SEC v. PROSPER BEYOND MOORE; and PROSPERITY INVESTMENTS & SOLUTIONS, LLC f/k/a PROSPERITY, INVESTMENTS & LENDING, LLC, No. 1:24-cv-00242-SCJ, Northern District of Georgia (Jan. 18, 2024) — Complaint

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

SECURITIES AND EXCHANGE
COMMISSION,

                            Plaintiff,
 Civil Action File No.
v.

PROSPER BEYOND MOORE,
PROSPERITY INVESTMENTS &
SOLUTIONS, LLC f/k/a PROSPERITY,
INVESTMENTS & LENDING, LLC,

Defendants.
JURY DEMAND

COMPLAINT

Plaintiff Securities and Exchange Commission (“Commission”) alleges as
follows:
SUMMARY
1. From approximately October 2021 through March 2023, Prosperity
Investments & Solutions, LLC (“Prosperity”) and its organizer, Prosper E. Beyond
Moore (“Moore”) raised more than $1.4 million from over 60 individual investors.
2. Defendants touted Prosperity as a large and reputable financial
organization that could provide investors with profits of 50% each month through a
diverse range of investments.

3. Contrary to these representations, Defendants used money received
from investors to make payments to other investors and to pay personal expenses.
4. To induce additional investments and retain investors, Defendants
fabricated false account statements that they provided to existing investors showing
weekly rates of return exceeding 10% and monthly rates of return exceeding 40%.
5. Defendants knew that the money invested was not being used to
generate the returns reflected on the account statements.
6. In fact, Prosperity did not actually invest most of the funds it received
from investors.
7. To the extent that Prosperity did use investor funds to make
investments, those investments generated losses of more than $67,000.
8. Many of the individuals who invested with Prosperity were members of
Moore’s church.
9. Other investors learned of Moore’s offerings through religious
affiliations in the Nigerian-American community.

VIOLATIONS
10. By the conduct described herein, Moore and Prosperity have engaged
and, unless restrained and enjoined by this Court, will continue to engage in acts and
practices that constitute and will constitute violations of Sections 5(a), 5(c), and 17(a)
of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a), 77e(c), and

77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”)
[15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-
5].
JURISDICTION AND VENUE
11. The Commission brings this action pursuant to the authority conferred
upon it by Sections 20(b) and 20(d) of the Securities Act [15 U.S.C. §§ 77t(b) and
77t(d)] and Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)].
12. This Court has jurisdiction over this action pursuant to Section 22(a)
of the Securities Act [15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act
[15 U.S.C. § 78aa(a)].
13. In connection with the transactions, acts, practices, and courses of
business described in this Complaint, Defendants, directly and indirectly, have
made use of the means or instrumentalities of interstate commerce, of the mails,
and/or of the means and instruments of transportation or communication in
interstate commerce.
14. Venue is proper in this district as all defendants reside, operate, or are
located in this district.

FACTS
Defendants
15. Prosper E Beyond Moore, age 27, is a resident of Loganville,
Georgia.  During the relevant period, Moore conducted business as Prosperity
Investment & Solutions, LLC, which was formerly known as Prosperity,
Investments & Lending, LLC.  Moore does not hold any professional licenses and
has never been associated with any Commission registered broker-dealer or
investment adviser.
16. Moore has not received any financial or investment education from
any credentialed university or institution, nor does he have any experience working
with any company in the financial or investment industry.
17. Prosperity Investments & Solutions, LLC is a Georgia corporation
with its principal place of business in Winder, Georgia.  On October 20, 2021,
Moore incorporated Prosperity.  Moore is Prosperity’s registered agent and
organizer.  Moore is in charge of all business operations and decisions of
Prosperity.  Prior to August 26, 2022, Prosperity was operated under the name
Prosperity, Investments & Lending, LLC.

Defendants’ Solicitation Efforts
18. Prosperity was marketed to prospective investors through social media
accounts and a website, the content of which was created, controlled, and
authorized by Moore.
19. Defendants focused their marketing efforts on individuals, like Moore,
who identified as Christian and were of Nigerian descent.
20. Many of Defendants’ investors were members of the church that
Moore attended or learned of Moore’s offerings through religious networks.
21. For example, one investor, a preacher, learned of Prosperity through
an online group called “Jesus Online.”
22. Defendants capitalized on shared religious beliefs to attract and retain
investors.
23. Some investor communications from Defendants contained biblical
quotes and assurances that Defendants were “trusting God that everything will be
better than it was before.”
24. The website soliciting investors described Prosperity as an “exclusive
investing and lending platform.”
25. The website told potential investors that Prosperity “provides up to
50% profit of your investment MONTHLY,” and “provides you with a new source
of passive income, giving you more time to do what you love.”

