2022-01-01 SEC Press complaint 1160 KB 16,269 chars

SEC v. Jebara Igbara, No. 1:22-cv-06669, Eastern District of New York (Jan. 1, 2022) — Complaint

raw: SEC v. JEBARA IGBARA

SEC v. JEBARA IGBARA, No. 1:22-cv-06669 (Jan. 1, 2022)

Caption
Securities and Exchange Commission v. Jebara Igbara
summary

Jebara Igbara defrauded over a dozen investors of $8 million through Halal Capital, misrepresenting investments in Quran-compliant ventures while using funds for personal luxuries and Ponzi-like payments.

paragraph

Jebara Igbara founded Halal Capital in October 2019, issuing promissory notes with annualized returns of 40% to over 100% to more than a dozen investors, totaling over $8 million. Instead of investing in Quran-compliant ventures as promised, Igbara misappropriated the funds for personal expenses, including luxury cars and online gambling, and made Ponzi-like payments to earlier investors. The SEC alleges Igbara violated Section 17(a) of the Securities Act and Section 10(b) and Rule 10b-5 of the Exchange Act.

narrative

Jebara Igbara, through his company Halal Capital, LLC, orchestrated a fraud scheme targeting the New York metropolitan area's Muslim community by issuing promissory notes with promised annualized returns ranging from 40% to over 100%. From October 2019 to August 2020, Igbara obtained more than $8 million from over a dozen investors, falsely representing that the funds would be invested in Quran-compliant ventures such as wholesale goods. Instead, he misappropriated the funds for personal luxuries, including luxury automobiles and online gambling, and made Ponzi-like payments to earlier investors. Igbara also orally guaranteed the return of principal to at least two investors and fabricated excuses for delays, such as theft and COVID-19 disruptions. The SEC charges Igbara with violating Section 17(a) of the Securities Act and Section 10(b) and Rule 10b-5 of the Exchange Act. The Commission seeks a permanent injunction against Igbara, disgorgement of all ill-gotten gains with prejudgment interest, and civil monetary penalties. Igbara, aged 27, is a resident of Edgewater, New Jersey, and the SEC's action was brought in the Eastern District of New York, where several investors reside and executed their investment agreements.

Enriched metadata

Scheme
ponzi (95%)
Court
Eastern District of New York
Case No.
1:22-cv-06669
Victim loss
$8,000,000
Victims
2
Classified ponzi(confidence 95%). EDGAR detection: forms Form D· recall 35% / precision 15%. detection rule →
Statutes
15 U.S.C. § 77q(a)15 U.S.C. § 78j(b)15 U.S.C. § 78u(d)15 U.S.C. § 77t(d)15 U.S.C. § 77v(a)15 U.S.C. § 78aa17 C.F.R. § 240.10b-5Section 17(a) of the Securities ActSection 10(b) of the Securities Exchange ActRule 10b-5
Parties
Securities and Exchange CommissionJebara Igbara
Keywords
halal capitaligbarahalalcapitalinvestorinvestmentinvestorsnewsecuritiessecurities exchangedocument pagepage pageidcapital investorsexchangeinitial investment

Extracted insights

Dollar amounts 7
  • $8.00M $8 million $1M–$10M
  • $2.00M $2,000,000 $1M–$10M
  • $350K $350,000 $100K–$1M
  • $120K $120,000 $100K–$1M
  • $100K $100,000 $100K–$1M
  • $100K $100,000 $100K–$1M
  • $10K $10,000 $10K–$100K
Entities 1
  • company halal capital
Triples 10
  • Igbara founded Halal Capital
  • Igbara began issuing promissory notes to investors
  • Igbara promised to invest Halal Capital investor funds
  • Halal Capital and Igbara obtained more than $8 million from investors
  • Igbara misappropriated all of Halal Capital’s investor proceeds
  • Igbara violated Section 17(a) of the Securities Act
  • Igbara violated Section 10(b) of the Exchange Act
  • The Commission seeks a judgment permanently enjoining Igbara
  • The Commission seeks a judgment ordering Igbara to disgorge all ill-gotten gains
  • The Commission seeks a judgment ordering Igbara to pay civil money penalties
Text layers
Extracted body text (16,269c)
Warning: TT: undefined function: 65

