SEC v. GEORGE IAKOVOU; VIKA VENTURES LLC; and PENELOPE ZBRAVOS, No. 4:22-cv-00194-CDL, Middle District of Georgia (July 9, 2024) — Complaint

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UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
COLUMBUS DIVISION

SECURITIES AND EXCHANGE
COMMISSION,
                        Plaintiff,
            v.                                                            Civil            No.
GEORGE IAKOVOU,
VIKA VENTURES LLC,
PENELOPE ZBRAVOS,

                        Defendants.

COMPLAINT
Plaintiff, United States Securities and Exchange Commission (“SEC” or “Commission”)
alleges as follows:
INTRODUCTION
1. Beginning in late 2019 through the end of 2021, George Iakovou (“Iakovou”) the
co-founder and Chief Executive Officer (“CEO”) of Vika Ventures LLC (“Vika”), used Vika to
defraud investors of more than $6.09 million through fraudulent offers and sales of purported
shares of private companies that might hold an initial public offering (“IPO”).  Iakovou enticed
investors to Vika by offering for sale hard to acquire securities in desirable pre-IPO companies at
lower prices than other venture capital firms.  However, at both the time of the solicitation and
the execution of contracts for sale, Vika did not own the shares and, subsequently never acquired
them.  Instead of purchasing securities, Iakovou used investor funds to support his lavish
lifestyle.

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2. Iakovou created documents that he provided to potential and actual investors that
he knew, or was reckless in not knowing, contained materially false and misleading information
about Vika’s business model and investment opportunities.  Iakovou told investors via email, by
telephone, and through text messaging that he, through Vika, would invest their money in pre-
IPO securities of particular companies.  After entering into contracts for sale, investors wired
money or wrote checks to Vika believing they had purchased specific amounts of pre-IPO
securities.  However, Iakovou knew Vika did not own the shares he offered for sale at the time of
the solicitation, and Vika, through Iakovou, subsequently never acquired them.
3. From late 2019 through June 2021, Penelope Zbravos (“Zbravos”), Vika’s other
co-founder and then-girlfriend of Iakovou, performed important tasks with respect to the
company including opening business bank accounts, completing paperwork necessary to form
the business, and other administrative tasks.  Zbravos was not initially aware of the fraud.
However, after multiple red flags, by December 2020 Zbravos should have known Vika was a
fraudulent scheme.  Nevertheless, she continued to perform tasks at Vika that perpetuated the
scheme including effecting large wire transfers of investor proceeds.
4. Throughout the fraud, Iakovou provided potential and actual investors with
formal documentation that Iakovou knew contained materially false or misleading information,
including private placement memorandums (“PPMs”), welcome letters, and Vika company
profiles that appeared online.  This documentation informed investors of Vika’s supposed
process to acquire pre-IPO securities, provided investment information, and background of
supposed previous deals made by Vika, including a report that depicted Vika as having $80
million assets under management with ten investments supported by nine employees.  None of
this information was accurate.

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5. The Vika website, controlled by Iakovou, contained materially false and
misleading information that led potential and actual investors to believe that Vika had previously
participated in major IPOs when, in fact, it had not.  The Vika website also touted participation
in funding rounds for high-profile private companies.  Vika never participated in any funding
rounds and never acquired interest in any such securities.
6. Iakovou enticed investors with fictitious pricing information for the various pre-
IPO securities Vika was purportedly offering.  He told investors they could purchase the various
pre-IPO securities at very attractive prices because Vika had such strong connections in the
industry, made sizable deals previously entitling the company to better pricing for future deals,
and because Vika was a young company, it would offer securities at cost.  As Iakovou and Vika
never closed a single deal to purchase securities, Iakovou fabricated all the pricing information to
convince investors to purchase securities through Vika.
7. When investors’ funds came into Vika, Iakovou and Zbravos effectively split the
funds three ways amongst themselves and the company, although the vast majority of funds
retained by Vika were ultimately routed to Iakovou.
8. Vika never purchased or owned any securities and investors received neither
securities nor payments.  Instead, Iakovou spent the approximately $3.9 million of proceeds he
received on his lavish lifestyle including renting private jets, purchasing expensive watches,
jewelry, and cars, and partying at nightclubs in Miami, New York, France, and Greece.
9. In total, from 2020 to 2021, Iakovou and Vika raised more than $6.09 million
from at least 46 investors, through their fraudulent offers and sales of purported pre-IPO
securities, by means of false and misleading misrepresentations and omissions of material fact,
as well as deceptive acts and a course of conduct designed to defraud investors.  Zbravos, for her

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participation in the scheme, received more than $2.1 million, some of which she also spent on
luxury goods, cosmetic surgery, vacations, and commissioning a fountain in Greece.  To date,
investors have not received any securities, payouts, or return of funds.
10. As a result of the conduct alleged in this Complaint, Iakovou and Vika violated
the anti-fraud provisions of the federal securities laws, specifically, the Securities Act of 1933
(“Securities Act”) Section 17(a) [15 U.S.C § 77q(a)], the Securities Exchange Act of 1934
(“Exchange Act”) Section 10(b) [15 U.S.C § 78j(b)] and Exchange Act Rule 10b-5 [17 C.F.R. §
240.10b-5], and Zbravos violated Securities Act Section 17(a) [15 U.S.C § 77q(a)].
11. The Commission requests that the Court enjoin Defendants from further
violations of the federal securities laws as alleged in this Complaint, and order them to pay a
monetary penalty based upon these violations.  The Commission also requests that the Court
order Iakovou and Zbravos to pay disgorgement amounts, and prejudgment interest thereon,
based upon these violations.  The Commission finally requests a judgment against Iakovou
barring him from serving as an officer or director of a public company and enjoining him from
participating in the issuance, purchase, offer, or sale of any security as specified below.
THE DEFENDANTS
12. George Iakovou (“Iakovou”), 29, is a resident of New York, NY.  He is a co-
founder of Vika and represented himself to investors as its CEO.  Iakovou invoked his Fifth
Amendment right against self-incrimination when subpoenaed for documents and testimony by
the Commission.
13. Vika Ventures LLC (“Vika”) is a Delaware limited liability company formed by
Iakovou and Zbravos on November 7, 2019 with its principal place of business in New York,
NY.  Vika has never registered an offering of securities with the Commission, and its securities

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do not trade on any exchange.  It has never been registered with the Commission as a broker,
dealer, or investment adviser.
14. Penelope Zbravos (“Zbravos”), 27, is a resident of Queens, NY. She is a co-
founder of Vika.  Prior to working at Vika, she was a financial analyst at a hospital network in
New York and prior to Vika, and she had extremely limited experience with the venture capital
industry.
JURISDICTION AND VENUE
15. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d)(1),
and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)], and Sections 21(d)
and 27 of the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa].
16. This Court has personal jurisdiction over Iakovou, Vika, and Zbravos
(collectively the ”Defendants”), and venue is proper in this District because the Defendants
engaged in certain acts and transactions constituting violations of the Securities Act and the
Exchange Act, such as investor solicitations, fraudulent offerings, and communications with
investors in this District.
17. In connection with the conduct alleged in this Complaint, specifically the
solicitation, offer, and sale of pre-IPO securities, the making and dissemination of fraudulent
statements, and the undertaking of fraudulent acts and practices, Defendants, directly and
indirectly, singly or in concert with others, made use of the means or instrumentalities of
interstate commerce, the means or instruments of transportation or communication in interstate
commerce, such as through email, the telephone, and text messages.