26. Prosperity’s website allowed investors to create a client account and
offered them the opportunity to invest a minimum amount of $5,000 in one of three
programs.
27. The “Silver Investment,” with a lock-in period of one month, offered
investors up to 50% profit to be delivered at the end of each 30-day investment
period, and an investment fee of 10% to be deducted from the investor’s total
profits.
28. The “Gold Investment,” with a lock-in period of three months, offered
investors up to 50% profit to be delivered at the end of each 30-day investment
period, and an investment fee of 7% to be deducted from the investor’s total
profits.
29. The “Platinum Investment,” with a lock-in period of twelve months,
offered investors up to 50% profit to be delivered at the end of each 30-day
investment period, and an investment fee of 5% to be deducted from the investor’s
total profits.
30. A “buy it now” button on Prosperity’s website provided a link with
instructions for investors to send funds.
31. In many instances, Defendants sent a confirmation email with
payment instructions to investors who had submitted a website application for the
program.

The Investment Contracts
32. Once Defendants had received the investor’s funds, Defendants issued
an “Investment Agreement Contract” to each investor through the website and
email.
33. The agreement provided that Prosperity could “use any and all
capital/funds/money in whatever/any way [Prosperity] see[s] fit; that includes but
are not exclusive to trading/investing into Stocks, ETFs, Options, Futures, Mutual
Funds, Real Estate, Businesses, Organizations, Entities, and etc.”
34. The agreement also stated that the investor would “not have access to
their capital/funds/money” during the selected investment period.
35. Pursuant to the agreement, Prosperity would “provide ... weekly
investment profit growth updates that correspond to the Investment Programs
and/or Services” provided by Prosperity and the investor could “expect delivery of
funds/capital/profits within 5-10 business days after the last day of [the investor’s]
pre-established investment/lending period.
36. The agreement also provided that Prosperity would be entitled to a
“specified investment fee percentage of profit,” which it would deduct from the
investor’s profits and set forth that Prosperity would “deliver up to 50% (percent)
return on the [investor’s] investment/capital.”

37. Between October 2021 and September 2022, Prosperity collected cash
investments exceeding $1.4 million from over 60 individual investors, with most
investors selecting the Gold Investment program.
38. Investors’ funds were pooled and deposited into accounts controlled
by Defendants.
39. Prosperity filed no registration statement with the Commission with
respect to any of its securities offerings.
40. Defendants did not know or verify the financial circumstances of the
investors to which they sold securities.
41. The information collected from prospective investors included only
their names, email and mailing addresses, and desired investment amounts.
42. Defendants took no steps to determine whether any of the investors
were accredited investors.
43. Many of the investors to which Defendants sold securities were
unaccredited.
Defendants’ Fraudulent Investment Scheme
A. False Statements to Prospective Investors
44. In their promotional materials, Defendants created the false
impression that Prosperity was a large and reputable financial organization with a
diverse portfolio of highly profitable investment activities.

45. For example, videos posted on Prosperity’s Instagram and Facebook
pages proclaimed that an “elite team of investors” from a “certified U.S. financial
institution” would apply their expertise to generate significant profits for investors.
46. Defendants also informed prospective investors that Prosperity held a
“diverse range of investments that include[d] but [we]re not exclusive to
trading/investing into Stocks, ETFs, Options, Futures, Mutual Funds, Real Estate,
Businesses, Organizations, Entities, products, and etc.”
47. Despite these representations, Moore was the only person managing
the investment funds, and he had no formal training or experience in the securities
industry.
48. Defendants transferred some investor funds to brokerage accounts
opened in Moore’s name and over which he had exclusive trading authority, and
traded stocks in those accounts.
49. The trades that Moore executed were largely unsuccessful, resulting in
total losses of at least $67,000.
50. Defendants did not make any other investments with investor funds.
51. Defendants held no other assets that could generate returns for
investors.
52. In fact, Defendants routed some investor funds to make personal
payments on behalf of Moore.