THOMAS P. SMITH, JR.
CO-ACTING REGIONAL DIRECTOR
Sheldon L. Pollock
Sandeep Satwalekar
Brian A. Kudon
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Office
100 Pearl Street, Suite 20-100
New York, New York 10004
(212) 336-1055 (Kudon)
[email protected]
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
SECURITIES AND EXCHANGE
C
OMMISSION,
Plaintiff,
-against-
JEBARA IGBARA,
Defendant.
COMPLAINT
22 Civ. 6669 (       )
JURY TRIAL DEMANDED
Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against
Defendant Jebara Igbara (“Igbara” or “Defendant” ), alleges as follows:
SUMMARY
1.This action involves the Defendant’s misappropriation of over $8 million in
investor funds and material misrepresentations in connection with the offering of promissory
notes targeting the New York metropolitan area’s Muslim community.
2.Beginning in approximately October 2019, Igbara founded Halal Capital, LLC
(“Halal Capital”) with the goal of sharing his purported business expertise with the Muslim
community.  Following its founding, Igbara began issuing promissory notes to investors and

2
promising significant returns of approximately 40 percent or more on an annualized basis.
Igbara promised to invest Halal Capital investor funds in a manner that was compliant with his
and the investors’ interpretation of the Quran and, to at least 2 investors, orally guaranteed the
return of their initial investment plus interest.
3. From approximately October 2019 through August 2020 (the “Relevant Period”),
Halal Capital and Igbara obtained more than $8 million from more than a dozen different
investors.
4. Igbara, however, did not use any of Halal Capital’s investment funds to actually
make the claimed investments on behalf of Halal Capital’s investors, and in fact,
misappropriated all of Halal Capital’s investor proceeds either for his own personal expenses,
which included the purchase of luxury automobiles and online gambling expenditures, or to
make Ponzi-like payments to Halal Capital’s investors.
VIOLATIONS
5. By virtue of the foregoing conduct and as alleged further herein, Igbara violated
Section 17(a) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)], and
Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)]
and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]  .
6. Unless Igbara is restrained and enjoined, he will engage in the acts, practices,
transactions, and courses of business set forth in this Complaint or in acts, practices, transactions,
and courses of business of similar type and object.
NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT
7. The Commission brings this action pursuant to the authority conferred upon it by
Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)] and Exchange Act

3
Section 21(d) [15 U.S.C. § 78u(d)].
8. The Commission seeks a judgment: (a) permanently enjoining Igbara from
violating the federal securities laws and rules this Complaint alleges he has violated; (b) ordering
Igbara to disgorge all ill-gotten gains he received as a result of the violations alleged here and to
pay prejudgment interest thereon pursuant to Exchange Act Sections 21(d)(3), 21(d)(5) and
21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; (c) ordering Igbara to pay civil
money penalties pursuant to Securities Act Section 20(d) [15 U.S.C. § 77t(d)] and Exchange Act
Section 21(d)(3) [15 U.S.C. § 78u(d)(3)]; and (d)   ordering any other and further relief the Court
may deem just and proper.
JURISDICTION AND VENUE
9. This Court has jurisdiction over this action pursuant to Securities Act Section
22(a) [15 U.S.C. § 77v(a)] and Exchange Act Section 27 [15 U.S.C. § 78aa].
10. Defendant, directly and indirectly, has made use of the means or instrumentalities
of interstate commerce or of the mails in connection with the transactions, acts, practices, and
courses of business alleged herein.
11. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)]
and Exchange Act Section 27 [15 U.S.C. § 78aa].   Several of Halal Capital’s investors reside in
the Eastern District of New York and executed their investment agreements and provided their
investment funds to Halal Capital within the Eastern District of New York.
DEFENDANT
12. Igbara, age 27, is a resident of Edgewater, New Jersey.  He founded Halal
Capital in approximately October 2019.  During the Relevant Period, Igbara told investors that
he would only use Halal Capital’s investors’ money for investment in Quran-compliant

