Many investors, believing their initial investments had been successful, invested additional funds.
	50. When investors requested to withdraw their funds, Defendants typically demanded that the investors pay commissions, performance, or other purported fees to access their funds.
	51. Some investors paid these purported fees.
	52. Investors did not know that they were actually investing with Defendants and not the Representatives whose identities Defendants had stolen.
	53. Onyeachonam participated in the scheme by setting up the impersonated Representatives’ websites; incorporating entities in the names of at least six impersonated Representatives; promoting impersonated Representatives online; setting up and operat...
	54. According to Onyeachonam’s public Goodreads profile, fifteen days after Onyeachonam registered the Lumentrades.com domain in 2018, Onyeachonam read The Confidence Game: Why We Fall for It . . . Every Time (Penguin Books 2017), a book written by Ma...
	55. Asiegbu participated in the scheme by assisting in setting up websites used in the scheme; promoting the impersonated Representatives and fake investment account platforms to the investing public; and managing email addresses used to communicate w...
	56. Nweke-Eze participated in the scheme by using social media to solicit potential investors; promoting impersonated Representatives and Defendants’ fictitious trading platforms online; and managing an email address used to communicate with victim in...
	57. During their fraudulent scheme, Defendants impersonated at least 22 Representatives and stole at least $2.9 million from at least 28 investors, at least 23 of whom reside in the U.S.
	58. The examples below detail Defendants’ fraudulent scheme with respect to five of these U.S. investors.
	II. ONYEACHONAM impersonateD a Registered representative from Wisconsin and DEFENDANTS stOLE more than $500,000 from a california investor.
	A. Onyeachonam Impersonated a Wisconsin Representative Online.
	59. In November 2019, Onyeachonam set up a website impersonating a Wisconsin-based registered Representative and investment adviser Representative (“Representative A”), who was employed by a large, dually registered broker-dealer and investment advise...
	60. In 2019, Representative A had 19 years of experience as a broker-dealer representative and/or investment adviser representative.
	61. In 2019, an email address attributable to Onyeachonam registered a domain name with Representative A’s actual first and last name.
	62. Onyeachonam then created a website on that domain that advertised the Representative’s financial services.
	63. The website displayed the real credentials and employment history of Representative A and linked to Representative A’s actual FINRA BrokerCheck website page.
	64. Onyeachonam’s phony website also listed an email address with Representative A’s name as a contact method.
	65. That email address, which Onyeachonam used to communicate with investors, had been set up using another email address attributable to Onyeachonam.
	66. In May 2020, Onyeachonam registered an LLC in the name of Representative A in the state of Colorado.
	B. Defendants Promoted Representative A Online.
	67. Onyeachonam, Asiegbu, and Nweke-Eze promoted Representative A using Google Ads, YouTube, and LinkedIn accounts, all of which directed potential investors to the Representative A website Onyeachonam had created.
	68. On November 28, 2019, Onyeachonam opened a Google Ads account in the name of Representative A and listed his own name—“Chibuzo Onyeachonam”—as the contact person and his Nigerian address at the time as the postal address.
	69. That day, email addresses attributable to Onyeachonam and Asiegbu began running ads on Google for Representative A stating, “[Representative A] is a Professional Investment Adviser, Expert Trader, Crypto Analyst, and a Financial Consultant.”
	70. The language in the Google ads was similar to the representations made on the phony Representative A website Onyeachonam had created.
	71. The Google ads also linked to the phony Representative A website.
	72. Email addresses attributable to Onyeachonam, Asiegbu, and Nweke-Eze also used fake identities to promote Representative A’s trading and investment services in comments to YouTube videos.
	73. The comments took the form of a fictitious online conversation between strangers, one mentioning their investment success with Representative A and the other following up with questions about Representative A, concluding with an instruction from t...
	74. The fictitious YouTube comments were scripted, and in emails between and among themselves (and others), Onyeachonam, Asiegbu, and Nweke-Eze emailed similar scripts used for another Representative Defendants impersonated.
	75. An email address attributable to Onyeachonam also opened a LinkedIn account for Representative A that touted Representative A as a Financial Consultant at the firm for which Representative A genuinely worked.
	C. A California Investor Found Representative A Online
	and Invested More Than $500,000.
	76. An investor who at all relevant times has resided in California (“Investor A”) learned about Representative A when someone in a Signal investor group chat circulated a link to YouTube comments touting Representative A’s services.1F
	77. Investor A then found Representative A’s fake website, reviewed Representative A’s qualifications and licenses, and emailed the person Investor A thought was Representative A in August 2020 at the email address listed on the fake website that Onye...
	78. On August 7, 2020, Onyeachonam sent an introductory email—purportedly from Representative A but actually from Onyeachonam—to Investor A asking where Investor A was located, what Investor A’s experience was investing in financial markets, what his ...
	79. In his email in response, Investor A said that he was a beginner in the financial market, he had only traded in foreign exchange, he had invested in other vehicles that provided a high annual yield, had about $40,000 to invest, and his goal was to...
	80. On August 14, 2020, Onyeachonam, again posing as Representative A, emailed Investor A and explained that Representative A traded across three major financial markets—the stock, foreign exchange, and digital currency markets—to maximize profit gene...
	81. Onyeachonam’s email further claimed that, after downloading and installing a list of trading apps, the client would create a trading account which the trader would sync with a copy-trading tool to ensure that the client would be able to transparen...
	82. This email was identical to one that Onyeachonam sent to other potential investors who sought to invest through Representative A.
	83. In August 2020, Onyeachonam, posing as Representative A, emailed Investor A a client investment form and a contract agreement.
	84. The client investment form required Investor A to provide contact and background information, as well as information about his investing experience, financial assets, and investments.
	85. The form claimed: “[Representative A] is a licensed Broker/Financial Adviser, regulated and accredited by the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative A] is therefore operatin...
	86. The contract agreement further represented that Investor A was required to pay a “10% commission fee” and a “one time payment of 5% insurance premium to protect your investment against any loss ascribable to market crash or fluctuation.”
	87. The contract agreement also promised that “the investment accounts would accrue a minimum of 15% profits monthly.”
	88. Investor A filled out the client investment form, signed the contract agreement, and returned both to Onyeachonam through the email address Onyeachonam had created and that purported to be Representative A’s email address.
	89. In August 2020, Onyeachonam, posing as Representative A, instructed Investor A to download and sign up for accounts at an SEC-registered broker-dealer, a platform for trading currency, and two crypto asset trading platforms and to set up a call so...
	90. On August 23, 2020, Onyeachonam, posing as Representative A, initiated a WhatsApp text conversation with Investor A.
	91. Onyeachonam, posing as Representative A, and Investor A thereafter communicated primarily through WhatsApp messages.2F
	92. On August 26, 2020, Onyeachonam, posing as Representative A, messaged Investor A through WhatsApp and claimed that, to maximize profit realization, Investor A’s capital would be split between the stock market and crypto asset market at a “11:89 ra...
	93. On August 26, 2020, Onyeachonam, posing as Representative A, instructed Investor A to make an initial deposit of $1,200 in Investor A’s newly-opened (genuine) brokerage account and $8,800 in Investor A’s crypto asset account, to use the funds in t...
	94. In September 2020, following the instructions of Onyeachonam posing as Representative A, Investor A purchased bitcoin in his crypto asset account and transferred approximately $10,108.92 to an address Investor A had set up at a crypto-asset tradin...
	95. Investor A then told Onyeachonam, whom Investor A understood to be Representative A, that Investor A had sent the bitcoin to his address at a crypto-asset trading platform.
	96. Onyeachonam, posing as Representative A, responded that she would start trading as soon as possible.
	97. After transferring the initial investment, Investor A asked whether Representative A would be trading the funds in Investor A’s (genuine) brokerage account, and Onyeachonam, posing as Representative A, replied affirmatively.
	98. Onyeachonam, posing as Representative A, then emailed Investor A that his funds had been “uploaded to [Representative A’s] copy trading system”—the CopyTradeApp Onyeachonam had created, where Investor A could see his purported investment returns—a...
	99. The LumenTrades.com website displayed Investor A’s investment and the purported trading returns, which appeared to be substantial.
	100. After Onyeachonam secured Investor A’s initial investment and Investor A saw the significant fictitious profits that Representative A was purportedly generating, Onyeachonam, posing as Representative A, succeeded in getting Investor A to transfer...
	101. Onyeachonam, posing as Representative A, used various techniques to extract additional funds from Investor A in addition to the fake returns on LumenTrades: Onyeachonam (1) promoted new trading strategies that required additional funds to garner ...