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DEFENDANTS’ ACTS IN VIOLATION OF THE FEDERAL SECURITIES LAWS
A. The Creation of Vika Ventures
18. Iakovou has worked in the financial services sector since 2015 and has
unsuccessfully attempted to pass the entry-level registered representatives’ exam on no less than
three occasions.  Since 2018, Iakovou was employed at an exempt reporting private fund advisor
that primarily conducted deals in the pre-IPO space.  During the summer of 2019, Iakovou asked
his then-girlfriend, Zbravos, to work as his assistant there.  However, after a series of
disagreements with the owner of the private fund advisor, including about Iakovou’s failure to
pay back monies owed to him, in November 2019, Iakovou left the advisor to strike out on his
own.  Zbravos left with Iakovou.
19. In fall of 2019, Iakovou and Zbravos founded Vika as a start-up venture capital
fund offering for sale pre-IPO securities of well-known private companies.  Iakovou held himself
out as the CEO, served as the face of the company, and communicated with potential and actual
investors.  Zbravos was Vika’s Finance Manager and performed various duties, primarily back
office support.
20. Zbravos assisted Iakovou with the formalities necessary to start the business
including registering the company with the proper authorities, designing the logo and creating
the Vika website.  Zbravos also created pitch decks shown to potential investors by Iakovou that
described Vika as well as the individual investment opportunities.  She created and maintained a
spreadsheet of investors and their investments.
21. To attract investors, Iakovou created a series of documents that conveyed
materially false and misleading information about Vika but appeared genuine to investors.
Specifically, Iakovou enrolled Vika in an online investing profiling platform that allowed him to

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self-report information and create a Venture Capital Profile (“Vika Profile”) to share with
potential investors.  Iakovou falsified information about Vika’s net worth, previous investments,
assets under management, and number of employees and falsely reported that by December 2020
Vika had more than $80 million assets under management with ten investments supported by
nine employees, none of which was accurate.  Iakovou sent investors the Vika Profile along with
reports from this online platform for various private companies Vika was offering of pre-IPO
securities.  Investors believed this information accurately reflected Vika as a growing and
dynamic business while Iakovou knew the documents were entirely fabricated.
22. Iakovou also provided potential investors with PPMs for Vika that he created and
that contained materially false or misleading information.  For example, Iakovou provided a
PPM to potential investors that represented that Vika would acquire shares or interests in pre-
IPO companies on behalf of investors.  The PPMs portrayed Vika as a legitimate business,
however, no securities were ever purchased by Vika.
23. Vika’s website touted purported previous investments made by Vika in companies
that had successful IPOs as well as opportunities to invest in much sought after private
companies anticipating IPOs.  Through its website, Vika held itself out as a venture capital firm
with prior successes.  In actuality, this information was materially false and misleading as Vika
had not participated in any previous investments nor did it own any shares in pre-IPO companies.
24. Prior to investing with Vika, several investors visited Vika’s website and were
presented with the false and misleading information.  They also viewed hyperlinks to several
news articles that quote Iakovou in various financial news publications talking about similar
investment opportunities, all of which created the aura of a highly successful company, leading
individuals to invest.

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B. Vika’s Fraudulent Offer and Sale of Pre-IPO Securities
25. Vika received its first investment on January 2, 2020 when the mother of
Iakovou’s childhood friend invested $105,000 for what she believed was an investment in the
pre-IPO shares of Company A.  Ultimately, Iakovou and Zbravos transferred or received over
half of these funds to their personal bank accounts.  From the remaining monies, Zbravos made
payments to the Vika business credit card for personal expenses incurred by Iakovou.  No shares
were ever purchased in Company A for the benefit of Vika’s first investor.
Georgia Investing Group
26. Vika did not receive another investment for nearly six months until Iakovou
connected with a former client from his previous employer.  In June 2020, Iakovou pitched Vika
to this individual who lives in Georgia and is a member of an informal, social investing club that
shares interesting investment opportunities with its participants.  This individual and a few other
club participants happened to be pricing the pre-IPO securities of Company B around the time
Iakovou reached out.  When asked about Company B, Iakovou told this individual that Vika
could offer it at $200 a share.  Because the other two identified offers came in at $250 and $275
per share and one investor had a prior positive experience with Iakovou, these three individuals
each decided to invest with Vika after reviewing the supporting paperwork provided by Iakovou.
27. When one investor from Georgia asked about the fee structure for the initial
Company B offer, Iakovou confirmed the investor’s understanding that he could pay an extra
$1,000 “commission” rather than have Iakovou take the fee out of his investment.  Iakovou told
the investor: “[t]hat way the full $20,000 would be towards stock.”  However, Iakovou and Vika
never purchased any shares of Company B on his behalf.

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28. Several of the Georgia investors shared information about their Vika investments
with numerous friends and family, who in turn, shared with other friends and family.  By
offering all of these individuals incredibly enticing deals in additional companies, Vika received
investments from 34 people in approximately eight private companies.
29. For example, on March 2, 2021, Iakovou emailed various investors with an
alleged opportunity in Company C.  Iakovou said via email:  “Just sending out [the Company C]
docs again.  We have a hard deadline of Wednesday for money in to close the transaction before
IPO.  Price is set at $6.50.  Your fee structure will be 0% upfront and 10% on the back.”
Following Iakovou’s solicitation, at least six individuals with prior Vika investments made what
they thought were investments in Company C.
30. From June 2020 until early April 2021, Iakovou and Vika defrauded these 34
individuals of approximately $2.9 million by leading them to believe they were investing in pre-
IPO companies when, in fact, no shares were purchased.
Other Vika Investors
31.  On June 23, 2020, a Zbravos family member wired $50,000 to Vika for what she
believed was an investment in Company A.  On July 3, 2020, Iakovou sent the family member
and Zbravos the buy confirmation letter for the purchase.  The letter sent via email stated:
Your  total  capital  contribution  of  $50,000.00  received  on  June  23rd,  2020,
constitutes a 100% membership interest in Series A-9 of the company.  Series A-9
currently holds 9,090 shares of common stock for [Company A] through an affiliate
of the Company.  There have been 0% fees deducted on this transaction and your
capital contribution is $50,000.00 which has been applied to an investment in 9,090
underlying shares of Company A at a purchase price equivalent to $5.50 per share.

Vika did not hold 9,090 shares of common stock for the family member.  Upon receipt of the
proceeds, Iakovou directed Zbravos to wire $5,000 to each of their personal accounts.  The

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remaining $40,000 was ultimately used by Iakovou for his lavish personal spending.  No shares
were purchased on the family member’s behalf.
32. In January 2021, a group of investors from California and Indiana who pool
resources to make investments in pre-IPO securities came across the Vika website and other
internet information regarding Vika while researching potential opportunities to invest in
Company B and contacted Iakovou.  Iakovou told them Vika was authorized by Company B to
transact secondary stock sales from employees and investors.  Iakovou also provided them with
the Vika Profile, a company profile from the online investing platform for Company B, Vika’s
PPM, and a redacted stock transfer agreement that purported to show Vika holding Company B
securities.  Given these assurances, on January 27, 2021, these investors wired $2.06 million to
Vika for what they believed was for 8,000 shares of Company B at $250 a share with an upfront
fee of 3%.  Iakovou directed Zbravos to wire him $690,000 and transfer $690,000 to herself on
January 28, 2021.
33. On February 8, 2021, the group made an additional investment for 1,600 shares of
Company B and wired $412,000 to Vika.  On February 9, 2021, at Iakovou’s direction, Zbravos
transferred $150,000 of this money to her personal bank account and wired $150,000 to
Iakovou’s personal account.  No Company B shares were ever
 purchased.
34. After these initial investments, these investors expressed interest in another deal
with Vika but wanted additional assurances from Iakovou before proceeding.  Iakovou made two
trips to California to meet with them.  During those trips, he made various promises, including
that he would file a Form ADV with the Commission, create an online portal to track their
investments, provide proof of actual ownership of the securities, and provide a notarized and
unredacted stock transfer agreement.  Although Iakovou had dinner with the investors one night,

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he then postponed meeting with them thereafter.  Iakovou claimed he was sick.  The investors
only learned by calling his hotel that Iakovou had already traveled back to New York.  Iakovou
never provided the requested information, and the group did not invest again thereafter.
35. In June 2021, after Iakovou ceased communicating with them, these four
investors made contact with both Company B and another company for which Vika had solicited
an investment.  Both companies told these investors they had no relationship with Vika nor was
Vika authorized to transact on their behalf.
 