4
activities.
OTHER RELEVANT ENTITIES
13. Halal Capital is a New Jersey limited liability company with its principal place
of business in Paramus, New Jersey.  It is a private investment fund purportedly focused on
making Quran-compliant investments.
FACTS
I. THE HALAL CAPITAL OFFERING
14. During the Relevant Period, Halal Capital and Igbara offered promissory notes to
New York City’s Muslim community, representing that investor funds would only be invested in
Quran-compliant investments, such as being pooled for the purchase of wholesale goods for
resale, including electronics and personal protective equipment (“PPE”).
15. The promissory notes provided for a set interest rate ranging from approximately
40 percent to more than 100 percent on an annualized basis.  The promissory notes either
provided for interest to be paid on a monthly basis with the initial investment paid at the maturity
of the promissory note, which was up to one year from the note’s issuance, or for interest and the
initial investment amount to be paid at maturity.  The rate of return depended on the amount
invested and the time frame for repayment.
16. Igbara sold the Halal promissory notes for a claimed business enterprise and to
allegedly finance substantial investments in wholesale goods with the aim of generating a profit
through their resale.  Igbara and Halal Capital actively solicited from New York’s large Muslim
community, and investors were primarily interested in the profit from their investments in Halal
Capital.    Investors were told that the purpose of Halal Capital and their investments was to enrich
New York’s Muslim community through Igbara’s efforts and expertise, and in fact, the

5
promissory notes specifically referred to the buyer as an investor.  Finally, there is no regulatory
scheme that would significantly reduce the risk of the investments offered by Halal Capital and
Igbara.
17. Before sending funds to Halal Capital and Igbara, investors executed an
investment agreement entitled “Transfer of Funds (Investment) Agreement” providing a rate of
return and the date that both the initial investment and interest would be paid.  In furtherance of
the goal of the Halal Capital investments being compliant with the Quran, the agreements
contained a provision that there would be no penalty for any late payments made by Halal
Capital to investors.
18. During the Relevant Period, Halal Capital received over $8 million from
approximately 12 to 15 investors, with investments ranging from approximately $10,000 to over
$2,000,000, including from several community centers and a mosque.
II.  IGBARA’S MISREPRESENTATIONS TO HALAL CAPITAL INVESTORS
19. Investors were persuaded to invest in Halal Capital based on the false
representation that Igbara would invest their money in a Quran-compliant manner.   In at least
one instance, Igbara also orally guaranteed to at least two investors that they would receive their
initial investment with interest upon maturity of their promissory note.
20. For example, in approximately December 2019, Igbara met a prospective investor
(“Investor 1”) at a sports club.  Shortly thereafter, Investor 1, along with his relative (“Investor
2”), met Igbara at a coffee shop, where Igbara discussed his purported business expertise and his
management of Halal Capital.
21. At Igbara’s suggestion, Investor 1 reached out to the relative of an earlier Halal
Capital investor, who told Investor 1 that Halal Capital was paying returns on the Halal Capital

6
investments as promised by Igbara.  Following that call, Investor 1 reached out directly to Igbara
who explained the investment and told him that he could earn higher returns if he invested a
larger amount of money.
22. Igbara also told Investor 1 that he would personally guarantee a return of Investor
1’s initial investment.
23. Based on the false representations that Igbara would invest his money in a manner
consistent with the Quran and Igbara’s personal guarantee, Investor 1 invested $100,000.
24. Shortly after Investor 1 made his $100,000 investment in Halal Capital, Igbara
reached out to Investor 2, and convinced both Investor 1 and Investor 2 to make a larger
investment, explaining once again that the larger the investment they made, the larger returns
they would receive and personally guaranteeing their investments.  As a result, Investor 1’s
original Halal Capital investment was voided, and a new investment agreement with Halal
Capital for a $350,000 investment was signed in early January 2020.  This agreement included a
guaranteed 15% monthly return for a period of one year.
25. In the ensuing months, Investor 1 and Investor 2 received several monthly interest
payments pursuant to their agreement, which Igbara sourced from other Halal Capital investor
funds.  However, their remaining interest payments were not made and their initial investment
was never returned as promised.
26. Igbara made various false claims related to the delay, including that millions of
dollars in investor money had been stolen from his car.
27. Igbara subsequently reached out to Investor 1 claiming that he would send the
initial amount he and Investor 2 invested by wire, but no wire was ever sent, and Investor 1 and
Investor 2 never received the remainder of the guaranteed interest payments or a return of their