	102. By the end of December 2020, the LumenTrades.com website showed that Investor A’s $518,299 net investment (after purported transaction fees) had purportedly earned $1,893,378 in net trading profits—a purported return of more than 250% in approxim...
	103. Those earnings were fake, as Defendants had never actually invested Investor A’s money as promised but had instead misappropriated it.
	D. Onyeachonam Gave Investor A the Runaround When He Attempted to Withdraw Funds.
	104. By late December 2020, Investor A’s bitcoin had been moved from Investor A’s crypto-asset trading platform address through several other addresses, and Defendants had thereby stolen the bitcoin.
	105. On December 29, 2020, Investor A instructed Representative A (in reality, Onyeachonam) to withdraw his entire portfolio on January 1, 2021, and asked for withdrawal instructions, because he needed to pay back the individuals who had given Investo...
	106. The same day, Onyeachonam, posing as Representative A, responded, “Got it, [Investor A].”
	107. Between December 29, 2020, and January 2, 2021, Investor A repeatedly messaged Representative A (in reality, Onyeachonam) on WhatsApp regarding Investor A’s funds.
	108. On January 2, 2021, Investor A stated, “[Representative A] I haven’t heard back from you, I don’t know where you are but please respond ASAP.  I need to move out the funds.  I’m already late and they expected it Jan 1[.]”
	109. On January 3, 2021, Onyeachonam, posing as Representative A, finally responded, “Hi [Investor A], Happy new year[.] I’m here.”
	110. On January 3, 2021, Investor A and Onyeachonam, posing as Representative A, messaged back and forth for approximately an hour.  Investor A reiterated that he needed to withdraw his funds, and Onyeachonam, posing as Representative A, responded, “I...
	111. When Investor A asked how many days it would take, Onyeachonam, posing as Representative A, responded, “3 business days.”
	112. Investor A and Onyeachonam, posing as Representative A, then turned their messages to the crypto market and the price of bitcoin.
	113. Onyeachonam, posing as Representative A, reminded Investor A of Representative A’s prediction that the price of bitcoin would “hit at least 25k before the last days of 2020,” and Investor A responded, “You were right.”
	114. On January 6, 2021, Investor A asked Onyeachonam, posing as Representative A, whether the withdrawal had been processed.
	115. On January 7, 2021, Onyeachonam, posing as Representative A, responded, “[Y]our funds are now available for withdrawal.  Go to the investment page at Lumentrades and click withdraw.”
	116. Later the same day, Investor A asked how long it would take for the funds to go from LumenTrades to Investor A’s address once Investor A hit the withdraw button.
	117. Onyeachonam, posing as Representative A, responded, “By the end of business day.”
	118. On January 8, 2021, Investor A messaged Representative A (in reality, Onyeachonam) stating that Investor A had not received his funds and that the LumenTrades website was down.
	119. That day, Onyeachonam, posing as Representative A, responded, “You just placed a withdrawal yesterday, it will take 3 business days to complete,” “I just saw that their site is down for maintenance,” and “[t]hey will process your withdrawal.”
	120. Investor A reminded Representative A (in reality, Onyeachonam), “Oh you told me by the end of the business day.”
	121. Onyeachonam did not respond to that message.
	122. On January 11, 2021, Onyeachonam, posing as Representative A, messaged Investor A that “Lumentrades is working on some features[;] that’s why there is a little delay in withdrawal.”
	123. Investor A responded, “Ok thank you so much,” and asked how long Representative A thought it would take.
	124. Onyeachonam did not respond.
	125. The same day, Investor A informed Representative A (in reality, Onyeachonam) that several people were upset with him, he was worried and anxious, his life would be destroyed, and his family and friends were close to killing him because he had not...
	126. Onyeachonam, posing as Representative A, responded that Investor A would receive his funds soon and everything was going well.
	127. Later the same day, Onyeachonam, posing as Representative A, told Investor A that his funds would be available two days later—by Wednesday, January 13, 2021.
	128. On January 13, 2021, Investor A did not receive his funds.
	129. Investor A messaged Representative A (in reality, Onyeachonam) regarding withdrawal.
	130. On January 14, 2021, Onyeachonam, posing as Representative A, told Investor A that LumenTrades is on it, “[t]hey are updating their services,” and that Investor A’s funds would be available the next day.
	131. On or around January 18, 2021, someone purporting to be from LumenTrades contacted Investor A and told him to pay additional money to receive a bonus.
	132. On January 18, 2021, Investor A informed Representative A (in reality, Onyeachonam) about the LumenTrades call and said that he did not have any more money and was “drained” and “basically bankrupt.”
	133. Onyeachonam, posing as Representative A, responded, “[P]lease follow the instruction on Lumentrades[.] . . . I did my best for you and you don’t want to follow simple instruction[ ] to withdraw your funds[?]”
	134. Investor A replied, “Lumentrades has no location, no real phone number, it’s not a real exchange anywhere.  They got my name spelled wrong in most of their emails . . . it’s not legitimate.”
	135. On January 18, 2021, in Investor A’s final WhatsApp message to Onyeachonam, Investor A stated, “Be honest with me.  I figured it out by now that you are not who you pose to be on the website.”
	136. Investor A then posed one final question: “How do you sleep at night knowing you’re destroying the lives of people who trust you[?]”
	137. Investor A received no response to his message.
	138. Nor did Investor A ever receive any funds or other assets back from Defendants.
	139. Between August and December 2022, Defendants stole $529,031.99 from Investor A.
	III. ONYEACHONAM AND ASIEGBU IMPERSONATED A FoRMER REGISTERED REPRESENTATIVE FROM texas, AND DEFENDANTS sTOLE more than $55,000 FROM AN arizona INVESTOR.
	A. Onyeachonam and Asiegbu Impersonated a Former Texas Representative Online.
	140. In April 2020, an unknown individual or individuals set up a website impersonating a former Texas-based broker-dealer and investment adviser Representative (“Representative B”) previously employed by a large, dually registered broker-dealer and i...
	141. By 2020, Representative B had had 36 years of experience as a broker-dealer representative and/or investment adviser representative during his career.
	142. In April 2020, an unknown individual or individuals registered a domain name with Representative B’s actual first and last names.
	143. An unknown individual or individuals also created a website on that domain that advertised Representative B’s financial services.
	144. The website displayed the real credentials and employment history of Representative B and linked to Representative B’s actual FINRA BrokerCheck website page.
	145. The phony website also listed an email address with Representative B’s name as a contact method.
	146. As early as May 2020, email account information indicates that Asiegbu and Onyeachonam controlled that email address, which was used to communicate with their investor victims.
	147. Additionally, Asiegbu maintained a Google Search Console account, a tool that helps website owners and developers understand how their site appears in Google Search results, for the phony website.
	148. In February 2021, Onyeachonam and/or Asiegbu purchased via an email address attributable to both of them a SSL certificate, a digital file that verifies a website’s identity and encrypts communication between a web browser and a web server, for t...
	149. In June 2021, Onyeachonam registered an LLC in the name of Representative B in the state of Delaware.
	B. Nweke-Eze Promoted Representative B Online.
	150. Starting in at least July 2020, an email address attributable to Nweke-Eze used fake identities to promote Representative B’s trading and investment services in comments to YouTube videos.
	151. The comments took the form of a fictitious online conversation between strangers, one mentioning their investment success with Representative B and the other following up with questions about Representative B, concluding with an instruction from ...
	152. The fictitious YouTube comments were scripted, and in emails sent to himself and others potentially involved in the fraud, Nweke-Eze emailed similar scripts used for another representative Defendants impersonated.
	C. An Arizona Investor Found Representative B Online
	and Invested More Than $55,000.
	153. An investor who at all relevant times has resided in Arizona (“Investor B”) learned about Representative B through comments made on YouTube touting Representative B’s services.
	154. Investor B then found Representative B’s fake website, controlled by Asiegbu, and emailed Representative B in August 2020 using the email address listed on the fake website.
	155. Investor B noted in his email that he had “heard good reviews about the services you provided to others.”
	156. On August 11, 2020, Onyeachonam and/or Asiegbu, posing as Representative B, sent an introductory email—purportedly from Representative B but actually from an email address attributable to Onyeachonam and Asiegbu—to Investor B asking where Investo...
	157. In response, Investor B said that he was a beginner in the financial market, he had made some trades and investments that had turned out poorly, he had about $130,000 in savings but did not want to invest all of it, and his goal was to earn enoug...
	158. On August 13, 2020, Onyeachonam and/or Asiegbu, again posing as Representative B, emailed Investor B and claimed that Representative B traded across three major financial markets—the stock, foreign exchange, and digital currency markets—to maximi...