53. To keep the scheme afloat, Defendants took out a loan from an online
lender to honor existing investors’ redemption requests.
54. Defendants also used new investor funds to pay existing investors.
55. Nevertheless, Defendants continued to solicit funds from new
investors by advertising the claim that “Prosperity’s elite team of investors will
work diligently to invest your capital and bring you back 50% return every
month.”
B. Fabricated Performance Statements
56. To maintain the appearance that Defendants were investing in
securities and making profits, they generated recurring statements and
“congratulations” letters, which they sent to investors, via email and U.S. mail,
showing the purported growth of each investor’s capital.
57. These statements and letters frequently showed weekly rates of return
exceeding 10% and monthly rates of return exceeding 40%.
58. The information in the letters and weekly and monthly reports were
false.
59. Apart from the investor’s initial capital contribution, the investment
growth percentages depicted in those documents were fabricated.
60. Defendants provided these recurring email “updates” to investors
touting the profitability of the investments that Prosperity was making even during

time periods when Defendants made no profits and conducted no investment
activities.
61. For example, several investors were told that they had earned 45%
returns between May 2, 2022, and June 3, 2022.
62. During that time period, Defendants did not initiate any transactions
in Moore’s brokerage accounts, and the beginning and ending balances in those
accounts did not change.
63. Defendants knew that the investors would rely on the fabricated
statements to reinvest their alleged profits with Prosperity.
64. Under the terms of the investment contract, investors could take their
principal, profits, or both, minus Prosperity’s fee, at the end of each investment
period.
65. Alternatively, investors could elect to reinvest their profits.
66. Several investors increased their investment or authorized
reinvestment after receiving the fabricated performance statements.
C. False Excuses in Response to Investor Complaints
67. Beginning in mid-2022, Defendants were unable to pay investors
whose contract terms had ended and who sought a return of their capital.
68. Nevertheless, Defendants continued to solicit new investors.

69. When soliciting new investors, Defendants did not tell those potential
investors that Prosperity was unable to fulfill the terms of existing investment
contracts.
70. Defendants also did not tell existing investors of their inability to
return capital at the end of the investment contract term.
71. To generate the funding necessary to return investor capital,
Defendants obtained a loan of $50,000 from an online lender.
72. Defendants did not disclose the existence of this loan to prospective
investors.
73. Prosperity’s website and social media accounts continued to represent
that investors could expect monthly returns of up to 50%.
74. Defendants also continued to issue fictional performance statements to
existing investors without disclosing the loan or Prosperity’s failure to generate
any revenue.
75. To explain delayed payments to concerned investors, Defendants
fabricated a variety of excuses.
76. Defendants told some investors that the delay was due to lengthy
closures of financial institutions due to public holidays.
77. Defendants also told investors that the delay was due to their efforts to
grow Prosperity into a larger and more profitable investment company.

78. Specifically, Defendants told investors that their need to hire
additional personnel and the purported burdens of complying with governing rules
and regulations affected Prosperity’s ability to honor redemption requests.
79. Defendants sent emails to investors stating that Prosperity was “in the
process of hiring more accountants to handle the increased demand of clients and
transactions,” had “recently added new customer services representatives to [its]
team” to field customer calls, and would “follow up with the account managers” to
explain changes to its investment plans.
80. In addition, the emails assured investors that the “Accounting and
Treasury Departments” and an “Executive Board” were working diligently to
deliver profit checks.
81. In fact, Moore was conducting all of Prosperity’s business operations,
and never hired additional personnel.
D. Targeting of Christian and Nigerian Communities
82. The investor pool largely comprised investors who identified as
Christian and of Nigerian descent.
83. Many of the Defendants’ investors were members of Moore’s church
or learned of Moore’s offerings through religious networks.

84. For example, one investor, a preacher, explained that he and two other
investors, also preachers, attended the same high school in Nigeria and learned of
Prosperity through an online group called “Jesus Online.”
85. Moreover, the Defendants appear to have capitalized on shared
religious beliefs to attract and retain investors.
86. Some investor communications from Moore contained biblical quotes
and assurances that the Defendants were “trusting God that everything will be
better than it was before.”
COUNT I

Violations of Sections 5(a) and 5(c) of the Securities Act
[15 U.S.C. §§ 77e(a) and 77e(c)]

87. Paragraphs 1 through 86 are hereby realleged and are incorporated
herein by reference.
88. Defendants offered and sold securities, including promissory notes.
89. Defendants used interstate transportation, communication or mails in
connection with the offer and sale of securities.
90. At the time of the offer and sale of securities, no registration statement
was in effect as to the securities offered and sold.

91. By reason of the foregoing, Defendants have violated and, unless
enjoined, will continue to violate Sections 5(a) and 5(c) of the Securities Act [15
U.S.C. §§ 77e(a) and 77e(c)].
COUNT II

Violations of Section 17(a)(1) of the Securities Act
[15 U.S.C. § 77q(a)(1)]

92. The Commission realleges paragraphs 1 through 86 above.
93. Between October 2021 and March 2023, Defendants in the offer and
sale of the securities described herein, by the use of means and instruments of
transportation and communication in interstate commerce and by use of the mails,
directly and indirectly, employed devices, schemes and artifices to defraud
purchasers of such securities, all as more particularly described above.
94. Defendants knowingly, intentionally, and/or recklessly engaged in the
aforementioned devices, schemes and artifices to defraud.
95. While engaging in the course of conduct described above, Defendants
acted with scienter, that is, with an intent to deceive, manipulate or defraud or with a
severe reckless disregard for the truth.
96. By reason of the foregoing, Defendants directly and indirectly, have
violated and, unless enjoined, will continue to violate Section 17(a)(1) of the
Securities Act [15 U.S.C. § 77q(a)(1)].

