Florida Man Arrested in "Arguably Largest"-Ever Crypto Ponzi Scheme

Plus Securities Enforcement Forum West is set for Thursday, May 21, 2026, please save the date!

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Good morning! Securities Enforcement Forum West is set for Thursday, May 21, 2026 at the historic Palace Hotel in San Francisco, please save the date! Full details are below.

Here’s what’s up.

Poll Results

A staggering 90% of you us did NOT know before yesterday that Kalshi could bring enforcement actions against users, levy penalties, demand disgorgement, issue suspensions, etc.

Clips ✂️

Florida man arrested in alleged $328M crypto ponzi scheme

A Florida man accused of running what is arguably the largest crypto-linked Ponzi scheme involving $328 million has been arrested, federal prosecutors said Wednesday.

Christopher Alexander Delgado, 34, of Apopka, Florida, was taken into custody on a criminal complaint charging him with wire fraud and money laundering, according to the U.S. Attorney’s Office for the Middle District of Florida. If convicted on all counts, he faces up to 30 years in federal prison. A criminal complaint contains allegations, and Delgado is presumed innocent unless and until proven guilty.

by Bloomberg

👉 “… arguably the largest crypto-linked Ponzi scheme" ever. Florida Man, why do you do the things you do?

The DOJ’s press release is here and the Criminal Complaint is here.

Polymarket bettors appear to have insider-traded on a market designed to catch insider traders

Can you insider-trade on an investigation into your own insider trading? Polymarket just turned that question from philosophical to practical.

Blockchain sleuth ZachXBT published findings Thursday morning naming Axiom, a crypto trading platform, as the company whose employees he believed had used non-public information to place profitable trades.

The investigation had been teased for days, and Polymarket had created a contract allowing users to bet on which company would be named, pulling in roughly $40 million in volume since Monday.

The problem is that someone clearly knew the answer before it dropped.
Lookonchain identified 12 wallets that bet heavily on Axiom before the reveal, netting a combined profit of over $1 million.

by CoinDesk

👉 This is not Commodities Docket and our upcoming event in San Francisco is certainly not Commodities Enforcement Forum but how can we resist adding prediction markets to the Insider Trading panel? Obviously, we cannot.

First Brands Executive Brumbergs Admits Fraud Scheme in Guilty Plea

A former First Brands Group executive told a judge last month that he falsified financial statements, inflated invoices and double-pledged collateral to help the auto-parts supply firm get billions of dollars in financing before its collapse.

Peter Andrew Brumbergs made the statements as part of his Jan. 27 guilty plea to fraud charges, a transcript of which was unsealed Wednesday. First Brands founder Patrick James and his brother Edward are also facing charges. The James have pleaded not guilty and deny wrongdoing, but Brumbergs, who is cooperating with prosecutors, could be a key witness against them.

by Bloomberg

SEC’s 2026 Enforcement Manual Codifies Wells Process, Cooperation Credit, and Waivers—Balancing Transparency with Flexibility

The 2026 Manual update is best understood as a codification of norms shaped heavily by years of defense-bar criticism, paired with a deliberate preservation of Commission and staff discretion. It brings clearer expectations, a more structured Wells process, expanded transparency around cooperation credit (including how timeliness, completeness, remediation, and practical assistance may factor into penalty recommendations), and a formal acknowledgment that settlement decisions and related waivers will typically be considered together at the same Closed Commission Meeting. But respondents should not assume these refinements amount to significant substantive changes that will routinely provide greater rights, more preparation time, or increased negotiating leverage.

In practice, the newly stated Wells timeline may cause the process to move faster, particularly if internal enforcement of the schedule tightens under certain Commission leadership. That acceleration could leave respondents with less room for extensions or tactical pacing at exactly the point in the investigation where delays were once common. Likewise, while access to the evidentiary record may be more readily offered, such transparency will still occur only when and to the extent the Division of Enforcement deems it appropriate. And although simultaneous consideration of settlements and waivers is now explicitly recognized, it largely memorializes a longstanding practical reality: meaningful settlements have almost always been conditioned on the availability of the necessary waiver, regardless of whether the votes were formally taken together or on separate tracks.

by Freshfields

👉 Interesting blog post by Melissa Hodgman of Freshfields pointing out that while the SEC has extended the Wells process response time from two weeks to four weeks, this may, in practice, “cause the process to move faster, particularly if internal enforcement of the schedule tightens under certain Commission leadership. That acceleration could leave respondents with less room for extensions or tactical pacing at exactly the point in the investigation where delays were once common.”

Separately, Kurt Wolfe, Sarah Heaton Concannon, and Stephen Frank of Quinn Emanuel wrote that in a recent speech, SEC Enforcement Director Margaret Ryan emphasized that “fairness cuts both ways. Respondents get four weeks — not five. And the defense bar was put on notice that tactical delay will be ‘met by steadfast commitment to reasonable and timely resolution.’ The Manual has standardized the process. The clock is now running for everyone.”

Venture Fraud

We assemble the first comprehensive sample of venture fraud cases involving 614 U.S. venture capital (VC)-backed startups founded since 2000. We find that VC-backed firms are 54% more likely to face fraud charges than comparable non-VC-backed firms within a subsample of newly public firms where detection likelihood is high and homogeneous. We then examine the role of governance in explaining venture fraud, focusing on two features that have risen in recent years—founder-friendly structures and cap table complexity. In a panel prediction model examining all venture fraud cases, we find that fraud is more likely in startups with stronger founder control rights, more convex founder cash flow rights, more investors, and greater participation of non-traditional investors. Founder-controlled boards are 88% more likely to commit fraud than VC-controlled or shared-control boards, even within the same firm. Governance variables matter much more than founder characteristics in predicting fraud. Hot funding conditions at the initial round, which weaken governance incentives, predict future fraud….

by National Bureau of Economic Research

👉 Research paper by Alexander Dyck, Freda Fang, Camille Hebert and Ting Xu of the University of Toronto that seeks to answer three questions:

  • How prevalent is fraud among VC-backed companies, and how has it evolved over time?

  • What are the determinants of venture fraud?

  • Is there external market discipline for fraudulent founders?

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Securities Enforcement Forum West 2026 is set for Thursday, May 21, 2026 at the historic Palace Hotel in San Francisco! Join us in person or tune in virtually to hear from nearly 50 luminaries in the securities enforcement field—including senior government officials, in-house counsel from major corporations, and lawyers and consultants from the best firms and in the world.

In addition, Securities Enforcement Forum West will feature a cant-miss Keynote Q&A with Coinbase Chief Legal Officer Paul Grewal, moderated by Peter Altman of Akin.

👉 Please register here. See you May 21 in San Francisco!!!

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👉 Yikes. 👀