	159. The email from Onyeachonam and/or Asiegbu further claimed that, after downloading and installing a list of trading apps, the client would create a trading account which the trader would sync with a copy-trading tool to ensure that the client woul...
	160. In August 2020, Onyeachonam and/or Asiegbu, posing as Representative B, emailed Investor B a client investment form and a contract agreement.
	161. Both the client investment form and the contract agreement included seals for the SEC and FINRA BrokerCheck.
	162. The client investment form required Investor B to provide contact and background information, as well as information about his investing experience, financial assets, and investments.
	163. The form claimed: “[Representative B] is a licensed Broker/Financial Adviser, regulated and accredited by the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative B] is therefore operati...
	164. The contract agreement further represented that Investor B was required to pay a “10% commission fee” and a “one time payment of insurance premium to protect your investment against any loss ascribable to market crash or fluctuation.”
	165. The contract agreement also promised that “the investment accounts would accrue a minimum of 15% profits monthly.”
	166. Investor B filled out the client investment form, signed the contract agreement, and returned both to Onyeachonam and/or Asiegbu through the email address they controlled that purported to be Representative B’s address.
	167. In August 2020, Onyeachonam and/or Asiegbu, again posing as Representative B, instructed Investor B via email to download and sign up for accounts at two SEC-registered broker-dealers, a platform for trading currency, and two crypto asset trading...
	168. In September 2020, Onyeachonam and/or Asiegbu, posing as Representative B, emailed Investor B a strategy document regarding a “bitcoin pump opportunity.”
	169. An email address Onyeachonam and Asiegbu controlled contained a Google Drive file with a similar document, dated March 24, 2021, with identical letterhead and Representative B’s fake contact information.
	170. On September 1, 2020, Onyeachonam and/or Asiegbu, posing as Representative B, emailed Investor B and claimed that, to maximize profit realization, Investor B’s capital would be split between the stock market and crypto asset market at a “19:81 ra...
	171. Representative B instructed Investor B to make an initial deposit of $5,700 in Investor B’s newly-opened (genuine) brokerage account and $24,300 in Investor B’s crypto asset account.
	172. On September 14, 2020, Onyeachonam, posing as Representative B, initiated a WhatsApp text conversation with Investor B.
	173. Onyeachonam, posing as Representative B, and Investor B thereafter communicated primarily through WhatsApp messages.
	174. In September 2020, following the instructions from Onyeachonam, posing as Representative B, Investor B purchased bitcoin in his crypto asset account and transferred approximately $20,382.97 in bitcoin to an address Investor B had set up at a cryp...
	175. Investor B was unable to set up the (genuine) brokerage account Onyeachonam, posing as Representative B, had instructed him to set up because Investor B needed additional documentation.
	176. Onyeachonam and/or Asiegbu, posing as Representative B, then emailed Investor B that his funds had been “uploaded to [Representative B’s] copy trading system”—the CopyTradeApp Onyeachonam had created, where Investor B could see his purported inve...
	177. The LumenTrades.com website displayed Investor B’s investment and the purported trading returns from Representative B.
	178. After Onyeachonam and/or Asiegbu secured Investor B’s initial investment and Investor B saw the significant fictitious profits that Representative B was purportedly generating, Onyeachonam and/or Asiegbu, posing as Representative B, succeeded in ...
	179. Onyeachonam and/or Asiegbu, posing as Representative B, used various techniques to extract additional funds from Investor B in addition to the fake returns on LumenTrades:  Onyeachonam and/or Asiegbu (1) promoted new trading strategies, which the...
	180. Defendants never invested Investor B’s money as promised but instead misappropriated it.
	D. Onyeachonam Gave Investor B the Runaround When He Attempted to Withdraw Funds.
	181. By October 27, 2020, Investor B’s bitcoin had been moved from Investor B’s crypto-asset trading platform address through several addresses, and Defendants thereby stole it.
	182. Starting on November 29, 2020, Investor B informed Representative B (in reality, Onyeachonam) via WhatsApp that he wanted to withdraw $30,000 and asked how to make a withdrawal.
	183. Onyeachonam, posing as Representative B, messaged Investor B and asked when he planned to make the withdrawal.
	184. Investor B responded, “In the next week or two, if possible.  I got pretty sick and racked up some medical bills.”
	185. Representative B (in reality, Onyeachonam) replied, “Okay.  Let me know when you’re ready.”
	186. On December 5, 2020, Investor B messaged the person he thought was Representative B:  “I tried making a withdrawal from the lumentrades [website] and it wasn’t working for me.  What’s the best route to go to get some [of] that profit out.”
	187. Onyeachonam, posing as Representative B, responded, “I will contact them and have it processed soon.”
	188. Between December 6, 2020, and December 21, 2020, Investor B repeatedly messaged Representative B (in reality, Onyeachonam) on WhatsApp regarding withdrawing Investor B’s funds.
	189. At various times in December 2020, Onyeachonam, posing as Representative B, told Investor B, “I’m trying to close some position[s] so I can process your withdrawal;” “You can withdraw it from Lumentrades but I still hold some positions that I nee...
	190. Investor B was never able to withdraw any of his funds from LumenTrades.
	191. On January 2, 2021, Investor B messaged Representative B, “Whats the deal with withdrawals.  Submitted it the 21st and its still pending.”
	192. Onyeachonam, posing as Representative B, replied, “I will contact them and get back to you.”
	193. On January 4, 2021, the purported “Lumentrades Billing Team” emailed Investor B from an email address created and controlled by Onyeachonam, “We sincerely apologise [sic] for the delay in withdrawal.  We are updating our terms and functionalities...
	194. On January 15, 2021, the same email address emailed Investor B writing, “We have fully updated our terms and functionalities.  You can now withdraw your investment and have it available in your account today.”
	195. Investor B never received any funds or other assets back from Defendants.
	196. Between September and October 2020, Defendants stole $58,194,89 from Investor B.
	IV.  DEFENDANTS IMPERSONATED A REGISTERED REPRESENTATIVE FROM MINNESOTA and stOLE more than $105,000 from a california investor.
	A. Asiegbu and Nweke-Eze Impersonated a Minnesota Representative Online.
	197. In October 2020, an unknown individual or individuals set up a website impersonating a Minnesota-based broker-dealer and investment adviser Representative (“Representative C”) employed by a large, dually registered broker-dealer and investment ad...
	198. In 2020, Representative C had 13 years of experience as a broker-dealer representative and/or investment adviser representative.
	199. In October 2020, an unknown individual or individuals registered a domain name with Representative C’s actual first and last names.
	200. An unknown individual or individuals created a website on that domain that advertised Representative C’s financial services.
	201. The website displayed the real credentials and employment history of Representative C and linked to Representative C’s actual FINRA BrokerCheck website page.
	202. The phony website also listed an email address with Representative C’s name as a contact method.
	203. That email address, used to communicate with Defendants’ investor victims, was controlled by Asiegbu starting in at least November 2020 and by Nweke-Eze starting in at least June 2021.
	204. Starting at least the day after the phony website’s domain name was registered, Asiegbu controlled the website.  For example, he set up and maintained through at least September 2021 a webhosting account for the domain—a service that stores and m...
	205. In June 2021, Onyeachonam registered an LLC in the name of Representative C in the state of Delaware.
	B. Nweke-Eze Promoted Representative C Online.
	206. Nweke-Eze promoted Representative C using YouTube, which directed potential investors to research Representative C.
	207. Starting in at least November 2020, an email address attributable to Nweke-Eze used fake identities to promote Representative C’s trading and investment services in comments to YouTube videos.
	208. The comments took the form of a fictitious online conversation between strangers, one mentioning their investment success with Representative C and the other following up with questions about Representative C, concluding with an instruction from ...
	209. The fictitious YouTube comments were scripted, and in emails sent to himself and others, Nweke-Eze emailed similar scripts used for another representative Defendants impersonated.
	C. A California Investor Found Representative C Online
	and Invested More Than $105,000.
	210. An investor who at all relevant times has resided in California (“Investor C”) learned about Representative C through comments made on YouTube touting Representative C’s services.
	211. Investor C then found Representative C’s fake website, which Asiegbu controlled, and sent Representative C a message in June 2021 using the form on the website.
	212. On June 23, 2021, Asiegbu and/or Nweke-Eze sent an introductory email—purportedly from Representative C but actually from an email address attributable to Asiegbu and Nweke-Eze—to Investor C asking where Investor C was located, what Investor C’s ...