 Iakovou’s Additional Lies
36. In March 2020, a credit card company closed the Vika charge account after
Iakovou made several unsuccessful payments after charging tens of thousands of dollars in
personal expenses.  Zbravos used her own funds to pay the balance and sought reimbursement
from Iakovou.  Iakovou paid Zbravos back with proceeds received from investors.  In fact,
Iakovou repaid a portion of the balance by instructing Zbravos to take the proceeds of an entire
investment sent by one individual.  When asked how Vika would give this person his Company
A shares, Iakovou told Zbravos he had “extra” shares, which was patently false.
 
37. To further hide his misconduct, Iakovou took steps to direct the use of fictitious
wire transfers.  In November 2020, five months after Vika began raising money in earnest,
Iakovou attempted to make a wire transfer to an entity he told Zbravos was the investment bank
from which Vika was purchasing the pre-IPO securities.  Since he was not able to make the
transfer, Iakovou instructed Zbravos to send money via an ACH payment system for the
purchase of pre-IPO securities.
 
38. Despite the volume of investor proceeds coming into Vika for investments, this is
the first time Iakovou instructed Zbravos to wire funds for the purchase of securities.  During her

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employment with Vika, Zbravos wired more than $1 million to this account without ever
receiving a single confirmation of monies received or stock purchased.  Unbeknownst to
Zbravos, the purported investment bank account number Iakovou provided to her belonged to
one of his friends who ultimately transferred almost all of the funds back to Iakovou.
 
39. In January 2021, Zbravos texted Iakovou to say that their friends thought Vika,
Iakovou, and Zbravos were “scammers & unprofessional” stating, “You’ve been lying to me. . .
.If you didn’t have the f*!@(* stock why did you do this?”  Iakovou did not reply.
The Unraveling of Vika
40. Some investors believed they owned shares of Company A which conducted its
IPO in September 2020.  Iakovou told the investors who believed they owned pre-IPO securities
in Company A – including Zbravos’ family member – that there was a six month lock up period
which would expire at the end of March 2021.  At March’s end, investors began questioning
Iakovou as to when they would receive their shares.
41. Iakovou provided a myriad of false or misleading excuses as to why Vika could
not transfer the shares.  First, Iakovou said there was a long list of investing firms that the
transfer agent was working through and Vika’s shares were not priorities.  Then, he said the
transfer agent experienced significant issues and would not be able to send the shares promptly.
Iakovou sent multiple emails blaming various delays, however, the truth was that Vika never
purchased the securities.  Thereafter, he ceased communicating with any investors.
42. Around the time Vika investors were inquiring about Company A shares, Zbravos
ended her romantic relationship with Iakovou after she uncovered several lies – both personal
and professional – that he told her.  She formally left the company on June 4, 2021.

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43. After Zbravos’ departure, Iakovou continued to raise approximately $395,000
funds from additional investors through at least December 2021.  Iakovou directed these
investors write checks or wire funds to his personal account earmarked for a Vika investment, as
the existing Vika bank accounts had been closed.
C. Zbravos Ignored Red Flags
44. While Iakovou pitched purported investment opportunities to various individuals,
Zbravos supported the company behind the scenes.  She edited documents such as the PPMs and
the welcome letters, drafted pitch decks for Iakovou to use with potential and actual investors,
and maintained the spreadsheet of the investor funds that Vika received.  Given Iakovou’s
negative financial history of delinquent payments, Zbravos opened bank accounts for Vika and a
business credit card for Vika using her financial history.  Zbravos had prime responsibility for
the Vika bank accounts and effected the vast majority of payments and wire transfers.
45.  In October and November 2020, Zbravos began asking Iakovou questions
regarding the wire transfers to the investment bank and about his actions and personal spending.
By December 2020, Zbravos knew or should have known that Iakovou and Vika were
conducting a fraudulent scheme.  Zbravos ignored these red flags and continued to transfer large
amounts of investor proceeds into her and Iakovou’s personal bank accounts for several more
months even in the face of additional warning signs.
46. For example, on April 3, 2021, Zbravos discovered that Iakovou had faked the
emails supposedly sent to her from the investment bank.  Zbravos texted Iakovou, stating, “I
think if you want to save yourself. Stop taking accepting further investments & find whatever
stock you don't own & end it.”

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47. Iakovou responded that he had all the stock that was needed, to which Zbravos
replied: “No you don't, can you stop lying to me for just a second & talk openly. Forget about
[stock transfer agreements] you don't even have confirmation emails stating the purchase of
stock.”  Despite these conversations, Zbravos continued to manage the funds in the bank
accounts from new investors well into the end of May 2021, wiring herself and Iakovou shares of
the proceeds.
48. Zbravos formally removed herself from all Vika entities’ operating agreements on
June 4, 2021.  As she was in the process of leaving Vika, Zbravos transferred $300,000 from
Vika’s account to her personal account in order to negotiate a buyout from Iakovou, telling him
she thought it was ‘insulting’ that she would give up her 50 percent ownership stake in Vika for
nothing.
49.   Iakovou replied “[it is] insulting that you barely did anything and made $2.5M
and now you're holding my stock money hostage.”  Ultimately, she and Iakovou agreed she
would keep $60,000 as her payout.  Between June 4, 2021 and June 10, 2021, the Vika bank
accounts were emptied of all remaining investor funds and Zbravos closed the accounts.
D. Iakovou and Zbravos Syphoned Off Investor Funds for Personal Use
50. Iakovou spent his share of the proceeds lavishly.  He spent more than $680,000 on
luxury watches and designer jewelry.  Over $173,000 was spent in nightclubs and lounges in
Miami, New York, France, and Greece.  Iakovou purchased more than $372,000 worth of
designer goods and spent nearly $220,000 renting or buying luxury cars.  Iakovou dined at high-
end restaurants with some meals costing more than $112,000.  He spent $56,000 on
entertainment and sports betting while also racking up $70,000 on home furnishings.   Iakovou
spent nearly $650,000 on private jet travel and another $125,000 on additional travel expenses

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including stays at five-star hotels in Miami, Florida, Cannes, France, and Athens, Greece.
Iakovou also invested more than $135,000 on a cryptocurrency exchange for his own investment.
51. Zbravos used investor funds she received to take a luxury vacation in Cabo San
Lucas, Mexico, buy designer handbags, enroll in expensive fitness classes, undergo cosmetic
surgery, and commission a fountain in her family’s village in Greece.  She also benefited
significantly from Iakovou buying her expensive jewelry and dining at high-end restaurants.
Zbravos deposited $934,000 of investor funds in her personal bank and brokerage accounts.

FIRST CLAIM FOR RELIEF
(As to Iakovou and Vika)

Violations of Section 10(b) of the Exchange Act and Rule 10b-5
Thereunder
[15 U.S.C. § 78q(b), 17 C.F.R. § 240.10b-5]

52. The Commission realleges and incorporates by reference paragraphs 1 through
51.
53. By engaging in the acts and conduct alleged above, Iakovou and Vika, directly or
indirectly, in connection with the purchase or sale of securities, by the use of means or
instrumentalities of interstate commerce, or of the mails, or of a facility of a national security
exchange, knowingly or recklessly, (a) employed devices, schemes, or artifices to defraud; (b)
made untrue statements of material fact or omitted to state material facts necessary in order to
make the statements made, in light of the circumstances under which they were made, not
misleading; and (c) engaged in acts, practices, or courses of business which operated or would
operate as a fraud or deceit upon other persons, including purchases and sellers of securities, in
violation of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and subsections (a), (b), and
(c) of Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5(a), (b), and (c)].