COUNT III

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

97. Paragraphs 1 through 86 are hereby realleged and are incorporated by
reference.
98. Between October 2021 and March 2023, Defendants, in the offer and
sale of securities described herein, by use of means and instruments of
transportation and communication in interstate commerce and by use of the mails,
directly and indirectly:
a. obtained money and property by means of untrue statements of
material fact and omissions 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
b. engaged in transactions, practices and courses of business
which would and did operate as a fraud and deceit upon the
purchasers of such securities, all as more particularly described above.
99. Defendants, directly and indirectly, have violated and, unless enjoined,
will continue to violate Sections 17(a)(2) and 17(a)(3) of the Securities Act [15
U.S.C. §§ 77q(a)(2) and 77q(a)(3)].

COUNT IV

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

100. The Commission realleges paragraphs 1 through 86 above.
101. Between October 2021 and March 2023, Defendants, in connection
with the purchase and sale of securities described herein, by the use of the means and
instrumentalities of interstate commerce and by use of the mails, directly and
indirectly:
                    a.          employed          devices,          schemes, and artifices to defraud;
 b. made untrue statements of material facts and 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, and courses of business which would
and did operate as a fraud and deceit upon the purchasers of such
securities,
all as more particularly described above.
102. Defendants knowingly, intentionally, and/or recklessly engaged in the
aforementioned devices, schemes and artifices to defraud, made untrue statements of
material facts and omitted to state material facts, and engaged in fraudulent acts,
practices and courses of business.  In engaging in such conduct, Defendants acted

with scienter, that is, with an intent to deceive, manipulate or defraud or with a severe
reckless disregard for the truth.
103. By reason of the foregoing, Defendants, directly and indirectly, have
violated and, unless 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].
PRAYER FOR RELIEF
          WHEREFORE,          the          Commission          respectfully prays for:
I.
 Permanent injunctions enjoining Defendants and their officers, agents,
servants, employees, and attorneys from violating, directly or indirectly, Sections
5(a), 5(c) and 17(a) of the Securities Act [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)],
and 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].
II.
 A permanent injunction enjoining Defendant Moore from directly or indirectly
participating in the issuance, purchase, offer, or sale of any security, provided that
such injunction shall not prevent Moore from purchasing or selling securities listed
on a national securities exchange for his own personal account.

III.
 An order, pursuant to Sections 21(d)(5) and (7) of the Exchange Act [15
U.S.C. §§ 78(u)(d)(5), (7)] and this Court’s inherent equitable authority, requiring
disgorgement by Defendants of all ill-gotten gains or unjust enrichment with
prejudgment interest, to effect the remedial purposes of the federal securities laws.
IV.
 An order pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)]
and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] imposing civil
penalties against Defendants.
V.
 An order pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C.
§ 78u(d)(2)] and/or Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)]
prohibiting Defendant Moore from acting as an officer or director of any issuer that
has a class of securities registered pursuant to Section 12 of the Exchange Act [15
U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the
Exchange Act [15 U.S.C. § 78o(d)].

VI.
 Such other and further relief as this Court may deem just, equitable, and
appropriate in connection with the enforcement of the federal securities laws and
for the protection of investors.

JURY TRIAL DEMAND
 The Commission hereby demands a trial by jury as to all issues that may be
so tried.
Respectfully submitted this 18th day of January, 2024,
/s/ Kristin W. Murnahan
M. Graham Loomis
Regional Trial Counsel
United States Securities & Exchange Commission
950 E. Paces Ferry Road NE, Suite 900
Atlanta, GA 30326
404-842-7622
Georgia Bar No. 457868
[email protected]

Kristin W. Murnahan
Senior Trial Counsel
United States Securities & Exchange Commission
950 E. Paces Ferry Road NE, Suite 900
Atlanta, GA 30326
404-842-7655
Georgia Bar No. 759054
[email protected]

COUNSEL FOR PLAINTIFF

UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF GEORGIA 

ATLANTA DIVISION 
 
  
SECURITIES AND EXCHANGE 
COMMISSION, 

 

  
                            Plaintiff,  
 Civil Action File No. 

v.         
         