	213. In response, Investor C said that she was a beginner in the financial market, she was interested in a balanced portfolio that provided monthly cashflow as well as long term growth, and she had $30,000 to invest and would like to increase the amou...
	214. On June 28, 2021, Asiegbu and/or Nweke-Eze, again posing as Representative C, emailed Investor C and claimed that Representative C traded across three major financial markets—the stock, foreign exchange, and digital currency markets—to maximize p...
	215. The email further claimed that, after downloading and installing a list of trading apps, the client would create a trading account which the trader would sync with a copy-trading tool to ensure that the client would be able to transparently view ...
	216. Attached to the email was a document titled, “Portfolio Management Business Model.”
	217. The Portfolio Management Business Model included the seals for the SEC and FINRA BrokerCheck.
	218. The Portfolio Management Business Model claimed, “[Representative C] is a licensed and regulated broker/portfolio manager with over 20 years of experience working with notable financial/investment firms in the United States.”
	219. The document also claimed that Representative C “guaranteed [a] monthly capital gain of 15-25%” and charged a 5-10% “performance fee or trade commission” and a 5% “insurance premium” to “insure investor’s funds against losses.”
	220. In July 2021, Asiegbu and/or Nweke-Eze, posing as Representative C, emailed Investor C a client investment form and a contract agreement.
	221. Both the client investment form and contract agreement included the seals for the SEC and FINRA BrokerCheck.
	222. The client investment form was identical to one that an email address associated with Onyeachonam and Asiegbu had emailed to [email protected] three months earlier, on March 24, 2021.
	223. The client investment form required Investor C to provide contact and background information, as well as information about her investing experience, financial assets, and investments.
	224. The form claimed: “[Representative C] is a licensed Broker/Financial Adviser, regulated and accredited by the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative C] is therefore operati...
	225. The contract agreement further represented that Investor C was required to pay a “5% commission fee” and a “one-time payment of insurance premium to protect your investment against any loss ascribable to market crash or fluctuation.”
	226. The contract agreement also promised that “the investment accounts would accrue a minimum of 15% profits monthly.”
	227. Investor C filled out the client investment form, signed the contract agreement, and returned both to Asiegbu and/or Nweke-Eze through the email address that they controlled and that purported to be Representative C’s email address.
	228. In July 2021, Asiegbu and/or Nweke-Eze, posing as Representative C, instructed Investor C to download and sign up for accounts at two SEC-registered broker-dealers, a platform for trading currency, and two crypto asset trading platforms and to se...
	229. On July 8, 2021, Onyeachonam, posing as Representative C, initiated a WhatsApp text conversation with Investor C.
	230. Representative C and Investor C thereafter communicated primarily through WhatsApp messages.
	231. On July 19, 2021, Asiegbu and/or Nweke-Eze, posing as Representative C, emailed Investor C and claimed that, to maximize profit realization, Investor C’s capital would be split between the stock market and crypto asset market at a “10:90 ratio” f...
	232. Representative C (in reality, Asiegbu and/or Nweke-Eze) instructed Investor C to make an initial deposit of $2,000 in Investor C’s newly-opened (genuine) brokerage account and $18,000 in Investor C’s crypto asset account.
	233. In July 2021, following these instructions, Investor C purchased bitcoin in her crypto asset account and transferred $19,005.17 in bitcoin to an address Investor C had set up at a crypto-asset trading platform.
	234. Investor C also deposited $2,000 into her (genuine) brokerage account.
	235. On July 24, 2021, Onyeachonam, posing as Representative C, messaged Investor C claiming that Representative C would “start trading in your account today.”
	236. Asiegbu and/or Nweke-Eze, posing as Representative C, then emailed Investor C that her funds had been “uploaded to [Representative C’s] copy trading system”—the CopyTradeApp Onyeachonam had created, where Investor C could see his purported invest...
	237. The LumenTrades.com website displayed Investor C’s investment and the purported trading returns from Representative C, which appeared to be substantial.
	238. Onyeachonam, posing as Representative C, and Investor C arranged a call via WhatsApp for August 19, 2021, at 9 a.m. Pacific Time to discuss a “new strategy” for investment.
	239. Indeed, Onyeachonam’s scheduling app listed a call on August 19, 2021, at 9 a.m. Pacific Time and described “Chibuzo [Onyeachonam]’s task” as to “Call [Investor C’s first name] • [Representative C’s first name] Project.”
	240. After Defendants secured Investor C’s initial investment and Investor C saw the significant fictitious profits that Representative C was purportedly generating, Defendants, posing as Representative C, succeeded in getting Investor C to transfer a...
	241. Defendants, posing as Representative C, used various techniques to extract additional funds from Investor C in addition to the fake returns on LumenTrades: Defendants (1) promoted new trading strategies that required additional funds to garner hi...
	242. Defendants never invested Investor C’s money as promised but instead misappropriated it.
	243. On December 2, 2021, Investor C asked Representative C for an “alternate contact” in case Investor C was unable to get a hold of Representative C.
	244. Onyeachonam, posing as Representative C, responded that the firm would have its assistant “Susan” reach out.
	245. On December 3, 2021, someone posing as “Susan Olsen,” a fictitious individual with a LumenTrades.com email address, reached out to Investor C, stating “You can reach out to me whenever you have any questions or difficulty with your account.”
	246. The same day, an email address attributable to Onyeachonam received identical draft correspondence from “Susan Olsen.”
	247. Investor C and Onyeachonam, posing as Representative C, discussed investing in the stock market.
	248. On December 15, 2021, Onyeachonam, posing as Representative C, messaged Investor C, “I will start trading the funds [in Investor C’s genuine brokerage account] as soon as possible.”
	249. Investor C responded, “awesome thanks for confirming.”
	250. Defendants never traded the funds in Investor C’s genuine brokerage account.
	D. Onyeachonam Gave Investor C the Runaround and Charged Additional Fees When She Attempted to Withdraw Funds.
	251. By March 1, 2022, Investor C’s bitcoin had been moved from Investor C’s crypto-asset trading platform address through several addresses, and Defendants had stolen the bitcoin.
	252. On March 1, 2022, Investor C messaged Representative C, “How do I withdraw my monthly gain?”
	253. Representative C did not respond.
	254. Investor C messaged Representative C several times throughout March 2022, noted that her emails to Representative C were “getting bounced,” and yet did not receive a response.
	255. On June 29, 2022, Onyeachonam, posing as Representative C, messaged Investor C, claiming that Representative C had been sick the last few months and therefore had not responded to any of Investor C’s messages.
	256. Later in the conversation, Onyeachonam claimed that Investor C “needed to buy ethereum to pay the processing fee,” and after doing so “[Investor C’s] funds will be available to [withdraw].”
	257. Investor C responded, “[A]re you sure they will release funds after I give processing fees?”
	258. Representative C replied, “Yes, that’s how it work[s].”
	259. Following instructions from Onyeachonam, posing as Representative C, Investor C used funds in her crypto asset account to purchase ethereum and transferred $2,222.16 in ethereum to an address displayed for Investor C on Secawallet.com, which Onye...
	260. Indeed, the address displayed for Investor C on Secawallet.com appeared several times in Onyeachonam’s emails.
	261. The next day, June 30, 2022, Investor C reported to Representative C that LumenTrades was now stating she needed to pay an advisory fee of approximately $8,000 to “unlock [her] funds.”
	262. Onyeachonam, posing as Representative C, told Investor C that “It’s included in the contract.”
	263. Investor C responded, “in any case I don’t have that kind of funds right now.…”
	264. On September 16, 2022, Investor C asked Representative C, “Is there any other fees after [the processing fees already paid] and your fees?”
	265. Onyeachonam, posing as Representative C, responded, “Hi [Investor C], there is no other fees….  Once the pending payment is cleared, your funds will be automatically available.”
	266. On September 16, 2022, Investor C used funds in her crypto asset account to purchase ethereum and transferred $3,161.31 in ethereum to the same Secawallet.com address for Investor C previously described in paragraph 259 above.
	267. On September 19, 2022, Onyeachonam, posing as Representative C, messaged Investor C, “[T]he payment has been confirmed.  You can login to secawallet to withdraw your funds.”
	268. Investor C was still unable to withdraw her funds, and on September 26, 2022, Investor C messaged Representative C, “[Lumentrades] support is saying it’s stuck because there is [not] enough processing fees.  Did you know about it?”
	269. The next day, Onyeachonam, posing as Representative C, responded, “[P]lease follow the instruction from Lumentrades.  I can’t change anything at this point.”