7
initial investment.
28. Based on similar false claims that Igbara would invest his money in a Quran-
compliant manner, in late February 2020, another prospective investor (“Investor 3”) agreed to
invest $100,000 in Halal Capital and executed a promissory note providing for a 20% return on
investment in a little less than 6 months.
29. However, when Investor 3’s payment was due in June 2020, he was instead
offered a new deal.  Investor 3 agreed to rollover his investment in Halal Capital, which was now
allegedly worth $120,000, due to his prior investment plus interest, at a 20% rate of return.
30. In September 2020, when his second Halal Capital investment return was due,
Investor 3 was again told that there was a delay and that Igbara needed a couple more weeks to
pay him back.  Ultimately, Investor 3 never received any of the promised interest payments or a
return of his initial investment from Igbara or Halal Capital.
31. In reality, as discussed below, none of the Halal Capital investors’ money was
actually placed in any investment, let alone the purported Quran-compliant investments, but
rather was misappropriated by Igbara.
III. MISAPPROPRIATION OF INVESTOR FUNDS
32. Igbara used Halal Capital investment funds for his own personal expenses or to
make Ponzi-like payments to earlier investors.
33. Ultimately, when Halal Capital and Igbara were unable to return investors’ initial
investment or make monthly interest payments, Igbara made a number of false claims related to
the delays, including that payments were delayed due to the Covid-19 pandemic.
34. Of the more than $8 million collected by Halal Capital from the New York
metropolitan area’s Muslim community during the Relevant Period, Igbara used all of the Halal

8
Capital funds for personal expenses or to make Ponzi-like interest payments to earlier Halal
Capital investors, and not for the claimed investment purposes.
35. Specifically, Igbara used Halal Capital’s investor funds to buy several luxury
automobiles and to pay for online gambling expenditures and other personal expenses, including
the repayment of personal loans he received from family, friends, and a jeweler.
36. Igbara never disclosed to investors that he was using their investments in this
manner.
FIRST CLAIM FOR RELIEF
Violations of Securities Act Section 17(a)

37. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 36.
38. Igbara, directly or indirectly, singly or in concert, in the offer or sale of securities
and by the use of the means or instruments of transportation or communication in interstate
commerce or the mails, (1) knowingly or recklessly employed one or more devices, schemes or
artifices to defraud, (2) knowingly, recklessly, or negligently obtained money or property by
means of one or more untrue statements of a material fact or omissions of a material fact
necessary in order to make the statements made, in light of the circumstances under which they
were made, not misleading, and/or (3) knowingly, recklessly, or negligently engaged in one or
more transactions, practices, or courses of business which operated or would operate as a fraud
or deceit upon the purchaser.
39. Igbara violated Section 17(a) of the Securities Act by, among other things,
knowingly or recklessly making material misrepresentations to Halal Capital’s investors about
the use of money Halal Capital raised and misappropriating their investments.
40. By reason of the foregoing, Igbara, directly or indirectly, singly or in concert, has

9
violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C.
§ 77q(a)].
SECOND CLAIM FOR RELIEF
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder

41. The Commission re-alleges and incorporates by reference here the allegations in
paragraphs 1 through 36.
42. Igbara, directly or indirectly, singly or in concert, in connection with the purchase
or sale of securities and by the use of means or instrumentalities of interstate commerce, or the
mails, or the facilities of a national securities exchange, knowingly or recklessly (i) employed
one or more devices, schemes, or artifices to defraud, (ii) made one or more untrue statements of
a material fact or omitted to state one or more material facts necessary in order to make the
statements made, in light of the circumstances under which they were made, not misleading,
and/or (iii) engaged in one or more acts, practices, or courses of business which operated or
would operate as a fraud or deceit upon other persons.
43. Igbara violated Section 10(b) of the Exchange Act and Rule 10b-5 thereunder by,
among other things, knowingly or recklessly making material misrepresentations to Halal
Capital’s investors about the use of money Halal Capital raised and misappropriating their
investments.
44. By reason of the foregoing, Igbara, directly or indirectly, singly or in concert, has
violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)]
and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].

10
PRAYER FOR RELIEF

 WHEREFORE, the Commission respectfully requests that the Court enter a Judgment:
I.
Permanently enjoining Igbara from violating, directly or indirectly, Securities Act Section
17(a) [15 U.S.C. § 77q(a)] and Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5
thereunder [17 C.F.R. § 240.10b-5]  ;
II.
Ordering Igbara to disgorge all ill-gotten gains he received directly or indirectly, with
prejudgment interest thereon pursuant to Exchange Act Sections 21(d)(3), 21(d)(5) and 21(d)(7)
[15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)];
III.