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54. Through fraudulent solicitations and statements, Iakovou and Vika entered into
contracts for sale and obtained money from investors who believed they were purchasing pre-
IPO securities from Vika.  By the reasons of the foregoing, Defendants Iakovou and Vika
violated, and unless restrained and enjoined will continue to violate, 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].
SECOND CLAIM FOR RELIEF
(As to Iakovou and Vika)

Section 17(a) of the Securities Act
[15 U.S.C. § 77q(a)]

55. The Commission realleges and incorporates by reference paragraphs 1 through
51.
56. By engaging in the acts and conduct alleged above, Iakovou and Vika directly or
indirectly, in the offer or sale of securities, by use of the means or instruments of transportation
or communication in interstate commerce or by use of the mails, (1) knowingly or recklessly
employed devices, schemes, or artifices to defraud; (2) with negligence, obtained money or
property by means of untrue statements of material fact or by omitting to state material facts
necessary in order to make statements made, in the light of the circumstances under which they
were made, not misleading; and (3) with negligence, engage in transactions, practices or courses
of business which operated or would operate as a fraud or deceit upon the purchasers, in
violation of Section 17(a)(1), (2), and (3) of the Securities Act [15 U.S.C. § 77q(a)(1), (2), and
(3)].
57. Through fraudulent solicitations and statements, Defendants Iakovou and Vika
sold securities and obtained money from investors who believed they were purchasing pre-IPO
securities from Vika.  By the reasons of the foregoing, Defendants Iakovou and Vika violated,

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and unless restrained and enjoined will continue to violate, Section 17(a) of the Securities Act
[15 U.S.C. § 77q(a)].
THIRD CLAIM FOR RELIEF
(As to Zbravos)

Section 17(a)(3) of the Securities Act
[15 U.S.C. § 77q(a)(3)]

58. The Commission realleges and incorporates by reference paragraphs 1 through
51.
59. By engaging in the acts and conduct alleged above, Zbravos directly or indirectly,
in the offer or sale of securities, by use of the means or instruments of transportation or
communication in interstate commerce or by use of the mails, with negligence, engaged in
transactions, practices or courses of business, which operated or would operate as a fraud or
deceit upon the purchasers, in violation of Section 17(a)(3) of the Securities Act [15 U.S.C. §
77q(a)(3)].
60.  For the foregoing reasons, Defendant Zbravos violated, and unless restrained and
enjoined, will continue to violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
PRAYER FOR RELIEF
 WHEREFORE, the SEC respectfully requests that the Court enter a judgment:
I.
Permanently restraining and enjoining Defendants Iakovou and Vika from, directly or
indirectly, violating 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];

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II.
Permanently restraining and enjoining Defendant Zbravos from, directly or indirectly,
violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)];
III.
Permanently enjoining Defendant Iakovou from directly or indirectly, including, but not
limited to, through any entity owned or controlled by him, participating in the issuance,
purchase, offer, or sale of securities in an offering not registered with the Commission, provided,
however, that such injunction shall not prevent them from purchasing or selling securities for his
own personal accounts;
IV.
Ordering Defendants to pay civil penalties pursuant to Section 20(d) of the Securities Act
[15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)];
V.
Ordering Defendants Iakovou and Zbravos to disgorge their ill-gotten gains according to
proof, plus prejudgment interest thereon;
VI.
Barring Iakovou from acting as an officer or director of any public company pursuant to
Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange
Act [15 U.S.C. § 78u(d)(2)]; and
VII.
Granting such other and further relief as this Court may deem just, equitable, or
necessary.

19
 
JURY DEMAND
Plaintiff respectfully demands a trial by jury.
Dated: December 7, 2022   Respectfully submitted,

                                                                        /s/            James            M.            Carlson
                                                                        James            M.            Carlson
                                                                        Supervisory            Trial            Counsel
                                                                        S.D.            Fla.            Court            No.            A5501534
                                                                        100            F            Street,            N.E.
                                                                        Washington,            D.C.            20549
                                                                        (202)            551-3711
                                                                        [email protected]

Counsel for Plaintiff Securities and
Exchange Commission

Of Counsel:
 Michelle I. Bougdanos
 Florida Bar # 20731

      Allison      M.      Rochford
 Ohio Bar # 96343

Counsel for Plaintiff
Securities and Exchange Commission

AO 440 (Rev. 06/12)  Summons in a Civil Action
UNITEDSTATESDISTRICTCOURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v.Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
          Middle District of Georgia
Securities and Exchange Commission
22-CV-194
George Iakovou,
Vika Ventures LLC,
Penelope Zbravos,
George Iakovou
c/o Ira Lee Sorkin, Esq.
Mintz & Gold LLP
600 Third Avenue
25th Floor
New York, NY 10016
U.S. Securities and Exchange Commission
c/o James Carlson
Division of Enforcement
100 F Street, N.E.
Washington, DC 20549 -5030

AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on(date).
uI personally served the summons on the individual at
 (place)
on(date); or
uI left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date), and mailed a copy to the individual’s last known address; or
uI served the summons on
(name of individual), who is
 designated by law to accept service of process on behalf of
(name of organization)
on(date); or
uI returned the summons unexecuted because; or
uOther
(specify):
.
My fees are $for travel and $for services, for a total of $.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
22-CV-194
Geor
ge Iakovou
0.00

AO 440 (Rev. 06/12)  Summons in a Civil Action
UNITEDSTATESDISTRICTCOURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v.Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
          Middle District of Georgia
Securities and Exchange Commission
22-CV-194
George Iakovou,
Vika Ventures LLC,
Penelope Zbravos,
Penelope Zbravos
c/o Charles Cox, Jr., Esq.
484 1st Street, Suite 1
Macon, GA 31201
U.S. Securities and Exchange Commission
c/o James Carlson
Division of Enforcement
100 F Street, N.E.
Washington, DC 20549 -5030

AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on(date).
uI personally served the summons on the individual at
 (place)
on(date); or
uI left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date), and mailed a copy to the individual’s last known address; or
uI served the summons on
(name of individual), who is
 designated by law to accept service of process on behalf of
(name of organization)
on(date); or
uI returned the summons unexecuted because; or
uOther
(specify):
.
My fees are $for travel and $for services, for a total of $.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
22-CV-194
Penelo
pe Zbravos
0.00

AO 440 (Rev. 06/12)  Summons in a Civil Action
UNITEDSTATESDISTRICTCOURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v.Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
          Middle District of Georgia
Securities and Exchange Commission
22-CV-194
George Iakovou,
Vika Ventures LLC,
Penelope Zbravos,
Vika Ventures LLC
c/o Ira Lee Sorkin, Esq.
Mintz & Gold LLP
600 Third Avenue
25th Floor
New York, NY 10016
U.S. Securities and Exchange Commission
c/o James Carlson
Division of Enforcement
100 F Street, N.E.
Washington, DC 20549 -5030

AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on(date).
uI personally served the summons on the individual at
 (place)
on(date); or
uI left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date), and mailed a copy to the individual’s last known address; or
uI served the summons on
(name of individual), who is
 designated by law to accept service of process on behalf of
(name of organization)
on(date); or
uI returned the summons unexecuted because; or
uOther
(specify):
.
My fees are $for travel and $for services, for a total of $.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
22-CV-194
Vika Ventures LLC
0.00

1 
 

UNITED STATES DISTRICT COURT 
FOR THE MIDDLE DISTRICT OF GEORGIA 

COLUMBUS DIVISION 
 

SECURITIES AND EXCHANGE 
COMMISSION, 

  Plaintiff, 

 v.     Civil No.  

GEORGE IAKOVOU,  
VIKA VENTURES LLC, 
PENELOPE ZBRAVOS, 
 
  Defendants. 