PROSPER BEYOND MOORE, 
PROSPERITY INVESTMENTS & 
SOLUTIONS, LLC f/k/a PROSPERITY, 
INVESTMENTS & LENDING, LLC, 
 

Defendants. 

JURY DEMAND 

 
COMPLAINT 

 
Plaintiff Securities and Exchange Commission (“Commission”) alleges as 

follows: 

SUMMARY 

1. From approximately October 2021 through March 2023, Prosperity 

Investments & Solutions, LLC (“Prosperity”) and its organizer, Prosper E. Beyond 

Moore (“Moore”) raised more than $1.4 million from over 60 individual investors. 

2. Defendants touted Prosperity as a large and reputable financial 

organization that could provide investors with profits of 50% each month through a 

diverse range of investments.   

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3. Contrary to these representations, Defendants used money received 

from investors to make payments to other investors and to pay personal expenses. 

4. To induce additional investments and retain investors, Defendants 

fabricated false account statements that they provided to existing investors showing 

weekly rates of return exceeding 10% and monthly rates of return exceeding 40%. 

5. Defendants knew that the money invested was not being used to 

generate the returns reflected on the account statements. 

6. In fact, Prosperity did not actually invest most of the funds it received 

from investors. 

7. To the extent that Prosperity did use investor funds to make 

investments, those investments generated losses of more than $67,000. 

8. Many of the individuals who invested with Prosperity were members of 

Moore’s church. 

9. Other investors learned of Moore’s offerings through religious 

affiliations in the Nigerian-American community. 

VIOLATIONS 

10. By the conduct described herein, Moore and Prosperity have engaged 

and, unless restrained and enjoined by this Court, will continue to engage in acts and 

practices that constitute and will constitute violations of Sections 5(a), 5(c), and 17(a) 

of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a), 77e(c), and 

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77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) 

[15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-

5]. 

JURISDICTION AND VENUE 

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

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

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

12. This Court has jurisdiction over this action pursuant to Section 22(a) 

of the Securities Act [15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act 

[15 U.S.C. § 78aa(a)].   

13. In connection with the transactions, acts, practices, and courses of 

business described in this Complaint, Defendants, directly and indirectly, have 

made use of the means or instrumentalities of interstate commerce, of the mails, 

and/or of the means and instruments of transportation or communication in 

interstate commerce. 

14. Venue is proper in this district as all defendants reside, operate, or are 

located in this district. 

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FACTS  

Defendants 

15. Prosper E Beyond Moore, age 27, is a resident of Loganville, 

Georgia.  During the relevant period, Moore conducted business as Prosperity 

Investment & Solutions, LLC, which was formerly known as Prosperity, 

Investments & Lending, LLC.  Moore does not hold any professional licenses and 

has never been associated with any Commission registered broker-dealer or 

investment adviser. 

16. Moore has not received any financial or investment education from 

any credentialed university or institution, nor does he have any experience working 

with any company in the financial or investment industry. 

17. Prosperity Investments & Solutions, LLC is a Georgia corporation 

with its principal place of business in Winder, Georgia.  On October 20, 2021, 

Moore incorporated Prosperity.  Moore is Prosperity’s registered agent and 

organizer.  Moore is in charge of all business operations and decisions of 

Prosperity.  Prior to August 26, 2022, Prosperity was operated under the name 

Prosperity, Investments & Lending, LLC.   

 

 

 

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Defendants’ Solicitation Efforts 

18. Prosperity was marketed to prospective investors through social media 

accounts and a website, the content of which was created, controlled, and 

authorized by Moore.   

19. Defendants focused their marketing efforts on individuals, like Moore, 

who identified as Christian and were of Nigerian descent. 

20. Many of Defendants’ investors were members of the church that 

Moore attended or learned of Moore’s offerings through religious networks.   

21. For example, one investor, a preacher, learned of Prosperity through 

an online group called “Jesus Online.”   

22. Defendants capitalized on shared religious beliefs to attract and retain 

investors.   

23. Some investor communications from Defendants contained biblical 

quotes and assurances that Defendants were “trusting God that everything will be 

better than it was before.” 

24. The website soliciting investors described Prosperity as an “exclusive 

investing and lending platform.”  

25. The website told potential investors that Prosperity “provides up to 

50% profit of your investment MONTHLY,” and “provides you with a new source 

of passive income, giving you more time to do what you love.”   

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26. Prosperity’s website allowed investors to create a client account and 

offered them the opportunity to invest a minimum amount of $5,000 in one of three 

programs.  

27. The “Silver Investment,” with a lock-in period of one month, offered 

investors up to 50% profit to be delivered at the end of each 30-day investment 

period, and an investment fee of 10% to be deducted from the investor’s total 

profits. 