Ordering Igbara to pay civil monetary penalties pursuant to Section 20(d) of the

11
Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §
78u(d)(3)]; and
IV.
Granting any other and further relief this Court may deem just and proper.
Dated:  New York, New York
November 2, 2022
/s/ Thomas P. Smith, Jr.
THOMAS P. SMITH, JR.
CO-ACTING REGIONAL DIR
ECTOR
Sheldon L. Pollock
Sandeep Satwalekar
Brian A. Kudon
Attorneys for Plaintiff
SECURITIES AND EXCHANGE COMMISSION
New York Regional Of
fice
100 Pearl Street, Suite 20-100
New York, New York 10004
(212)336-1055 (Kudon)
[email protected]
OCR text (18,955c · tika · 95% conf)
THOMAS P. SMITH, JR. 
CO-ACTING REGIONAL DIRECTOR 
Sheldon L. Pollock  
Sandeep Satwalekar 
Brian A. Kudon 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street, Suite 20-100 
New York, New York 10004 
(212) 336-1055 (Kudon)
[email protected]

UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 

-against-

JEBARA IGBARA,  

Defendant. 

COMPLAINT 

22 Civ. 6669 (       ) 

JURY TRIAL DEMANDED 

Plaintiff Securities and Exchange Commission (“Commission”), for its Complaint against 

Defendant Jebara Igbara (“Igbara” or “Defendant”), alleges as follows: 

SUMMARY 

1. This action involves the Defendant’s misappropriation of over $8 million in

investor funds and material misrepresentations in connection with the offering of promissory 

notes targeting the New York metropolitan area’s Muslim community. 

2. Beginning in approximately October 2019, Igbara founded Halal Capital, LLC

(“Halal Capital”) with the goal of sharing his purported business expertise with the Muslim 

community.  Following its founding, Igbara began issuing promissory notes to investors and 

Case 1:22-cv-06669   Document 1   Filed 11/02/22   Page 1 of 11 PageID #: 14



 2 

promising significant returns of approximately 40 percent or more on an annualized basis.  

Igbara promised to invest Halal Capital investor funds in a manner that was compliant with his 

and the investors’ interpretation of the Quran and, to at least 2 investors, orally guaranteed the 

return of their initial investment plus interest.   

3. From approximately October 2019 through August 2020 (the “Relevant Period”), 

Halal Capital and Igbara obtained more than $8 million from more than a dozen different 

investors.   

4. Igbara, however, did not use any of Halal Capital’s investment funds to actually 

make the claimed investments on behalf of Halal Capital’s investors, and in fact, 

misappropriated all of Halal Capital’s investor proceeds either for his own personal expenses, 

which included the purchase of luxury automobiles and online gambling expenditures, or to 

make Ponzi-like payments to Halal Capital’s investors.   

VIOLATIONS 

5. By virtue of the foregoing conduct and as alleged further herein, Igbara violated 

Section 17(a) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C. § 77q(a)], and 

Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] 

and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

6. Unless Igbara is restrained and enjoined, he will engage in the acts, practices, 

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

and courses of business of similar type and object.   

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

7. The Commission brings this action pursuant to the authority conferred upon it by 

Securities Act Sections 20(b) and 20(d) [15 U.S.C. §§ 77t(b) and 77t(d)] and Exchange Act 

Case 1:22-cv-06669   Document 1   Filed 11/02/22   Page 2 of 11 PageID #: 15



 3 

Section 21(d) [15 U.S.C. § 78u(d)].  

8. The Commission seeks a judgment: (a) permanently enjoining Igbara from 

violating the federal securities laws and rules this Complaint alleges he has violated; (b) ordering 

Igbara to disgorge all ill-gotten gains he received as a result of the violations alleged here and to 

pay prejudgment interest thereon pursuant to Exchange Act Sections 21(d)(3), 21(d)(5) and 

21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; (c) ordering Igbara to pay civil 

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

Section 21(d)(3) [15 U.S.C. § 78u(d)(3)]; and (d) ordering any other and further relief the Court 

may deem just and proper.  