	270. On September 29, 2022, Investor C received an email from [email protected] informing Investor C that Secawallet had “started processing [Investor C’s] stuck transaction.”
	271. On September 30, 2022, Investor C messaged Representative C, “I am worried and stressed.”
	272. Onyeachonam, posing as Representative C, responded, “I’m sorry about the stress.  Everything should be settled today.”
	273. Investor C received no further communications from Representative C.
	274. Investor C continued communicating with [email protected] between September 2022 and February 2023.
	275. During that period, Onyeachonam, posing as a support representative from Secawallet, instructed Investor C to provide certain documents to complete an “identity verification” process, citing “many unusual activities on your account.”
	276. Investor C complied by providing [email protected] with scans of Investor C’s driver’s license, utility bill, and United States passport.
	277. On October 14, 2022, Onyeachonam, posing as a support representative with Secawallet, emailed Investor C, “For security reasons, we won’t be able to release the funds to the provided [crypto] address.”
	278. The purported support representative with Secawallet (in reality, Onyeachonam) directed Investor C to purchase a hardware wallet, a physical device that stores crypto assets offline, from shop.secawallet.com and told Investor C that this hardware...
	279. Two days later, Investor C responded, “Kindly please release the funds, this looks more like a scam to me now.”
	280. On November 7, 2022, Onyeachonam, posing as a support representative with Secawallet, emailed Investor C a formal invoice for the hardware wallet that listed its price as $899.99.
	281. Investor C continued exchanging emails regarding the hardware wallet with Onyeachonam, while he was posing as a support representative with Secawallet, until February 22, 2023.
	282. On that date, Onyeachonam, still posing as the Secawallet support representative, sent Investor C an email stating, “Once we receive your payment, your hardware wallet will be shipped to your location.”
	283. Investor C received no further communications from [email protected].
	284. Nor did Investor C ever receive any funds or other assets back from Defendants.
	285. Between July 2021 and September 2022, Defendants stole $106,400 from Investor C.
	V. ONYEACHONAM AND ASIEGBU impersonateD a Registered representative from CALIFORNIA and stOLE more than $45,000 from a NEW JERSEY investor.
	A. Onyeachonam and Asiegbu Impersonated a California Representative Online.
	286. In October 2020, an unknown individual or individuals set up a website impersonating a California-based broker-dealer and investment adviser representative (“Representative D”) employed by a large, dually registered broker-dealer and investment a...
	287. In 2020, Representative D had 22 years of experience as a broker-dealer representative and/or investment adviser representative.
	288. In October 2020, an unknown individual or individuals registered a domain name with Representative D’s actual first and last names.
	289. An unknown individual or individuals then created a website on that domain that advertised Representative D’s financial services.
	290. Asiegbu controlled the phony website starting in at least October 2020, and Onyeachonam controlled it starting in at least August 2021.  For example, Asiegbu maintained hosting accounts for the phony website, and Onyeachonam maintained an account...
	291. The phony website displayed the real credentials and employment history of Representative D and linked to Representative D’s actual FINRA BrokerCheck website page.
	292. The phony website also listed an email address with Representative D’s name as a contact method.
	293. That email address, used to communicate with investor victims, was controlled by Asiegbu since at least March 2021 and by Onyeachonam since at least April 2022.
	294. In June 2021, Onyeachonam registered an LLC in the name of Representative D in the state of Delaware.
	B. Onyeachonam and Asiegbu Promoted Representative D Online.
	295. As of March 2022, an email address attributable to Onyeachonam and Asiegbu used fake identities to promote Representative D’s trading and investment services in comments to YouTube videos.
	296. The comments took the form of a fictitious online conversation between strangers, one mentioning their investment success with Representative D and the other following up with questions about Representative D, concluding with an instruction from ...
	297. The fictitious YouTube comments were scripted, and in emails between and among themselves and others, Onyeachonam and Asiegbu emailed similar scripts used for another representative Defendants impersonated.
	C. A New Jersey Investor Found Representative D Online
	and Invested More Than $45,000.
	298. An investor who at all relevant times has resided in New Jersey (“Investor D”) learned about Representative D through comments made on YouTube touting Representative D’s services.
	299. Investor D then found Representative D’s fake website (in reality, controlled by Asiegbu and Onyeachonam) and sent Representative D a message in February 2022 using the form on the website.
	300. On February 9, 2022, Asiegbu and/or Onyeachonam sent an introductory email—purportedly from Representative D but actually from Asiegbu and/or Onyeachonam—to Investor D asking where Investor D was located, what Investor D’s experience was investin...
	301. To send the email, Asiegbu and/or Onyeachonam used the email address they controlled that purported to be Representative D’s address, and   Representative D’s purported email signature block included the seals for both the SEC and FINRA BrokerChe...
	302. In response, Investor D said that he had been investing for the last five years, had $25,000 to invest, and that his goal was to have steady monthly side income.
	303. On February 10, 2022, Asiegbu and/or Onyeachonam, again posing as Representative D, emailed Investor D and claimed that Representative D traded across three major financial markets—the stock, foreign exchange, and digital currency markets—to maxi...
	304. The email further claimed that, after downloading and installing a list of trading apps, the client would create a trading account which the trader would sync with a copy-trading tool to ensure that the client would be able to transparently view ...
	305. This email was identical to one that Asiegbu and/or Onyeachonam sent to other potential investors who sought to invest through Representative D.
	306. In February 2022, Asiegbu and/or Onyeachonam, posing as Representative D, emailed Investor D a client investment form and a contract agreement.
	307. The client investment form required Investor D to provide contact and background information, as well as information about his investing experience, financial assets, and investments.
	308. The form claimed:  “[Representative D] is a licensed Broker/Financial Adviser, regulated and accredited by the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative D] is therefore operat...
	309. Investor D filled out the client investment form, signed the contract agreement, and returned both to the email address that purported to be Representative D’s email address.
	310. In February 2022, Asiegbu and/or Onyeachonam, posing as Representative D, instructed Investor D to download and sign up for accounts at two SEC-registered broker-dealers, a platform for trading currency, two crypto asset trading platforms, and Lu...
	311. On February 19, 2022, Onyeachonam, posing as Representative D, initiated a WhatsApp text conversation with Investor D.
	312. Onyeachonam, posing as Representative D, and Investor D thereafter communicated primarily through WhatsApp messages.
	313. On February 24, 2022, Asiegbu and/or Onyeachonam, posing as Representative D, emailed Investor D; claimed that, to maximize profit realization, Investor D’s capital would be split between the stock market and crypto asset market at a “9:91 ratio”...
	314. In February and March 2022, following these instructions, Investor D purchased bitcoin in his crypto asset account and transferred $21,539.25 in bitcoin to an address Investor D had set up at a crypto-asset trading platform pursuant to instructio...
	315. Investor D also deposited $2,500 into his (genuine) brokerage account.
	316. On March 2, 2022, Investor D messaged Representative D (in reality, Onyeachonam) and asked, “[W]hat about [the genuine brokerage account]?  I have $2,500 [in] it.”
	317. Onyeachonam, posing as Representative D, responded, “Yes, I will start trading the accounts at once.”
	318. Onyeachonam and Asiegbu never placed any trades in Investor D’s genuine brokerage account.
	319. On March 10, 2022, Onyeachonam, posing as Representative D, messaged Investor D, “I’m executing my first trade on your [crypto asset] account today.”
	320. Investor D responded, “Awesome.”
	321. The LumenTrades.com website displayed Investor D’s investment and the purported trading returns from Representative D.
	322. On March 19, 2022, Investor D messaged Representative D, “I just logged [] into Lumentrades and saw you did trading yesterday and was able to make 17% profit in one day!  That is awesome!”
	323. After Onyeachonam secured Investor D’s initial investment and Investor D saw the significant fictitious profits that Representative D was purportedly generating, Onyeachonam, posing as Representative D, succeeded in getting Investor D to transfer...
	324. Onyeachonam and Asiegbu never invested Investor D’s money as promised but instead misappropriated it.
	325. On March 28, 2022, Investor D asked Representative D (in reality, Onyeachonam) if LumenTrades.com was “legit,” because Investor D had sent an email to [email protected] and the email bounced back.
	326. Onyeachonam, posing as Representative D, messaged Investor D, “They are doing scheduled maintenance.  That’s the reason for the delay….  Don’t be worried, I got you as your investment advisor.  You have to trust me as investment advisor.  I have ...
	D. Onyeachonam and Asiegbu Gave Investor D the Runaround When He Attempted to Withdraw Funds.
	327. By the end of March 2022, Investor D’s bitcoin had been moved through several addresses, and Onyeachonam and Asiegbu had stolen it.