 

COMPLAINT 

Plaintiff, United States Securities and Exchange Commission (“SEC” or “Commission”) 

alleges as follows: 

INTRODUCTION 

1. Beginning in late 2019 through the end of 2021, George Iakovou (“Iakovou”) the 

co-founder and Chief Executive Officer (“CEO”) of Vika Ventures LLC (“Vika”), used Vika to 

defraud investors of more than $6.09 million through fraudulent offers and sales of purported 

shares of private companies that might hold an initial public offering (“IPO”).  Iakovou enticed 

investors to Vika by offering for sale hard to acquire securities in desirable pre-IPO companies at 

lower prices than other venture capital firms.  However, at both the time of the solicitation and 

the execution of contracts for sale, Vika did not own the shares and, subsequently never acquired 

them.  Instead of purchasing securities, Iakovou used investor funds to support his lavish 

lifestyle. 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 1 of 19



2 
 

2. Iakovou created documents that he provided to potential and actual investors that 

he knew, or was reckless in not knowing, contained materially false and misleading information 

about Vika’s business model and investment opportunities.  Iakovou told investors via email, by 

telephone, and through text messaging that he, through Vika, would invest their money in pre-

IPO securities of particular companies.  After entering into contracts for sale, investors wired 

money or wrote checks to Vika believing they had purchased specific amounts of pre-IPO 

securities.  However, Iakovou knew Vika did not own the shares he offered for sale at the time of 

the solicitation, and Vika, through Iakovou, subsequently never acquired them.   

3. From late 2019 through June 2021, Penelope Zbravos (“Zbravos”), Vika’s other 

co-founder and then-girlfriend of Iakovou, performed important tasks with respect to the 

company including opening business bank accounts, completing paperwork necessary to form 

the business, and other administrative tasks.  Zbravos was not initially aware of the fraud.  

However, after multiple red flags, by December 2020 Zbravos should have known Vika was a 

fraudulent scheme.  Nevertheless, she continued to perform tasks at Vika that perpetuated the 

scheme including effecting large wire transfers of investor proceeds.  

4. Throughout the fraud, Iakovou provided potential and actual investors with 

formal documentation that Iakovou knew contained materially false or misleading information, 

including private placement memorandums (“PPMs”), welcome letters, and Vika company 

profiles that appeared online.  This documentation informed investors of Vika’s supposed 

process to acquire pre-IPO securities, provided investment information, and background of 

supposed previous deals made by Vika, including a report that depicted Vika as having $80 

million assets under management with ten investments supported by nine employees.  None of 

this information was accurate.   

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 2 of 19



3 
 

5. The Vika website, controlled by Iakovou, contained materially false and 

misleading information that led potential and actual investors to believe that Vika had previously 

participated in major IPOs when, in fact, it had not.  The Vika website also touted participation 

in funding rounds for high-profile private companies.  Vika never participated in any funding 

rounds and never acquired interest in any such securities.  

6. Iakovou enticed investors with fictitious pricing information for the various pre-

IPO securities Vika was purportedly offering.  He told investors they could purchase the various 

pre-IPO securities at very attractive prices because Vika had such strong connections in the 

industry, made sizable deals previously entitling the company to better pricing for future deals, 

and because Vika was a young company, it would offer securities at cost.  As Iakovou and Vika 

never closed a single deal to purchase securities, Iakovou fabricated all the pricing information to 

convince investors to purchase securities through Vika. 

7. When investors’ funds came into Vika, Iakovou and Zbravos effectively split the 

funds three ways amongst themselves and the company, although the vast majority of funds 

retained by Vika were ultimately routed to Iakovou.  

8. Vika never purchased or owned any securities and investors received neither 

securities nor payments.  Instead, Iakovou spent the approximately $3.9 million of proceeds he 

received on his lavish lifestyle including renting private jets, purchasing expensive watches, 

jewelry, and cars, and partying at nightclubs in Miami, New York, France, and Greece.   

9. In total, from 2020 to 2021, Iakovou and Vika raised more than $6.09 million 

from at least 46 investors, through their fraudulent offers and sales of purported pre-IPO 

securities, by means of false and misleading misrepresentations and omissions of material fact, 

as well as deceptive acts and a course of conduct designed to defraud investors.  Zbravos, for her 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 3 of 19



4 
 

participation in the scheme, received more than $2.1 million, some of which she also spent on 

luxury goods, cosmetic surgery, vacations, and commissioning a fountain in Greece.  To date, 

investors have not received any securities, payouts, or return of funds. 

10. As a result of the conduct alleged in this Complaint, Iakovou and Vika violated 

the anti-fraud provisions of the federal securities laws, specifically, the Securities Act of 1933 

(“Securities Act”) Section 17(a) [15 U.S.C § 77q(a)], the Securities Exchange Act of 1934 

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

240.10b-5], and Zbravos violated Securities Act Section 17(a) [15 U.S.C § 77q(a)]. 

11. The Commission requests that the Court enjoin Defendants from further 

violations of the federal securities laws as alleged in this Complaint, and order them to pay a 

monetary penalty based upon these violations.  The Commission also requests that the Court 

order Iakovou and Zbravos to pay disgorgement amounts, and prejudgment interest thereon, 

based upon these violations.  The Commission finally requests a judgment against Iakovou 

barring him from serving as an officer or director of a public company and enjoining him from 

participating in the issuance, purchase, offer, or sale of any security as specified below. 

THE DEFENDANTS 

12. George Iakovou (“Iakovou”), 29, is a resident of New York, NY.  He is a co-

founder of Vika and represented himself to investors as its CEO.  Iakovou invoked his Fifth 

Amendment right against self-incrimination when subpoenaed for documents and testimony by 

the Commission.   

13. Vika Ventures LLC (“Vika”) is a Delaware limited liability company formed by 

Iakovou and Zbravos on November 7, 2019 with its principal place of business in New York, 

NY.  Vika has never registered an offering of securities with the Commission, and its securities 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 4 of 19



5 
 

do not trade on any exchange.  It has never been registered with the Commission as a broker, 

dealer, or investment adviser.   

14. Penelope Zbravos (“Zbravos”), 27, is a resident of Queens, NY. She is a co-

founder of Vika.  Prior to working at Vika, she was a financial analyst at a hospital network in 

New York and prior to Vika, and she had extremely limited experience with the venture capital 

industry.  

JURISDICTION AND VENUE 

15. This Court has jurisdiction over this action pursuant to Sections 20(b), 20(d)(1), 

and 22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1), and 77v(a)], and Sections 21(d) 

and 27 of the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa]. 

16. This Court has personal jurisdiction over Iakovou, Vika, and Zbravos 

(collectively the ”Defendants”), and venue is proper in this District because the Defendants 

engaged in certain acts and transactions constituting violations of the Securities Act and the 

Exchange Act, such as investor solicitations, fraudulent offerings, and communications with 

investors in this District. 

17. In connection with the conduct alleged in this Complaint, specifically the 

solicitation, offer, and sale of pre-IPO securities, the making and dissemination of fraudulent 

statements, and the undertaking of fraudulent acts and practices, Defendants, directly and 

indirectly, singly or in concert with others, made use of the means or instrumentalities of 

interstate commerce, the means or instruments of transportation or communication in interstate 

commerce, such as through email, the telephone, and text messages. 

 

 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 5 of 19



6 
 

DEFENDANTS’ ACTS IN VIOLATION OF THE FEDERAL SECURITIES LAWS 

A. The Creation of Vika Ventures 

18. Iakovou has worked in the financial services sector since 2015 and has 

unsuccessfully attempted to pass the entry-level registered representatives’ exam on no less than 

three occasions.  Since 2018, Iakovou was employed at an exempt reporting private fund advisor 

that primarily conducted deals in the pre-IPO space.  During the summer of 2019, Iakovou asked 

his then-girlfriend, Zbravos, to work as his assistant there.  However, after a series of 

disagreements with the owner of the private fund advisor, including about Iakovou’s failure to 

pay back monies owed to him, in November 2019, Iakovou left the advisor to strike out on his 

own.  Zbravos left with Iakovou. 