JURISDICTION AND VENUE 

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

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

10. Defendant, directly and indirectly, has made use of the means or instrumentalities 

of interstate commerce or of the mails in connection with the transactions, acts, practices, and 

courses of business alleged herein. 

11. Venue lies in this District under Securities Act Section 22(a) [15 U.S.C. § 77v(a)] 

and Exchange Act Section 27 [15 U.S.C. § 78aa].  Several of Halal Capital’s investors reside in 

the Eastern District of New York and executed their investment agreements and provided their 

investment funds to Halal Capital within the Eastern District of New York.  

DEFENDANT 

12. Igbara, age 27, is a resident of Edgewater, New Jersey.  He founded Halal 

Capital in approximately October 2019.  During the Relevant Period, Igbara told investors that 

he would only use Halal Capital’s investors’ money for investment in Quran-compliant 

Case 1:22-cv-06669   Document 1   Filed 11/02/22   Page 3 of 11 PageID #: 16



 4 

activities.  

OTHER RELEVANT ENTITIES 

13. Halal Capital is a New Jersey limited liability company with its principal place 

of business in Paramus, New Jersey.  It is a private investment fund purportedly focused on 

making Quran-compliant investments.  

FACTS 

I. THE HALAL CAPITAL OFFERING 

14. During the Relevant Period, Halal Capital and Igbara offered promissory notes to 

New York City’s Muslim community, representing that investor funds would only be invested in 

Quran-compliant investments, such as being pooled for the purchase of wholesale goods for 

resale, including electronics and personal protective equipment (“PPE”).   

15. The promissory notes provided for a set interest rate ranging from approximately 

40 percent to more than 100 percent on an annualized basis.  The promissory notes either 

provided for interest to be paid on a monthly basis with the initial investment paid at the maturity 

of the promissory note, which was up to one year from the note’s issuance, or for interest and the 

initial investment amount to be paid at maturity.  The rate of return depended on the amount 

invested and the time frame for repayment.   

16. Igbara sold the Halal promissory notes for a claimed business enterprise and to 

allegedly finance substantial investments in wholesale goods with the aim of generating a profit 

through their resale.  Igbara and Halal Capital actively solicited from New York’s large Muslim 

community, and investors were primarily interested in the profit from their investments in Halal 

Capital.  Investors were told that the purpose of Halal Capital and their investments was to enrich 

New York’s Muslim community through Igbara’s efforts and expertise, and in fact, the 

Case 1:22-cv-06669   Document 1   Filed 11/02/22   Page 4 of 11 PageID #: 17



 5 

promissory notes specifically referred to the buyer as an investor.  Finally, there is no regulatory 

scheme that would significantly reduce the risk of the investments offered by Halal Capital and 

Igbara.  

17. Before sending funds to Halal Capital and Igbara, investors executed an 

investment agreement entitled “Transfer of Funds (Investment) Agreement” providing a rate of 

return and the date that both the initial investment and interest would be paid.  In furtherance of 

the goal of the Halal Capital investments being compliant with the Quran, the agreements 

contained a provision that there would be no penalty for any late payments made by Halal 

Capital to investors.   

18. During the Relevant Period, Halal Capital received over $8 million from 

approximately 12 to 15 investors, with investments ranging from approximately $10,000 to over 

$2,000,000, including from several community centers and a mosque.   

II.  IGBARA’S MISREPRESENTATIONS TO HALAL CAPITAL INVESTORS 

19. Investors were persuaded to invest in Halal Capital based on the false 

representation that Igbara would invest their money in a Quran-compliant manner.  In at least 

one instance, Igbara also orally guaranteed to at least two investors that they would receive their 

initial investment with interest upon maturity of their promissory note.   

20. For example, in approximately December 2019, Igbara met a prospective investor 

(“Investor 1”) at a sports club.  Shortly thereafter, Investor 1, along with his relative (“Investor 

2”), met Igbara at a coffee shop, where Igbara discussed his purported business expertise and his 

management of Halal Capital.   

21. At Igbara’s suggestion, Investor 1 reached out to the relative of an earlier Halal 

Capital investor, who told Investor 1 that Halal Capital was paying returns on the Halal Capital 

Case 1:22-cv-06669   Document 1   Filed 11/02/22   Page 5 of 11 PageID #: 18



 6 

investments as promised by Igbara.  Following that call, Investor 1 reached out directly to Igbara 

who explained the investment and told him that he could earn higher returns if he invested a 

larger amount of money.   