	328. On March 28, 2022, Investor D asked Representative D (in reality, Onyeachonam) how to withdraw funds.
	329. Onyeachonam, posing as Representative D, responded, “Let me know when [] you’re ready to make a withdrawal.  I have to close all the open positions in your account.  And the funds will be available for withdrawal.”
	330. On March 30, 2022, Investor D messaged Representative D (in reality, Onyeachonam), “I would like to withdraw the profit at the end of the day tomorrow, Mar 31st.”
	331. Onyeachonam, posing as Representative D, did not respond.
	332. Investor D sent Representative D (in reality, Onyeachonam) many messages over the next few days and did not receive a response.
	333. On April 2, 2022, Investor D emailed Representative D (in reality, Onyeachonam), “I have tried to reach out on all possible ways.  I don’t understand why you don’t reply to my messages?  I’m again getting worried about the investment.  I have als...
	334. Neither Onyeachonam nor Asiegbu, posing as Representative D, responded.
	335. On April 6, 2022, Investor D messaged Representative D (in reality Onyeachonam), “[P]lease reply to me so that I don’t doubt this to be a Fraud.”
	336. The next day, Onyeachonam, posing as Representative D, responded, “Please calm down.  I’m working currently.  I’m not 100% available to chat all the time but I will always make out time to communicate with my clients.”
	337. Investor D responded, “I understand you may have lots of clients.  I just want you to understand my situation as it changed after we spoke.  I bought a house in Dallas and counting on some profit I can take out for down payment.”
	338. Onyeachonam, posing as Representative D responded, “I will make the funds available for withdrawal.  How much do you want to withdraw?”
	339. Investor D responded, “[C]urrently it is showing me profit of $6,398.  I just want to withdraw profit.”
	340. Onyeachonam, posing as Representative D, replied, “If you withdraw that amount it will halt my trading strategy but I can proceed to process the withdrawal if that’s what you want.”
	341. Investor D asked follow up questions but received no response from Representative D.
	342. Investor D messaged Representative D (in reality, Onyeachonam) many times over the next two weeks asking about withdrawing his funds but received no response.
	343. On April 21, 2022, Investor D messaged Representative D (in reality, Onyeachonam), “[D]on’t make me believe it’s a Fraud.  I also called [Representative D’s genuine employer].  I spoke to [another employee] and she told me you were just a Sales A...
	344. Onyeachonam, posing as Representative D, replied, “I don’t know why you’re being insecure.  I don’t know why you called [Representative D’s employer].  You’re working with me independently….”
	345. Investor D responded, “Because you are not replying to me.  I want to take out profit as per our agreement.  If I can’t, then I want to just withdraw all my investment.”
	346. Onyeachonam, posing as Representative D, messaged back, “Alright, the funds will be available tomorrow.”
	347. The next day Investor D was unable to withdraw any money from his LumenTrades account, and his messages to Representative D that day and over the next six days went unanswered.
	348. On April 29, 2022, Onyeachonam, posing as Representative D, messaged Investor D, “I’m trading.  Relax, allow me to do my job.”
	349. Onyeachonam, posing as Representative D, then failed to respond to any of Investor D’s messages between April 29, 2022, and June 28, 2022, when Onyeachonam, posing as Representative D, messaged Investor D in part, “Your funds are ready,” and inst...
	350. After Investor D set up a Secawallet account, he messaged Representative D (in reality, Onyeachonam), “[I]t is asking me to send 2 [ethereum] to someone.  Is that you?”
	351. Onyeachonam, posing as Representative D, responded, “No, [it’s] Lumentrades withdrawal processing fee.”
	352. Investor D did not pay the “processing fee.”
	353. On September 7, 2022, Investor D wrote to Representative D, “I don’t want to pay anymore fees, you help me with the withdrawal.  Let me know how I can withdraw.”
	354. Onyeachonam, posing as Representative D, responded (in his final WhatsApp message to Investor D), “[Y]ou need to pay the processing fee.”
	355. Investor D wrote back, “I will pay the fees when [investor D’s money was withdrawn to a particular crypto asset platform].  I don’t want to pay fees on any other sites.  Please move the funds into [a particular crypto asset platform] and let me k...
	356. Investor D received no response to his message.
	357. Nor did Investor D ever receive any funds or other assets back from Onyeachonam and Asiegbu.
	358. Onyeachonam and Asiegbu stole $46,493.95 from Investor D.
	VI. ONYEACHONAM impersonateD a Registered representative from GEORGIA, and ONYEACHONAM and Nweke-Eze stOLE more than $500,000 from a california investor.
	A. Onyeachonam Impersonated a Georgia Representative Online.
	359. In November 2021, an unknown individual or individuals set up a website impersonating a broker-dealer and investment adviser Representative based in the State of Georgia (“Representative E”) who was employed by a large, dually registered broker-d...
	360. In 2021, Representative E had 37 years of experience as a registered representative and/or investment adviser representative.
	361. In November 2021, an unknown individual or individuals registered a domain name with Representative E’s actual first and last names.
	362. An unknown individual or individuals also created a website on that domain that advertised Representative E’s financial services.
	363. The phony website displayed the real credentials and employment history of Representative E and linked to Representative E’s actual FINRA BrokerCheck website page.
	364. The phony website listed an email address with Representative E’s name as a contact method.
	365. Onyeachonam controlled this email address, used to communicate with Defendants’ investor victims, by at least February 2022.
	366. The phony website also touted the legal registration of an LLC in the name of Representative E, claiming that Representative E offered financial planning services through that LLC.
	367. In June 2021, Onyeachonam registered the LLC listed on the phony website in the name of Representative E in the state of Delaware.
	368. Onyeachonam controlled the phony website starting in at least January 2022, as alleged in the paragraphs below.
	369. Among other things, Onyeachonam received a test communication from the phony website’s cpanel, a web-based interface that allows website owners to manage their websites and hosting accounts, in January 2022.
	370. From September to December 2023, Onyeachonam accessed the cpanel page for the phony website six times.
	371. Starting by at least September 2023, Onyeachonam maintained an account for the phony website with a web analytics tool that helps website owners analyze visitor behavior, track traffic, and optimize their websites.
	B. Onyeachonam and Nweke-Eze Promoted Representative E Online.
	372. Starting in at least June 2022, an email address attributable to Nweke-Eze used fake identities to promote Representative E’s trading and investment services in comments to YouTube videos.
	373. The comments took the form of a fictitious online conversation between strangers, one mentioning their investment success with Representative E and the other following up with questions about Representative E, concluding with an instruction from ...
	374. The fictitious YouTube comments were scripted, and in emails sent to himself and others potentially involved in the fraud, Nweke-Eze emailed similar scripts used for another representative Defendants impersonated.
	375. An email address attributable to Onyeachonam opened a LinkedIn account for Representative E that touted Representative E as a financial advisor at the LLC Onyeachonam had registered in Representative E’s name with the state of Delaware.
	C. A California Investor Found Representative E Online
	and Invested More Than $500,000.
	376. An investor who at all relevant times has resided in California (“Investor E”) found Representative E’s fake website and sent Representative E (in reality, Onyeachonam) a message in December 2022 using the form on the website.
	377. On December 5, 2022, Onyeachonam sent an introductory email—purportedly from Representative E but actually from Onyeachonam—to Investor E asking where Investor E was located, what Investor E’s experience was investing in financial markets, what h...
	378. Onyeachonam sent the email using the email address that purported to be Representative E’s address, and Representative E’s purported email signature block included the seals for both the SEC and FINRA BrokerCheck.
	379. In response, Investor E said that he had average knowledge of the financial markets, his goal was to increase his net worth to $7-8 million in five years, and that he had properties and stocks worth $5.5 million.
	380. On December 7, 2022, Onyeachonam, again posing as Representative E, emailed Investor E and claimed that Representative E traded across three major financial markets—the stock, foreign exchange, and digital currency markets—to maximize profit gene...
	381. In December 2022 and January 2023, Onyeachonam, posing as Representative E, emailed Investor E a client investment form and a contract agreement.
	382. The client investment form included the seals for both the SEC and FINRA Brokercheck.
	383. The client investment form required Investor E to provide contact and background information, as well as information about his investing experience, financial assets, and investments.
	384. The form claimed:  “[Representative E] is a licensed Broker/Financial Adviser, regulated and accredited by the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC)[.]  [Representative E] is therefore operat...
	385. The contract agreement claimed that Investor E was required to pay “10% of the profit accrued by the portfolio under the management.”