28. The “Gold Investment,” with a lock-in period of three months, offered 

investors up to 50% profit to be delivered at the end of each 30-day investment 

period, and an investment fee of 7% to be deducted from the investor’s total 

profits. 

29. The “Platinum Investment,” with a lock-in period of twelve months, 

offered investors up to 50% profit to be delivered at the end of each 30-day 

investment period, and an investment fee of 5% to be deducted from the investor’s 

total profits. 

30. A “buy it now” button on Prosperity’s website provided a link with 

instructions for investors to send funds. 

31. In many instances, Defendants sent a confirmation email with 

payment instructions to investors who had submitted a website application for the 

program.  

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The Investment Contracts 

32. Once Defendants had received the investor’s funds, Defendants issued 

an “Investment Agreement Contract” to each investor through the website and 

email.  

33. The agreement provided that Prosperity could “use any and all 

capital/funds/money in whatever/any way [Prosperity] see[s] fit; that includes but 

are not exclusive to trading/investing into Stocks, ETFs, Options, Futures, Mutual 

Funds, Real Estate, Businesses, Organizations, Entities, and etc.”  

34. The agreement also stated that the investor would “not have access to 

their capital/funds/money” during the selected investment period. 

35. Pursuant to the agreement, Prosperity would “provide … weekly 

investment profit growth updates that correspond to the Investment Programs 

and/or Services” provided by Prosperity and the investor could “expect delivery of 

funds/capital/profits within 5-10 business days after the last day of [the investor’s] 

pre-established investment/lending period. 

36. The agreement also provided that Prosperity would be entitled to a 

“specified investment fee percentage of profit,” which it would deduct from the 

investor’s profits and set forth that Prosperity would “deliver up to 50% (percent) 

return on the [investor’s] investment/capital.” 

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37. Between October 2021 and September 2022, Prosperity collected cash 

investments exceeding $1.4 million from over 60 individual investors, with most 

investors selecting the Gold Investment program.   

38. Investors’ funds were pooled and deposited into accounts controlled 

by Defendants. 

39. Prosperity filed no registration statement with the Commission with 

respect to any of its securities offerings. 

40. Defendants did not know or verify the financial circumstances of the 

investors to which they sold securities.     

41. The information collected from prospective investors included only 

their names, email and mailing addresses, and desired investment amounts. 

42. Defendants took no steps to determine whether any of the investors 

were accredited investors. 

43. Many of the investors to which Defendants sold securities were 

unaccredited. 

Defendants’ Fraudulent Investment Scheme 

A. False Statements to Prospective Investors 

44. In their promotional materials, Defendants created the false 

impression that Prosperity was a large and reputable financial organization with a 

diverse portfolio of highly profitable investment activities. 

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45. For example, videos posted on Prosperity’s Instagram and Facebook 

pages proclaimed that an “elite team of investors” from a “certified U.S. financial 

institution” would apply their expertise to generate significant profits for investors.   

46. Defendants also informed prospective investors that Prosperity held a 

“diverse range of investments that include[d] but [we]re not exclusive to 

trading/investing into Stocks, ETFs, Options, Futures, Mutual Funds, Real Estate, 

Businesses, Organizations, Entities, products, and etc.” 

47. Despite these representations, Moore was the only person managing 

the investment funds, and he had no formal training or experience in the securities 

industry. 

48. Defendants transferred some investor funds to brokerage accounts 

opened in Moore’s name and over which he had exclusive trading authority, and 

traded stocks in those accounts.   

49. The trades that Moore executed were largely unsuccessful, resulting in 

total losses of at least $67,000.  

50. Defendants did not make any other investments with investor funds.   

51. Defendants held no other assets that could generate returns for 

investors. 

52. In fact, Defendants routed some investor funds to make personal 

payments on behalf of Moore. 

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53. To keep the scheme afloat, Defendants took out a loan from an online 

lender to honor existing investors’ redemption requests. 

54. Defendants also used new investor funds to pay existing investors. 

55. Nevertheless, Defendants continued to solicit funds from new 

investors by advertising the claim that “Prosperity’s elite team of investors will 

work diligently to invest your capital and bring you back 50% return every 

month.” 

B. Fabricated Performance Statements 

56. To maintain the appearance that Defendants were investing in 

securities and making profits, they generated recurring statements and 

“congratulations” letters, which they sent to investors, via email and U.S. mail, 

showing the purported growth of each investor’s capital.   

57. These statements and letters frequently showed weekly rates of return 

exceeding 10% and monthly rates of return exceeding 40%.   

58. The information in the letters and weekly and monthly reports were 

false. 

59. Apart from the investor’s initial capital contribution, the investment 

growth percentages depicted in those documents were fabricated.   