19. In fall of 2019, Iakovou and Zbravos founded Vika as a start-up venture capital 

fund offering for sale pre-IPO securities of well-known private companies.  Iakovou held himself 

out as the CEO, served as the face of the company, and communicated with potential and actual 

investors.  Zbravos was Vika’s Finance Manager and performed various duties, primarily back 

office support.  

20. Zbravos assisted Iakovou with the formalities necessary to start the business 

including registering the company with the proper authorities, designing the logo and creating 

the Vika website.  Zbravos also created pitch decks shown to potential investors by Iakovou that 

described Vika as well as the individual investment opportunities.  She created and maintained a 

spreadsheet of investors and their investments. 

21. To attract investors, Iakovou created a series of documents that conveyed 

materially false and misleading information about Vika but appeared genuine to investors.  

Specifically, Iakovou enrolled Vika in an online investing profiling platform that allowed him to 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 6 of 19



7 
 

self-report information and create a Venture Capital Profile (“Vika Profile”) to share with 

potential investors.  Iakovou falsified information about Vika’s net worth, previous investments, 

assets under management, and number of employees and falsely reported that by December 2020 

Vika had more than $80 million assets under management with ten investments supported by 

nine employees, none of which was accurate.  Iakovou sent investors the Vika Profile along with 

reports from this online platform for various private companies Vika was offering of pre-IPO 

securities.  Investors believed this information accurately reflected Vika as a growing and 

dynamic business while Iakovou knew the documents were entirely fabricated. 

22. Iakovou also provided potential investors with PPMs for Vika that he created and 

that contained materially false or misleading information.  For example, Iakovou provided a 

PPM to potential investors that represented that Vika would acquire shares or interests in pre-

IPO companies on behalf of investors.  The PPMs portrayed Vika as a legitimate business, 

however, no securities were ever purchased by Vika.   

23. Vika’s website touted purported previous investments made by Vika in companies 

that had successful IPOs as well as opportunities to invest in much sought after private 

companies anticipating IPOs.  Through its website, Vika held itself out as a venture capital firm 

with prior successes.  In actuality, this information was materially false and misleading as Vika 

had not participated in any previous investments nor did it own any shares in pre-IPO companies. 

24. Prior to investing with Vika, several investors visited Vika’s website and were 

presented with the false and misleading information.  They also viewed hyperlinks to several 

news articles that quote Iakovou in various financial news publications talking about similar 

investment opportunities, all of which created the aura of a highly successful company, leading 

individuals to invest. 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 7 of 19



8 
 

B. Vika’s Fraudulent Offer and Sale of Pre-IPO Securities 

25. Vika received its first investment on January 2, 2020 when the mother of 

Iakovou’s childhood friend invested $105,000 for what she believed was an investment in the 

pre-IPO shares of Company A.  Ultimately, Iakovou and Zbravos transferred or received over 

half of these funds to their personal bank accounts.  From the remaining monies, Zbravos made 

payments to the Vika business credit card for personal expenses incurred by Iakovou.  No shares 

were ever purchased in Company A for the benefit of Vika’s first investor. 

Georgia Investing Group 

26. Vika did not receive another investment for nearly six months until Iakovou 

connected with a former client from his previous employer.  In June 2020, Iakovou pitched Vika 

to this individual who lives in Georgia and is a member of an informal, social investing club that 

shares interesting investment opportunities with its participants.  This individual and a few other 

club participants happened to be pricing the pre-IPO securities of Company B around the time 

Iakovou reached out.  When asked about Company B, Iakovou told this individual that Vika 

could offer it at $200 a share.  Because the other two identified offers came in at $250 and $275 

per share and one investor had a prior positive experience with Iakovou, these three individuals 

each decided to invest with Vika after reviewing the supporting paperwork provided by Iakovou.   

27. When one investor from Georgia asked about the fee structure for the initial 

Company B offer, Iakovou confirmed the investor’s understanding that he could pay an extra 

$1,000 “commission” rather than have Iakovou take the fee out of his investment.  Iakovou told 

the investor: “[t]hat way the full $20,000 would be towards stock.”  However, Iakovou and Vika 

never purchased any shares of Company B on his behalf.  

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 8 of 19



9 
 

28. Several of the Georgia investors shared information about their Vika investments 

with numerous friends and family, who in turn, shared with other friends and family.  By 

offering all of these individuals incredibly enticing deals in additional companies, Vika received 

investments from 34 people in approximately eight private companies.   

29. For example, on March 2, 2021, Iakovou emailed various investors with an 

alleged opportunity in Company C.  Iakovou said via email:  “Just sending out [the Company C] 

docs again.  We have a hard deadline of Wednesday for money in to close the transaction before 

IPO.  Price is set at $6.50.  Your fee structure will be 0% upfront and 10% on the back.”  

Following Iakovou’s solicitation, at least six individuals with prior Vika investments made what 

they thought were investments in Company C.   

30. From June 2020 until early April 2021, Iakovou and Vika defrauded these 34 

individuals of approximately $2.9 million by leading them to believe they were investing in pre-

IPO companies when, in fact, no shares were purchased.  

Other Vika Investors 

31.  On June 23, 2020, a Zbravos family member wired $50,000 to Vika for what she 

believed was an investment in Company A.  On July 3, 2020, Iakovou sent the family member 

and Zbravos the buy confirmation letter for the purchase.  The letter sent via email stated:  

Your total capital contribution of $50,000.00 received on June 23rd, 2020, 
constitutes a 100% membership interest in Series A-9 of the company.  Series A-9 
currently holds 9,090 shares of common stock for [Company A] through an affiliate 
of the Company.  There have been 0% fees deducted on this transaction and your 
capital contribution is $50,000.00 which has been applied to an investment in 9,090 
underlying shares of Company A at a purchase price equivalent to $5.50 per share. 
 

Vika did not hold 9,090 shares of common stock for the family member.  Upon receipt of the 

proceeds, Iakovou directed Zbravos to wire $5,000 to each of their personal accounts.  The 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 9 of 19



10 
 

remaining $40,000 was ultimately used by Iakovou for his lavish personal spending.  No shares 

were purchased on the family member’s behalf.  

32. In January 2021, a group of investors from California and Indiana who pool 

resources to make investments in pre-IPO securities came across the Vika website and other 

internet information regarding Vika while researching potential opportunities to invest in 

Company B and contacted Iakovou.  Iakovou told them Vika was authorized by Company B to 

transact secondary stock sales from employees and investors.  Iakovou also provided them with 

the Vika Profile, a company profile from the online investing platform for Company B, Vika’s 

PPM, and a redacted stock transfer agreement that purported to show Vika holding Company B 

securities.  Given these assurances, on January 27, 2021, these investors wired $2.06 million to 

Vika for what they believed was for 8,000 shares of Company B at $250 a share with an upfront 

fee of 3%.  Iakovou directed Zbravos to wire him $690,000 and transfer $690,000 to herself on 

January 28, 2021.  

33. On February 8, 2021, the group made an additional investment for 1,600 shares of 

Company B and wired $412,000 to Vika.  On February 9, 2021, at Iakovou’s direction, Zbravos 

transferred $150,000 of this money to her personal bank account and wired $150,000 to 

Iakovou’s personal account.  No Company B shares were ever purchased. 

34. After these initial investments, these investors expressed interest in another deal 

with Vika but wanted additional assurances from Iakovou before proceeding.  Iakovou made two 

trips to California to meet with them.  During those trips, he made various promises, including 

that he would file a Form ADV with the Commission, create an online portal to track their 

investments, provide proof of actual ownership of the securities, and provide a notarized and 

unredacted stock transfer agreement.  Although Iakovou had dinner with the investors one night, 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 10 of 19



11 
 

he then postponed meeting with them thereafter.  Iakovou claimed he was sick.  The investors 

only learned by calling his hotel that Iakovou had already traveled back to New York.  Iakovou 

never provided the requested information, and the group did not invest again thereafter.  