	386. The contract agreement also promised that “the investment accounts of [Investor E] under the management of [Representative E] would accrue a minimum of 5% profits monthly.”
	387. Investor E filled out the client investment form, signed the contract agreement, and returned both to Onyeachonam through the email address he controlled, which purported to be Representative E’s address.
	388. On December 23, 2022, Onyeachonam, posing as Representative E, sent an email to Investor E instructing him to download and sign up for accounts at two SEC-registered broker-dealers, a platform for trading currency, one crypto asset trading platfo...
	389. On January 13, 2023, Onyeachonam, posing as Representative E, initiated a WhatsApp text conversation with Investor E.
	390. Onyeachonam, posing as Representative E, and Investor E thereafter communicated primarily through WhatsApp messages.
	391. On January 13, 2023, Onyeachonam, posing as Representative E, instructed Investor E through a WhatsApp message to sign up for Representative E’s copy trading system and provided a link to a purported copy-trading tool to purportedly ensure that t...
	392. On January 16, 2023, Onyeachonam, posing as Representative E, emailed Investor E and claimed that, to maximize profit realization, Investor E’s capital would be split between the stock market and crypto asset market at a “40:60 ratio” for the fir...
	393. In the same email, Onyeachonam instructed Investor E to make an initial deposit of $20,000 in Investor E’s (genuine) brokerage account and $30,000 in Investor E’s crypto asset account.
	394. In January and February 2023, following these instructions, Investor E purchased bitcoin in his crypto asset accounts and transferred $33,997.54 in bitcoin to addresses displayed by the Secawallet website.
	395. Investor E also deposited $20,000 in his (genuine) brokerage account.
	396. On January 31, 2023, Onyeachonam, posing as Representative E, told Investor E that she had started trading Investor E’s crypto asset account and provided a link and login credentials to LumenTrades.com, the fake investment account platform Onyeac...
	397. The LumenTrades.com website displayed Investor E’s investment and the purported trading returns from Representative E, which appeared to be substantial.
	398. After Onyeachonam secured Investor E’s initial investment and Investor E saw the significant fictitious profits that Representative E was purportedly generating, Onyeachonam, posing as Representative E, succeeded in getting Investor E to transfer...
	399. Onyeachonam, posing as Representative E, used various techniques to extract additional funds from Investor E in addition to the fake returns on LumenTrades:  Onyeachonam (1) promoted new trading strategies that required additional funds to garner...
	400. On June 1, 2023, Onyeachonam, posing as Representative E, emailed Investor E about an “exceptional investment opportunity” called the Alpha Crypto Private Fund and attached a Prospectus for the Fund.
	401. The Prospectus touted Alpha Crypto Private Fund as having “consistently achieved a 6% monthly ROI [return on investment]” and having a “current valuation of $29 million.”
	402. The Prospectus also claimed that “we only charge a nominal fee of 10% on the profit generated,” and that the “minimum investment amount” was $600,000.
	403. On June 9, 2023, Onyeachonam, posing as Representative E, emailed Investor E, attaching a document titled “Tax-Loss Harvesting,” and, in his cover email, wrote, “I strongly urge you to consider the new investment recommendation, as it flawlessly ...
	404. The “Tax-Loss Harvesting” document purported to explain various tax aspects of investments and recommended the Alpha Crypto Private Fund because it “balances regular withdrawals and long-term capital growth potential” and “implements an advanced ...
	405. The “Tax-Loss Harvesting” document also claimed that, if Investor E rolled over his LumenTrades account and invested approximately $82,000 in additional funds, he would “achieve a harmonious balance between regular withdrawal of $3,000 and the po...
	406. On June 14, 2023, Onyeachonam, posing as Representative E, emailed Investor E an investment application form and subscription agreement for the Alpha Crypto Private Fund.
	407. The Alpha Crypto Private Fund investment application form required Investor E to provide contact and background information, as well as information about his investing experience, financial assets, and investments.
	408. The Alpha Crypto Private Fund subscription agreement claimed that the Alpha Crypto Private Fund “shall generate a monthly profit of 6%,” and “shall charge a performance fee of 10% of the Profit earned by the Subscriber.”
	409. Investor E filled out the client investment form, signed the subscription agreement, and returned both to Representative E (in reality, Onyeachonam).
	410. On June 16, 2023, Investor E purchased bitcoin in his crypto asset account and transferred $35,185.11 in bitcoin to an address displayed by the Secawallet website.
	411. Four days later, Onyeachonam, posing as Representative E, messaged Investor E via WhatsApp that it would be “advantageous” to increase his current portfolio of $358,965.78 to $400,000 to “ensure seamless integration with our fund’s investment and...
	412. Investor E responded, “So 42k more….  Ok I will arrange that.”
	413. Onyeachonam, posing as Representative E, replied, “Ok, once your portfolio reaches $400,000, it will transitioned [sic] to the fund.”
	414. On June 21, 2023, Investor E purchased bitcoin in his crypto asset account and transferred $39,258.74 in bitcoin to an address displayed by the Secawallet website.
	415. On July 12, 2023, Onyeachonam, posing as Representative E, provided a link and log-in credentials to portal.alphacryptofund.com, the fake investment account platform Onyeachonam had created and controlled.
	416. On July 26, 2023, Onyeachonam, posing as Representative E, provided a link and log-in credentials to portal.alphacryptofund.io, which he called “the backup domain” and which Onyeachonam also created and controlled.
	417. Both the portal.alphacryptofund.com and portal.alphacryptofund.io websites displayed Investor E’s investment and the purported trading returns from Representative E’s work with the purported Alpha Crypto Private Fund, and the trading returns appe...
	418. Between August 7 and August 23, 2023, Investor E and Onyeachonam, posing as Representative E, discussed via WhatsApp messages Investor E beginning monthly withdrawals of $3,000 at the end of the month.
	419. On August 23, 2023, Onyeachonam, posing as Representative E, purported to explain to Investor E via WhatsApp how to make a withdrawal from the Alpha Crypto Fund investor portal.
	420. Investor E then wrote to Representative E (in reality, Onyeachonam), “So for my investment, we will solely focus on crypto.”
	421. Onyeachonam, posing as Representative E, replied, “Yes for now.  We will transition to other markets when I see opportunity for high returns.”
	422. Investor E responded, “sounds good thx.”
	423. Later that day, Investor E submitted a request to withdraw funds from his Alpha Crypto Fund account.
	424. On August 25, 2023, Investor E confirmed via WhatsApp messages with Representative E (in reality, Onyeachonam) that he had received the $3,000 withdrawal in his crypto asset account and was able to transfer the money to his bank account.
	425. On September 12, 2023, email addresses attributable to Onyeachonam exchanged with others a draft of an email to a purported investor regarding a purported capital call, and the draft email had two attachments.
	426. On September 13, 2023, Onyeachonam, posing as Representative E, sent Investor E an email attaching two documents regarding a purported capital call by the Alpha Crypto Private Fund—the same email and attachments Onyeachonam had emailed in draft f...
	427. The first attachment, the capital call notice, purported to require Investor E to make a capital contribution of $197,220.57 to the Alpha Crypto Private Fund to reach a total commitment of $600,000 “as per the Subscription Agreement dated 06/14/2...
	428. The capital call notice warned that, if Investor E failed to make the payments by September 29, 2023, he would be “subject to late fees,” and would be charged interest on the unpaid amount and/or suffer a reduction in his percentage interest in t...
	429. The second attachment, titled “ALPHA CRYPTO PRIVAGE FUND:  New Investment Strategy,” claimed that the capital call was necessary to take significant positions, to invest in blockchain infrastructure projects and diversity investments, and to crea...
	430. On September 13, 2023, Investor E messaged Representative E (in reality, Onyeachonam), “I think I committed to 400k on my initial sign up, 600k would be high investment for me.”
	431. In response, Onyeachonam, posing as Representative E, messaged Investor E that investing in the Alpha Crypto Private Fund aligned with his goals of a passive income stream, continued wealth accumulation, and an optimized tax strategy.
	432. Representative E (in reality, Onyeachonam) also offered Investor E an “upgrade to Tier 2, designed for investors who hold a full stake in the fund and receive the exact percentage the fund earns each month.”
	433. On September 15, 2023, Investor E messaged Representative E, “I will send 100k first and remaining later.”
	434. Onyeachonam, posing as Representative E, responded, “Ok.”
	435. On September 29, 2023, Investor E purchased bitcoin in his crypto asset account and transferred an additional $99,089.28 to an address displayed by Secwallet.com.