60. Defendants provided these recurring email “updates” to investors 

touting the profitability of the investments that Prosperity was making even during 

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time periods when Defendants made no profits and conducted no investment 

activities.   

61. For example, several investors were told that they had earned 45% 

returns between May 2, 2022, and June 3, 2022. 

62. During that time period, Defendants did not initiate any transactions 

in Moore’s brokerage accounts, and the beginning and ending balances in those 

accounts did not change. 

63. Defendants knew that the investors would rely on the fabricated 

statements to reinvest their alleged profits with Prosperity. 

64. Under the terms of the investment contract, investors could take their 

principal, profits, or both, minus Prosperity’s fee, at the end of each investment 

period. 

65. Alternatively, investors could elect to reinvest their profits. 

66. Several investors increased their investment or authorized 

reinvestment after receiving the fabricated performance statements. 

C. False Excuses in Response to Investor Complaints 

67. Beginning in mid-2022, Defendants were unable to pay investors 

whose contract terms had ended and who sought a return of their capital. 

68. Nevertheless, Defendants continued to solicit new investors.   

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69. When soliciting new investors, Defendants did not tell those potential 

investors that Prosperity was unable to fulfill the terms of existing investment 

contracts. 

70. Defendants also did not tell existing investors of their inability to 

return capital at the end of the investment contract term. 

71. To generate the funding necessary to return investor capital, 

Defendants obtained a loan of $50,000 from an online lender. 

72. Defendants did not disclose the existence of this loan to prospective 

investors. 

73. Prosperity’s website and social media accounts continued to represent 

that investors could expect monthly returns of up to 50%. 

74. Defendants also continued to issue fictional performance statements to 

existing investors without disclosing the loan or Prosperity’s failure to generate 

any revenue. 

75. To explain delayed payments to concerned investors, Defendants 

fabricated a variety of excuses. 

76. Defendants told some investors that the delay was due to lengthy 

closures of financial institutions due to public holidays. 

77. Defendants also told investors that the delay was due to their efforts to 

grow Prosperity into a larger and more profitable investment company. 

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78. Specifically, Defendants told investors that their need to hire 

additional personnel and the purported burdens of complying with governing rules 

and regulations affected Prosperity’s ability to honor redemption requests.   

79. Defendants sent emails to investors stating that Prosperity was “in the 

process of hiring more accountants to handle the increased demand of clients and 

transactions,” had “recently added new customer services representatives to [its] 

team” to field customer calls, and would “follow up with the account managers” to 

explain changes to its investment plans.   

80. In addition, the emails assured investors that the “Accounting and 

Treasury Departments” and an “Executive Board” were working diligently to 

deliver profit checks.   

81. In fact, Moore was conducting all of Prosperity’s business operations, 

and never hired additional personnel. 

D. Targeting of Christian and Nigerian Communities 

82. The investor pool largely comprised investors who identified as 

Christian and of Nigerian descent. 

83. Many of the Defendants’ investors were members of Moore’s church 

or learned of Moore’s offerings through religious networks.   

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84. For example, one investor, a preacher, explained that he and two other 

investors, also preachers, attended the same high school in Nigeria and learned of 

Prosperity through an online group called “Jesus Online.”   

85. Moreover, the Defendants appear to have capitalized on shared 

religious beliefs to attract and retain investors.   

86. Some investor communications from Moore contained biblical quotes 

and assurances that the Defendants were “trusting God that everything will be 

better than it was before.” 

COUNT I 
 

Violations of Sections 5(a) and 5(c) of the Securities Act 
[15 U.S.C. §§ 77e(a) and 77e(c)] 

 
87. Paragraphs 1 through 86 are hereby realleged and are incorporated 

herein by reference. 

88. Defendants offered and sold securities, including promissory notes. 

89. Defendants used interstate transportation, communication or mails in 

connection with the offer and sale of securities. 

90. At the time of the offer and sale of securities, no registration statement 

was in effect as to the securities offered and sold. 

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91. By reason of the foregoing, Defendants have violated and, unless 

enjoined, will continue to violate Sections 5(a) and 5(c) of the Securities Act [15 

U.S.C. §§ 77e(a) and 77e(c)]. 

COUNT II 
 

Violations of Section 17(a)(1) of the Securities Act  
[15 U.S.C. § 77q(a)(1)] 

 
92. The Commission realleges paragraphs 1 through 86 above. 

93. Between October 2021 and March 2023, Defendants in the offer and 

sale of the securities described herein, by the use of means and instruments of 

transportation and communication in interstate commerce and by use of the mails, 

directly and indirectly, employed devices, schemes and artifices to defraud 

purchasers of such securities, all as more particularly described above. 