35. In June 2021, after Iakovou ceased communicating with them, these four 

investors made contact with both Company B and another company for which Vika had solicited 

an investment.  Both companies told these investors they had no relationship with Vika nor was 

Vika authorized to transact on their behalf. 

 Iakovou’s Additional Lies 

36. In March 2020, a credit card company closed the Vika charge account after 

Iakovou made several unsuccessful payments after charging tens of thousands of dollars in 

personal expenses.  Zbravos used her own funds to pay the balance and sought reimbursement 

from Iakovou.  Iakovou paid Zbravos back with proceeds received from investors.  In fact, 

Iakovou repaid a portion of the balance by instructing Zbravos to take the proceeds of an entire 

investment sent by one individual.  When asked how Vika would give this person his Company 

A shares, Iakovou told Zbravos he had “extra” shares, which was patently false. 

37. To further hide his misconduct, Iakovou took steps to direct the use of fictitious 

wire transfers.  In November 2020, five months after Vika began raising money in earnest, 

Iakovou attempted to make a wire transfer to an entity he told Zbravos was the investment bank 

from which Vika was purchasing the pre-IPO securities.  Since he was not able to make the 

transfer, Iakovou instructed Zbravos to send money via an ACH payment system for the 

purchase of pre-IPO securities.   

38. Despite the volume of investor proceeds coming into Vika for investments, this is 

the first time Iakovou instructed Zbravos to wire funds for the purchase of securities.  During her 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 11 of 19



12 
 

employment with Vika, Zbravos wired more than $1 million to this account without ever 

receiving a single confirmation of monies received or stock purchased.  Unbeknownst to 

Zbravos, the purported investment bank account number Iakovou provided to her belonged to 

one of his friends who ultimately transferred almost all of the funds back to Iakovou.   

39. In January 2021, Zbravos texted Iakovou to say that their friends thought Vika, 

Iakovou, and Zbravos were “scammers & unprofessional” stating, “You’ve been lying to me. . . 

.If you didn’t have the f*!@(* stock why did you do this?”  Iakovou did not reply.  

The Unraveling of Vika 

40. Some investors believed they owned shares of Company A which conducted its 

IPO in September 2020.  Iakovou told the investors who believed they owned pre-IPO securities 

in Company A – including Zbravos’ family member – that there was a six month lock up period 

which would expire at the end of March 2021.  At March’s end, investors began questioning 

Iakovou as to when they would receive their shares.   

41. Iakovou provided a myriad of false or misleading excuses as to why Vika could 

not transfer the shares.  First, Iakovou said there was a long list of investing firms that the 

transfer agent was working through and Vika’s shares were not priorities.  Then, he said the 

transfer agent experienced significant issues and would not be able to send the shares promptly.  

Iakovou sent multiple emails blaming various delays, however, the truth was that Vika never 

purchased the securities.  Thereafter, he ceased communicating with any investors. 

42. Around the time Vika investors were inquiring about Company A shares, Zbravos 

ended her romantic relationship with Iakovou after she uncovered several lies – both personal 

and professional – that he told her.  She formally left the company on June 4, 2021. 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 12 of 19



13 
 

43. After Zbravos’ departure, Iakovou continued to raise approximately $395,000 

funds from additional investors through at least December 2021.  Iakovou directed these 

investors write checks or wire funds to his personal account earmarked for a Vika investment, as 

the existing Vika bank accounts had been closed.   

C. Zbravos Ignored Red Flags 

44. While Iakovou pitched purported investment opportunities to various individuals, 

Zbravos supported the company behind the scenes.  She edited documents such as the PPMs and 

the welcome letters, drafted pitch decks for Iakovou to use with potential and actual investors, 

and maintained the spreadsheet of the investor funds that Vika received.  Given Iakovou’s 

negative financial history of delinquent payments, Zbravos opened bank accounts for Vika and a 

business credit card for Vika using her financial history.  Zbravos had prime responsibility for 

the Vika bank accounts and effected the vast majority of payments and wire transfers. 

45.  In October and November 2020, Zbravos began asking Iakovou questions 

regarding the wire transfers to the investment bank and about his actions and personal spending.  

By December 2020, Zbravos knew or should have known that Iakovou and Vika were 

conducting a fraudulent scheme.  Zbravos ignored these red flags and continued to transfer large 

amounts of investor proceeds into her and Iakovou’s personal bank accounts for several more 

months even in the face of additional warning signs. 

46. For example, on April 3, 2021, Zbravos discovered that Iakovou had faked the 

emails supposedly sent to her from the investment bank.  Zbravos texted Iakovou, stating, “I 

think if you want to save yourself. Stop taking accepting further investments & find whatever 

stock you don't own & end it.”  

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 13 of 19



14 
 

47. Iakovou responded that he had all the stock that was needed, to which Zbravos 

replied: “No you don't, can you stop lying to me for just a second & talk openly. Forget about 

[stock transfer agreements] you don't even have confirmation emails stating the purchase of 

stock.”  Despite these conversations, Zbravos continued to manage the funds in the bank 

accounts from new investors well into the end of May 2021, wiring herself and Iakovou shares of 

the proceeds. 

48. Zbravos formally removed herself from all Vika entities’ operating agreements on 

June 4, 2021.  As she was in the process of leaving Vika, Zbravos transferred $300,000 from 

Vika’s account to her personal account in order to negotiate a buyout from Iakovou, telling him 

she thought it was ‘insulting’ that she would give up her 50 percent ownership stake in Vika for 

nothing. 

49.   Iakovou replied “[it is] insulting that you barely did anything and made $2.5M 

and now you're holding my stock money hostage.”  Ultimately, she and Iakovou agreed she 

would keep $60,000 as her payout.  Between June 4, 2021 and June 10, 2021, the Vika bank 

accounts were emptied of all remaining investor funds and Zbravos closed the accounts. 

D. Iakovou and Zbravos Syphoned Off Investor Funds for Personal Use 

50. Iakovou spent his share of the proceeds lavishly.  He spent more than $680,000 on 

luxury watches and designer jewelry.  Over $173,000 was spent in nightclubs and lounges in 

Miami, New York, France, and Greece.  Iakovou purchased more than $372,000 worth of 

designer goods and spent nearly $220,000 renting or buying luxury cars.  Iakovou dined at high-

end restaurants with some meals costing more than $112,000.  He spent $56,000 on 

entertainment and sports betting while also racking up $70,000 on home furnishings.   Iakovou 

spent nearly $650,000 on private jet travel and another $125,000 on additional travel expenses 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 14 of 19



15 
 

including stays at five-star hotels in Miami, Florida, Cannes, France, and Athens, Greece.  

Iakovou also invested more than $135,000 on a cryptocurrency exchange for his own investment. 

51. Zbravos used investor funds she received to take a luxury vacation in Cabo San 

Lucas, Mexico, buy designer handbags, enroll in expensive fitness classes, undergo cosmetic 

surgery, and commission a fountain in her family’s village in Greece.  She also benefited 

significantly from Iakovou buying her expensive jewelry and dining at high-end restaurants.  

Zbravos deposited $934,000 of investor funds in her personal bank and brokerage accounts.   

FIRST CLAIM FOR RELIEF 
(As to Iakovou and Vika) 

 
Violations of Section 10(b) of the Exchange Act and Rule 10b-5 

Thereunder 
[15 U.S.C. § 78q(b), 17 C.F.R. § 240.10b-5] 

 
52. The Commission realleges and incorporates by reference paragraphs 1 through 

51. 

53. By engaging in the acts and conduct alleged above, Iakovou and Vika, directly or 

indirectly, in connection with the purchase or sale of securities, by the use of means or 

instrumentalities of interstate commerce, or of the mails, or of a facility of a national security 

exchange, knowingly or recklessly, (a) employed devices, schemes, or artifices to defraud; (b) 

made untrue statements of material fact or omitted to state material facts necessary in order to 

make the statements made, in light of the circumstances under which they were made, not 

misleading; and (c) engaged in acts, practices, or courses of business which operated or would 

operate as a fraud or deceit upon other persons, including purchases and sellers of securities, in 

violation of Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and subsections (a), (b), and 

(c) of Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5(a), (b), and (c)].   