	436. As Investor E was working on transferring the funds, Onyeachonam, posing as Representative E, messaged him, “[Investor E], just a friendly reminder:  please ensure that you move the funds to your secawallet account by 11:59 pm today to avoid incu...
	437. Investor E responded, “yes working on it.”
	438. On October 9, 2023, Onyeachonam, posing as Representative E, sent Investor E an email attaching the Alpha Crypto Private Fund’s purported September 2023 performance report.
	439. The purported performance report claimed “total assets under management” of $35.5 million, a September opening balance of $29.2 million, “September Performance” of 6.42% and “YTD Performance” of 58.7%.
	440. The report included a purported “Fund Manager’s Commentary” from Representative E.
	441. On October 13, 2023, Investor E asked Representative E (in reality, Onyeachonam) via WhatsApp why Investor E’s account on the Alpha Crypto Fund investor portal showed a return of 4.08%, while the September newsletter stated a return of 6.42%.
	442. Onyeachonam, posing as Representative E, responded that if Investor E invested an additional $96,000, he would “receive the actual percentage that the fund earns,” and that Investor E would begin “to receive a stable cash flow of $3,000 every mon...
	443. Investor E responded that he would work on selling a rental property to cover the additional funds.
	444. On November 3, 3023, Onyeachonam posing as Representative E, sent Investor E an email attaching the Alpha Crypto Private Fund’s purported October 2023 performance update.
	445. The purported performance update listed monthly returns of 6.72%, year-to date returns of 59.5%, and year-to-date asset growth of 23.5%.
	446. The purported performance update appeared to be signed by Representative E as the Fund Manager of the Alpha Crypto Private Fund.
	447. On November 3, 2023, Onyeachonam, posing as Representative E, messaged Investor E that he needed to invest additional funds to utilize a tax saving strategy that “could potentially lessen [Investor E’s] tax liabilities by up to 45%,” noting that ...
	448. On November 10, 2023, Investor E purchased bitcoin in his crypto asset account, transferred an additional $59,127.54 in bitcoin to an address displayed by the Secawallet website, and told Representative E (in reality, Onyeachonam) via WhatsApp th...
	449. On November 10, 2023, Onyeachonam, posing as Representative E, messaged Investor E that he was approximately $35,000 short of the “required principal target” because rolling over profits to meet funding requirements was not “feasible” to “avoid a...
	450. On November 27, 2023, Investor E purchased bitcoin in his crypto asset account, transferred an additional $36,601.13 in bitcoin to an address displayed on the Secawallet website, and messaged Representative E (in reality, Onyeachonam), “I just de...
	451. Investor E also asked, “That should fulfill the capital requirement for the fund right?”
	452. Onyeachonam, posing as Representative E, responded, “Yes.”
	453. In reality, Onyeachonam and Nweke-Eze never invested Investor E’s money as promised but instead misappropriated it.
	D. Onyeachonam Gave Investor E the Runaround When He Attempted to Withdraw Additional Funds.
	454. By late November 2023, Investor E’s bitcoin had been moved through several addresses, and Onyeachonam and Nweke-Eze had stolen it.
	455. On November 28, 2023, Investor E wrote to Representative E (in reality, Onyeachonam), “I will start my monthly withdrawal in Jan [2024].”
	456. Onyeachonam, posing as Representative E, responded, “I got it, January 2024.”
	457. On January 11, 2024, Investor E emailed Representative E (in reality, Onyeachonam), “I am trying to contact you, can you either reply back to this email or send me message on whatsapp.  thx.”
	458. Onyeachonam, posing as Representative E, responded, “I will get back to you on WhatsApp as soon as possible.”
	459. Onyeachonam did not respond on WhatsApp.
	460.  Investor E emailed Representative E (in reality, Onyeachonam) multiple times in January 2024 about being unable to make withdrawals from the Alpha Crypto Fund portal or the Secawallet website and about his emails to the support address for these...
	461. On January 26, 2024, Investor E emailed the support email address for Secawallet and received a notice that the email was unable to be delivered.
	462. Onyeachonam, posing as Representative E, and Investor E spoke on the phone on February 2, 2024.
	463. After the phone call, Investor E emailed Representative E (in reality, Onyeachonam) three times in February 2024 without a response.
	464. On February 20, 2024, Onyeachonam, posing as Representative E, sent a final email to Investor E, noting that Investor E’s portfolio had accrued more than $220,000 in profit and suggesting that Investor E either move the invested funds to “a more ...
	465. Investor E did not respond to this email.
	466. Investor E did not receive any additional funds or other assets back from Onyeachonam or Nweke-Eze other than the single $3,000 payment described above.
	467. Between January and November 2023, Onyeachonam and Nweke-Eze stole $510,138.38 from Investor E.
	Violations of Securities Act Sections 17(a)(1) and (3)
	(All Defendants)
	468. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 467.
	469. Defendants, directly or indirectly, singly or in concert, in the offer or sale of securities and by the use of the means or instruments of transportation or communication in interstate commerce or the mails, (i) knowingly or recklessly have emplo...
	470. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, have violated and, unless enjoined, will again violate Securities Act Sections 17(a)(1) and (3) [15 U.S.C. §§ 77q(a)(1) and 77q(a)(3)].
	Violations of Securities Act Section 17(a)(2)
	(Onyeachonam)
	471. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 54, 57 through 149, 153 through 196, 205, 210 through 371, and 375 through 467.
	472. Onyeachonam, directly or indirectly, singly or in concert, in the offer or sale of securities and by the use of the means or instruments of transportation or communication in interstate commerce or the mails, knowingly, recklessly, or negligently...
	473. By reason of the foregoing, Onyeachonam, directly or indirectly, singly or in concert, has violated and, unless enjoined, will again violate Securities Act Section 17(a)(2) [15 U.S.C. § 77q(a)(2)].
	Violations of Exchange Act Section 10(b) and Rules 10b-5(a) and (c) Thereunder
	(All Defendants)
	474. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 467.
	475. Defendants, directly or indirectly, singly or in concert, in connection with the purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or the mails, or the facilities of a national securities exchange...
	476. By reason of the foregoing, Defendants, directly or indirectly, singly or in concert, have violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rules 10b-5(a) and (c) thereunder [17 C.F.R. §§ 240.1...
	Violations of Exchange Act Section 10(b) and Rule 10b-5(b)
	(Onyeachonam)
	477. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 54, 57 through 149, 153 through 196, 205, 210 through 371, and 375 through 467.
	478. Onyeachonam, directly or indirectly, singly or in concert, in connection with the purchase or sale of securities and by the use of means or instrumentalities of interstate commerce, or the mails, or the facilities of a national securities exchang...
	479. By reason of the foregoing, Onyeachonam, directly or indirectly, singly or in concert, has violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5(b) thereunder [17 C.F.R. § 240.10b-5(b)].
	FIFTH CLAIM FOR RELIEF
	Violations of Advisers Act Sections 206(1) and (2)
	(Onyeachonam and Asiegbu)
	480. The Commission re-alleges and incorporates by reference here the allegations in paragraphs 1 through 55, 57 through 149, 153 through 205, 210 through 371, and 375 through 467.
	481. At all relevant times, Onyeachonam and Asiegbu were investment advisers, under Advisers Act Section 202(11) [15 U.S.C. § 80b-2(11)].
	482. Onyeachonam and Asiegbu, by use of the mails or any means or instrumentality of interstate commerce, directly or indirectly have (i) knowingly or recklessly employed one or more devices, schemes, or artifices to defraud any client or prospective ...
	483. By reason of the foregoing, Onyeachonam and Asiegbu, directly or indirectly, singly or in concert, have violated and, unless enjoined, will again violate Advisers Act Sections 206(1) and (2) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)].
	PRAYER FOR RELIEF
	Dated: New York, New York
	Tejal Shah
	Adam S. Grace
	Travis Hill
	Rhonda Jung
	Attorneys for Plaintiff
	SECURITIES AND EXCHANGE COMMISSION
	New York Regional Office
	100 Pearl Street
	Suite 20-100
	212-336-9135 (Hill)
	[email protected]

	Designation of Agent for Service 12.11.24
	Pursuant to Local Rule 101.1(f), because the Securities and Exchange Commission (the “Commission”) does not have an office in this district, the United States Attorney for the District of New Jersey is hereby designated as eligible as an alternative t...
	Respectfully submitted,
	Tejal Shah
	Adam S. Grace
	Travis Hill
	Rhonda Jung
	Attorneys for Plaintiff
	SECURITIES AND EXCHANGE COMMISSION
	New York Regional Office
	100 Pearl Street
	Suite 20-100
	212-336-9135 (Hill)
	[email protected]