94. Defendants knowingly, intentionally, and/or recklessly engaged in the 

aforementioned devices, schemes and artifices to defraud. 

95. While engaging in the course of conduct described above, Defendants 

acted with scienter, that is, with an intent to deceive, manipulate or defraud or with a 

severe reckless disregard for the truth. 

96. By reason of the foregoing, Defendants directly and indirectly, have 

violated and, unless enjoined, will continue to violate Section 17(a)(1) of the 

Securities Act [15 U.S.C. § 77q(a)(1)]. 

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COUNT III 
 

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

 
97. Paragraphs 1 through 86 are hereby realleged and are incorporated by 

reference. 

98. Between October 2021 and March 2023, Defendants, in the offer and 

sale of securities described herein, by use of means and instruments of 

transportation and communication in interstate commerce and by use of the mails, 

directly and indirectly: 

a. obtained money and property by means of untrue statements of 

material fact and omissions 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 

b. engaged in transactions, practices and courses of business 

which would and did operate as a fraud and deceit upon the 

purchasers of such securities, all as more particularly described above. 

99. Defendants, directly and indirectly, have violated and, unless enjoined, 

will continue to violate Sections 17(a)(2) and 17(a)(3) of the Securities Act [15 

U.S.C. §§ 77q(a)(2) and 77q(a)(3)]. 

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COUNT IV 
 

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

 
100. The Commission realleges paragraphs 1 through 86 above. 

101. Between October 2021 and March 2023, Defendants, in connection 

with the purchase and sale of securities described herein, by the use of the means and 

instrumentalities of interstate commerce and by use of the mails, directly and 

indirectly: 

  a. employed devices, schemes, and artifices to defraud; 

 b. made untrue statements of material facts and 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, and courses of business which would 

and did operate as a fraud and deceit upon the purchasers of such 

securities, 

all as more particularly described above. 

102. Defendants knowingly, intentionally, and/or recklessly engaged in the 

aforementioned devices, schemes and artifices to defraud, made untrue statements of 

material facts and omitted to state material facts, and engaged in fraudulent acts, 

practices and courses of business.  In engaging in such conduct, Defendants acted 

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with scienter, that is, with an intent to deceive, manipulate or defraud or with a severe 

reckless disregard for the truth. 

103. By reason of the foregoing, Defendants, directly and indirectly, have 

violated and, unless 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].  

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully prays for: 

I. 

 Permanent injunctions enjoining Defendants and their officers, agents, 

servants, employees, and attorneys from violating, directly or indirectly, Sections 

5(a), 5(c) and 17(a) of the Securities Act [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)], 

and 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]. 

II. 

 A permanent injunction enjoining Defendant Moore from directly or indirectly 

participating in the issuance, purchase, offer, or sale of any security, provided that 

such injunction shall not prevent Moore from purchasing or selling securities listed 

on a national securities exchange for his own personal account. 

 
 

 

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III. 

 An order, pursuant to Sections 21(d)(5) and (7) of the Exchange Act [15 

U.S.C. §§ 78(u)(d)(5), (7)] and this Court’s inherent equitable authority, requiring 

disgorgement by Defendants of all ill-gotten gains or unjust enrichment with 

prejudgment interest, to effect the remedial purposes of the federal securities laws. 

IV. 

 An order pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] 

and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)] imposing civil 

penalties against Defendants.  

V. 

 An order pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. 

§ 78u(d)(2)] and/or Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] 

prohibiting Defendant Moore from acting as an officer or director of any issuer that 

has a class of securities registered pursuant to Section 12 of the Exchange Act [15 

U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the 

Exchange Act [15 U.S.C. § 78o(d)]. 

VI. 

 Such other and further relief as this Court may deem just, equitable, and 

appropriate in connection with the enforcement of the federal securities laws and 

for the protection of investors. 

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JURY TRIAL DEMAND 

 The Commission hereby demands a trial by jury as to all issues that may be 

so tried. 

Respectfully submitted this 18th day of January, 2024, 

/s/ Kristin W. Murnahan  
M. Graham Loomis 
Regional Trial Counsel 
United States Securities & Exchange Commission 
950 E. Paces Ferry Road NE, Suite 900 
Atlanta, GA 30326 
404-842-7622 
Georgia Bar No. 457868 
[email protected] 
 
Kristin W. Murnahan 
Senior Trial Counsel 
United States Securities & Exchange Commission 
950 E. Paces Ferry Road NE, Suite 900 
Atlanta, GA 30326 
404-842-7655 
Georgia Bar No. 759054   
[email protected] 
 
COUNSEL FOR PLAINTIFF 

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