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 15 of 19



16 
 

54. Through fraudulent solicitations and statements, Iakovou and Vika entered into 

contracts for sale and obtained money from investors who believed they were purchasing pre-

IPO securities from Vika.  By the reasons of the foregoing, Defendants Iakovou and Vika 

violated, and unless restrained and enjoined will continue to violate, 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]. 

SECOND CLAIM FOR RELIEF 
(As to Iakovou and Vika) 

 
Section 17(a) of the Securities Act 

[15 U.S.C. § 77q(a)] 
 

55. The Commission realleges and incorporates by reference paragraphs 1 through 

51. 

56. By engaging in the acts and conduct alleged above, Iakovou and Vika directly or 

indirectly, in the offer or sale of securities, by use of the means or instruments of transportation 

or communication in interstate commerce or by use of the mails, (1) knowingly or recklessly 

employed devices, schemes, or artifices to defraud; (2) with negligence, obtained money or 

property by means of untrue statements of material fact or by omitting to state material facts 

necessary in order to make statements made, in the light of the circumstances under which they 

were made, not misleading; and (3) with negligence, engage in transactions, practices or courses 

of business which operated or would operate as a fraud or deceit upon the purchasers, in 

violation of Section 17(a)(1), (2), and (3) of the Securities Act [15 U.S.C. § 77q(a)(1), (2), and 

(3)]. 

57. Through fraudulent solicitations and statements, Defendants Iakovou and Vika 

sold securities and obtained money from investors who believed they were purchasing pre-IPO 

securities from Vika.  By the reasons of the foregoing, Defendants Iakovou and Vika violated, 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 16 of 19



17 
 

and unless restrained and enjoined will continue to violate, Section 17(a) of the Securities Act 

[15 U.S.C. § 77q(a)].  

THIRD CLAIM FOR RELIEF 
(As to Zbravos) 

 
Section 17(a)(3) of the Securities Act 

[15 U.S.C. § 77q(a)(3)] 
 
58. The Commission realleges and incorporates by reference paragraphs 1 through 

51. 

59. By engaging in the acts and conduct alleged above, Zbravos directly or indirectly, 

in the offer or sale of securities, by use of the means or instruments of transportation or 

communication in interstate commerce or by use of the mails, with negligence, engaged in 

transactions, practices or courses of business, which operated or would operate as a fraud or 

deceit upon the purchasers, in violation of Section 17(a)(3) of the Securities Act [15 U.S.C. § 

77q(a)(3)].  

60.  For the foregoing reasons, Defendant Zbravos violated, and unless restrained and 

enjoined, will continue to violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

PRAYER FOR RELIEF 

 WHEREFORE, the SEC respectfully requests that the Court enter a judgment: 

I. 

Permanently restraining and enjoining Defendants Iakovou and Vika from, directly or 

indirectly, violating 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]; 

 

 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 17 of 19



18 
 

II. 

Permanently restraining and enjoining Defendant Zbravos from, directly or indirectly, 

violating Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; 

III. 

Permanently enjoining Defendant Iakovou from directly or indirectly, including, but not 

limited to, through any entity owned or controlled by him, participating in the issuance, 

purchase, offer, or sale of securities in an offering not registered with the Commission, provided, 

however, that such injunction shall not prevent them from purchasing or selling securities for his 

own personal accounts; 

IV. 

Ordering Defendants to pay civil penalties pursuant to Section 20(d) of the Securities Act 

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

V. 

Ordering Defendants Iakovou and Zbravos to disgorge their ill-gotten gains according to 

proof, plus prejudgment interest thereon;  

VI. 

Barring Iakovou from acting as an officer or director of any public company pursuant to 

Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange 

Act [15 U.S.C. § 78u(d)(2)]; and  

VII. 

Granting such other and further relief as this Court may deem just, equitable, or 

necessary. 

 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 18 of 19



19 
 

JURY DEMAND 

Plaintiff respectfully demands a trial by jury. 

Dated: December 7, 2022   Respectfully submitted, 

 

      /s/ James M. Carlson    
      James M. Carlson 
      Supervisory Trial Counsel 
      S.D. Fla. Court No. A5501534 
      100 F Street, N.E. 
      Washington, D.C. 20549 
      (202) 551-3711  
      [email protected]  
 

Counsel for Plaintiff Securities and 
Exchange Commission 

 
Of Counsel: 
 Michelle I. Bougdanos 
 Florida Bar # 20731 

 
 Allison M. Rochford 
 Ohio Bar # 96343 

 
Counsel for Plaintiff 
Securities and Exchange Commission 

 

Case 4:22-cv-00194-CDL   Document 1   Filed 12/07/22   Page 19 of 19



Case 4:22-cv-00194-CDL   Document 1-1   Filed 12/07/22   Page 1 of 1



AO 440 (Rev. 06/12)  Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

__________ District of __________ 

)
)
)
)
)
)
)
)
)
)
)
)

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. 
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

          Middle District of Georgia

Securities and Exchange Commission

22-CV-194
George Iakovou, 

Vika Ventures LLC,
Penelope Zbravos,

George Iakovou
c/o Ira Lee Sorkin, Esq.
Mintz & Gold LLP
600 Third Avenue
25th Floor
New York, NY 10016

U.S. Securities and Exchange Commission
c/o James Carlson
Division of Enforcement
100 F Street, N.E.
Washington, DC 20549 -5030

Case 4:22-cv-00194-CDL   Document 1-2   Filed 12/07/22   Page 1 of 2



AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

I served the summons on (name of individual) , who is

 designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

22-CV-194

George Iakovou

0.00

Case 4:22-cv-00194-CDL   Document 1-2   Filed 12/07/22   Page 2 of 2



AO 440 (Rev. 06/12)  Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

__________ District of __________ 

)
)
)
)
)
)
)
)
)
)
)
)

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. 
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

          Middle District of Georgia

Securities and Exchange Commission

22-CV-194
George Iakovou, 

Vika Ventures LLC,
Penelope Zbravos,

Penelope Zbravos
c/o Charles Cox, Jr., Esq.
484 1st Street, Suite 1
Macon, GA 31201

U.S. Securities and Exchange Commission
c/o James Carlson
Division of Enforcement
100 F Street, N.E.
Washington, DC 20549 -5030

Case 4:22-cv-00194-CDL   Document 1-3   Filed 12/07/22   Page 1 of 2



AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

I served the summons on (name of individual) , who is

 designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

22-CV-194

Penelope Zbravos

0.00

Case 4:22-cv-00194-CDL   Document 1-3   Filed 12/07/22   Page 2 of 2



AO 440 (Rev. 06/12)  Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the

__________ District of __________ 

)
)
)
)
)
)
)
)
)
)
)
)

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant’s name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure.  The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. 
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

          Middle District of Georgia

Securities and Exchange Commission

22-CV-194
George Iakovou, 

Vika Ventures LLC,
Penelope Zbravos,

Vika Ventures LLC
c/o Ira Lee Sorkin, Esq.
Mintz & Gold LLP
600 Third Avenue
25th Floor
New York, NY 10016

U.S. Securities and Exchange Commission
c/o James Carlson
Division of Enforcement
100 F Street, N.E.
Washington, DC 20549 -5030

Case 4:22-cv-00194-CDL   Document 1-4   Filed 12/07/22   Page 1 of 2



AO 440 (Rev. 06/12)  Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for (name of individual and title, if any)

was received by me on (date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individual’s residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individual’s last known address; or

I served the summons on (name of individual) , who is

 designated by law to accept service of process on behalf of (name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other (specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc:

22-CV-194

Vika Ventures LLC

0.00

Case 4:22-cv-00194-CDL   Document 1-4   Filed 12/07/22   Page 2 of 2