EFTA00094182.pdf

From: Chris Dilorio A I. To: Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Date: Sat, 12 Sep 2020 14:23:57 +0000 Attachments: KCG_Appendix_3-20_13_penultimate.docx; KCG_TCR_3-20-13-penultimate_draft.pdf; KCG_TCR_3-20-13-penultimate_draft.docx; KCG_Appendix_3-20_13_penultimate.pdf Judges Cave and Jones, The SEC corruption goes well beyond just Handler/Jefferies/NITE. My research: I developed a template. I would search NITE top traded OTCM shells. From there: Derivatives. I have filed several separate but related TCR's based on that information. The SEC has brought several actions related to my 2013 Knight TCR with Berger: Hanover/Magna, JMJ,Keener, Hicks, Fife,UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA brought a complaint against Brown Brothers Harriman AFTER the SEC was in possession of my information for almost a year. That complaint IS also my information. New SEC NY Richard Best brought that FINRA complaint. ALL of the entities are un named. WHY? Per the complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. NITE as the #1 trader in the space would most certainly have executed BBH trades converting worthless certs to real money. The BBH complaint also cites un named Swiss Banks and FFI's. As a result of exposing these frauds the SEC/FINRA no longer allow searches of OTCM share volume by Market Maker. Further, Cifu,Handler,the SEC have allowed the post VIRT/KCG: NITE to no longer disclose these share volumes in any SEC filings NOR SEC reviewed investor presentations. Has NITE exited this business? ABSOLUTELY not. It is and always has been the DRIVER of NITE trading profits. Virtually riskless albeit illegal. The investing public is intentionally misled as to the true, core business of NITE. The August 1 2012 "glitch" proved my allegations that Knight was insolvent. Knight had to raise virtually the entire "glitch" loss despite claiming to have a "highly liquid balance sheet". The accounting fraud is a result of the illegal naked shorting. The SEC,Handler,Jefferies et al "glitch" and bailout wasn't JUST a cover up of a massive SEC failure to protect the investing public however. The 2012 "glitch" was the first of many cover ups so that this massive fraud on the public can continue. Per previous correspondence and the extensive record with the SEC: As with the "glitch" ALL participants KNEW exactly the NITE core business and accounting fraud at NITE in 2017 had not changed. As the record clearly shows: NITE was engaged in abusive naked shorting OTCM (and other) money laundering shells immediately prior to the VIRT/KCG merger closing. Many of the same players in the 2017 "glitch" as the 2012 "glitch". JPM,GS,JEF/Handler, and Jay Clayton Sull Crom colleague Jared Fishman. How did the VIRT/KCG merger get approved in the face of the overwhelming evidence I provided? The same way the 2013 Knight/Getco reverse merger got approved: SEC criminal obstruction. In 2017 the SEC,Cifu,Handler wrote down 4 billion+ Naked short fails immediately prior to the VIRT/KCG deal closing. These fraud "assets" were sitting on the KCG balance sheet and used to calculate the grossly inflated EFTA00094182 tangible book value used in the KCG acquisition price. KCG was grossly insolvent. ALL participants and the SEC knew this. The primary beneficiary of this fraud: Handler/Jefferies. In 1Q2020 I alerted the SEC that absolutely nothing had changed. NITE reported a receivable of 2.5 BILLION+. This was up 90% sequentially. HUGE red flags. No investigation. In 2Q2020 the receivable had fallen by just $100 mil from 10. Meaning: The 10 receivable would have zeroed out within days of March 31 2020 as is required: settlement Then, the receivable at June 30 was within 100 mil of the March 31 balance. Inconceivable. The March 31 receivable was NEVER zeroed out as is required by law. Further, the fails listed as "assets" are a fraud. More accurately: liability. AND there is nothing in the receivable that can be converted into cash for company use. There are prior commitments: settlement. Combine this with the THIRD CFO in a year and you have the makings of ANOTHER "glitch" As I've told the SEC: HFT holdings:seconds. No receivable there. DMM? KCG sold theirs in 2016. So that leaves the VIRT DMM. Even AFTER the massive 2Q2017 Cifu/Handler/SEC write down, the receivable is up more than 6X from the last VIRT stand alone 2Q2017. AGAIN the effects of the core NITE illegal activity. So, what has changed since August 1 2012? Absolutely nothing. This is an ongoing, massive fraud perpetrated on the American people. Well orchestrated by the SEC,Handler/Jefferies,Sull Crom et al. Did Clayton recuse himself from my Award denial? Did Clayton recuse himself from the VIRT/KCG approval? Did Clayton EVER disclose his Sull Crom NITE conflicts? The answer can be found in the very carefully structured complaints against several entities in my 2013 and derivative TCR's: NONE of the activity in these SEC/FINRA complaints takes place without a willing, executing BD/MM converting worthless certs into real money. The #1 trader in the space: NITE. Yet, you won't find NITE in ANY of these complaints. As far as the SEC is concerned: :"penny stock trading fairies". The corrupt, criminal SEC/Handler/Jefferies relationship explained. I offer AGAIN to fly to SEC DC HQ or NY Office on my own dime to have the best and brightest at the SEC rip me apart and refute my extremely serious allegations 1 by 1. Bring the SDNY too. Better yet: RE forward my information to Handler,Cifu et al. I know they have already seen it from the SEC. I still have yet to be sued by ANYONE related to my information. The Opco Denial Award is also further evidence of SEC criminal obstruction. A gross mishandling of my information to both bring strategic complaints while protecting the criminal entity NITE. Ms Norberg has created some of the most extraordinary reasons for denying my award. The best so far: "SEC investigators never saw my information". An acknowledgement of SEC criminal Obstruction. It is the job of the OWB exclusively and explicitly to distribute whistleblower information within the SEC. A whistleblower has no way of knowing WHO at the SEC is working on a case. Further, despite my request for Norberg to produce the entirety of my extensive record with the SEC, she failed to do so. What was the denial in Opco based on? The SEC, Clayton, Handler, Jefferies, NITE et al ongoing massive fraud on the public must continue. So it does. Mr Kamensky must have my information. This massive fraud on the public MUST end. ALL of it Per the extensive record and my derivative TCR's: It isn't just NITE,Cifu,Handler,Jefferies et al the SEC is protecting. Is it Jane? Regards, Christopher J Dilorio Whistleblower From: Chris Dilorio e > Sent: Tuesday, July 7, 2020 6:09 AM EFTA00094183 Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Janey, MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of my award application/denial/appeal AND REQUIRED by the statute I have referenced: 240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed. But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not confined to Opco,NITE,UBSS,Sason,Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money laundering/transaction laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity. Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill. ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while EFTA00094184 screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the brain child of Chair Clayton and his Sull Cromm colleague Jared Fishman who has played a key role in keeping the criminal entity NITE/VIRT up and running. NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE? Only another fraud: Mullen. Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership. The K50 EV is manufactured in China by Qiantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US. But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to the SEC: the record: known as SeeThroughEquity https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259.pdf Seethruequity, LLC, Ajay Tandon, and Amit Tandon THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in 2011 by brothers Ajay Tandon and Amit Tandon. www.sec gov SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018 https://www.netelement.com/press-releases/release-content/1062906#.XwRXEOWSnIV SeeThruEquity Issues Update on Net Element, Inc. NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE April 2018 Update Note. Net Element, Inc. (NASDAQ: NETE, "Net Element") is a global financial www.netelement.com https://www.netelernent.com/press-releaseskelease-content/10734671#.XwRXGu\VSnIV SeeThruEquity Issues Update on Net Element, Inc. NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE August 2018 Update Note. Net Element Inc. (Nasdaq CM: NETE, "Net Element") is a global financial EFTA00094185  www.netelement.com So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone? The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares Act money. A summary of the record. Janey, Hoecker et al, Please update my Net Element and AQR TCR's Cheers! Christopher J Dilorio Whistleblower Not just irony but a massive fraud on the From: Chris Dilorio Sent: Tuesday. June 30. 2020 1.01 PM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Janey, the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any more clear: run the clock out and protect NITE,UBSS,Magna et al while denying me rightful compensation. But, As I have repeatedly told you, Hoecker, your colleagues: the last overt act of this vast conspiracy has not yet occurred: NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal, shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can EFTA00094186 circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the criminal enterprise known as Knight/KCG/VIRT: NITE. Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut down IMMEDIATELY. Certainly not exhaustive BUT a good start Cheers! Christopher J Dilorio Whistleblower From: Chris Dilorio ‹ > Sent: Tuesday, June 30, 2020 7:36 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Janey, please add the following info to my appeal of your preliminary denial of my Opco award. More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence to support my allegations. Highlighted in my attached TCR and related to my Opco Award application: Joshie Sason/Hanover/Magna: CGFIA, IMDS,NewLead,FreeSeas, PRTH etc etc etc. The SEC Sason/NewLead complaint is also my information as I filed separate but related NewLead, and FreeSeas TCR's with your office. The SEC complaint: Sason EFTA00094187 assignments: bogus notes. NO SHIT? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the FINRA World Trade Financial complaint. https://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-anti- money-laundering FINRA Fines Three Firms $900,000 for Inadequate Anti-Money Laundering Programs I FINRA.org WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined three firms a total of $900,000 for failing to establish and implement adequate anti-money laundering (AML) programs and other supervisory systems to detect suspicious transactions. www.finra.org Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA requested information from Keener related to his assignments and acquisition of bogus convertible notes including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off" https://www.finra.org/sites/default/files/OHODecision/p182993 0 0.pdf FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS 5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA www.finra.org FINRA barred Keener/JMJ in 2013 as a "Bad Actor" The SEC was certainly aware of the FINRA action https://www.sec.gov/litigation/opinions/2012/34-68014.pdf As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink Charging fka New Image Concepts https://www.sec.gov/cgi-bin/browse-edgar? action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0 https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm EFTA00094188  EDGAR Filing Documents for 0001144204-19-004046 Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 I State of Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G/A I Act: 34 ... ;'u_SEC (7,0V New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to Keener involvement. https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf Case No. 2:16-cv-03250 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document 1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ... vAyw sec g ov But Keener not the only 1 involved who knew New Concept was a money laundering shell. CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days. The SEC revoked the registration of Farkas/Skyway in 2007 https://www.sec.gov/cgi-bin/browse-edga r? action=getcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0 The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction laundering blank check shell: Cazador/Arco: Net Element A director of Blink is a guy named Donald Engel who worked at Drexel with Milken. New Concepts was HQ'd in Santa Monica: Milken But it gets better the Jaclin shell factory also linked to Honig,Stetson,Alpha Cap, Frost as well http://www.teribuhl.com/2019/08/06/honigs-shell-factory-attorney-gregg-jaclin-barred-as-sec-lawmi Honig's Shell Factory Attorney Gregg Jaclin Barred as SEC lawyer - TERI BUHL Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - L.A. Cannabis News on Text messages show Cannabis investors Defrancesco & Serruya allegedly Colluded with Clarus Securities' Christodoulis in Multiple Stocks; High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - www.teribuhl.com Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled EFTA00094189 Gruntal int Ladenburg. Gruntal: Icahn,Sater,SAC,Feinberg et al: Milken The SEC intentionally omitted a Honig/Stetson shell from this complaint: Millenium Bio/lnergetics linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019. https://www.sec.gov/cgi-bin/browse-edgar? action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0 Finally, SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey, The SEC is going after Keener/JMJ related to my information AGAIN 17.5 BILLION shares of money laundering penny stocks. https://www.sec.gov/litigation/litreleases/2020/Ir24779.htm Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020) 'Army sec g ov WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering shells???? What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint AND where NITE and UBSS traded billions of shares of CGFIA AND where NITE and UBSS traded billions of shares of IMDS also Now, what are the odds of all of that? All you have to do is read my attached TCR Janey. Cheers! Christopher J Dilorio Whistleblower From: Chris Dilorio Sent: Tuesday, June 23, 2020 4:11 PM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix small typos/corrections: EFTA00094190 Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume data in 1O2014 and 2O2014 that were expunged from KCG 10Q SEC filings. Not 2O2014 and 3O2014 SEC reviewed 10O's as I previously stated corrected below Chris From: Chris Dilorio ‹ > Sent: Tuesday, June 23, 2020 9:48 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Ms Norberg, I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in notifying me. ALL of my response pertains to the denial appeal at hand. In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just $105 mil in working capital at June 30, 2011. AND, for the EFTA00094191 resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive naked shorting. NITE is still in business TODAY. The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to $3 OR $1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure financing is an offer to sell. JPM looked the other way. As did the SEC. EFTA00094192 Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? 2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal activity. Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS. I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover. Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ. AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell. Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff: Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on steroids. Cereplast ended in bankruptcy. NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami, Apockinas/Grinshpun/Antonov/Rakishev/Trump/Kushner/SBNY/CardWorks/Merrick Bank/ESCt/Cohen etc etc etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer money then announcing it was "unlocking the value in its misunderstood payment processing business" by doing a reverse merger with a CA electric car company started by a former musician. The payment processing business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction EFTA00094193 and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and somehow settled on "mobile app developer" Austin TX: Phunware. PHUN CEO is well known to the SEC with shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the "genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional, Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings. Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was "securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office. Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the PHUN/Trump/Kushner/Parscale mobile app technology. Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also transaction/money laundering like NETE. Also involved: Hanover/Magna. ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity. SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease. This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT. Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born. But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer. Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still "IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and IM0S. The SEC response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In 1Q2020, the receivable at NITE/VIRT increased $1.2 BILLION sequentially. Up almost 90%. AND the tangible book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency. Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include: Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years: what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg: Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank ($50 bil Bad Bank to Goldman). Another Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal: Feinberg,SAC,Icahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by Vector/NewValley:Icahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC EFTA00094194 risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis, Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black: HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an Epstein money laundering vehicle: JUNK IS JUNK. THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal obstruction. SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017. Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate Cifu/Coleman/Handler/GS/JPM wrote down more than $4 billion in open naked short fails: "leverage". The SEC let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT grossly OVER paid for insolvent KCG. Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014 10O was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not. This portion of the KCG 1O2014100 was expunged as well as 2Q2014 OTCM share volumes. I have detailed this to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG. The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including: management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust: "worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies. Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own EFTA00094195 money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming Messenger also receiving taxpayer Cares Act money. Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr) also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint. OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation HOW? According to stories: activity pea