22. Igbara also told Investor 1 that he would personally guarantee a return of Investor 

1’s initial investment.   

23. Based on the false representations that Igbara would invest his money in a manner 

consistent with the Quran and Igbara’s personal guarantee, Investor 1 invested $100,000.   

24. Shortly after Investor 1 made his $100,000 investment in Halal Capital, Igbara 

reached out to Investor 2, and convinced both Investor 1 and Investor 2 to make a larger 

investment, explaining once again that the larger the investment they made, the larger returns 

they would receive and personally guaranteeing their investments.  As a result, Investor 1’s 

original Halal Capital investment was voided, and a new investment agreement with Halal 

Capital for a $350,000 investment was signed in early January 2020.  This agreement included a 

guaranteed 15% monthly return for a period of one year.   

25. In the ensuing months, Investor 1 and Investor 2 received several monthly interest 

payments pursuant to their agreement, which Igbara sourced from other Halal Capital investor 

funds.  However, their remaining interest payments were not made and their initial investment 

was never returned as promised.   

26. Igbara made various false claims related to the delay, including that millions of 

dollars in investor money had been stolen from his car.   

27. Igbara subsequently reached out to Investor 1 claiming that he would send the 

initial amount he and Investor 2 invested by wire, but no wire was ever sent, and Investor 1 and 

Investor 2 never received the remainder of the guaranteed interest payments or a return of their 

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initial investment.   

28. Based on similar false claims that Igbara would invest his money in a Quran-

compliant manner, in late February 2020, another prospective investor (“Investor 3”) agreed to 

invest $100,000 in Halal Capital and executed a promissory note providing for a 20% return on 

investment in a little less than 6 months.   

29. However, when Investor 3’s payment was due in June 2020, he was instead 

offered a new deal.  Investor 3 agreed to rollover his investment in Halal Capital, which was now 

allegedly worth $120,000, due to his prior investment plus interest, at a 20% rate of return.   

30. In September 2020, when his second Halal Capital investment return was due, 

Investor 3 was again told that there was a delay and that Igbara needed a couple more weeks to 

pay him back.  Ultimately, Investor 3 never received any of the promised interest payments or a 

return of his initial investment from Igbara or Halal Capital.      

31. In reality, as discussed below, none of the Halal Capital investors’ money was 

actually placed in any investment, let alone the purported Quran-compliant investments, but 

rather was misappropriated by Igbara.   

III. MISAPPROPRIATION OF INVESTOR FUNDS 

32. Igbara used Halal Capital investment funds for his own personal expenses or to 

make Ponzi-like payments to earlier investors.   

33. Ultimately, when Halal Capital and Igbara were unable to return investors’ initial 

investment or make monthly interest payments, Igbara made a number of false claims related to 

the delays, including that payments were delayed due to the Covid-19 pandemic.   

34. Of the more than $8 million collected by Halal Capital from the New York 

metropolitan area’s Muslim community during the Relevant Period, Igbara used all of the Halal 

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Capital funds for personal expenses or to make Ponzi-like interest payments to earlier Halal 

Capital investors, and not for the claimed investment purposes.   

35. Specifically, Igbara used Halal Capital’s investor funds to buy several luxury 

automobiles and to pay for online gambling expenditures and other personal expenses, including 

the repayment of personal loans he received from family, friends, and a jeweler.   

36. Igbara never disclosed to investors that he was using their investments in this 

manner. 

FIRST CLAIM FOR RELIEF 
Violations of Securities Act Section 17(a) 

 
37. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 36. 

38. Igbara, directly or indirectly, singly or in concert, in the offer or sale of securities 

and by the use of the means or instruments of transportation or communication in interstate 

commerce or the mails, (1) knowingly or recklessly employed one or more devices, schemes or 

artifices to defraud, (2) knowingly, recklessly, or negligently obtained money or property by 

means of one or more untrue statements of a material fact or omissions of a material fact 

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

were made, not misleading, and/or (3) knowingly, recklessly, or negligently engaged in one or 

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

or deceit upon the purchaser. 

39. Igbara violated Section 17(a) of the Securities Act by, among other things, 

knowingly or recklessly making material misrepresentations to Halal Capital’s investors about 

the use of money Halal Capital raised and misappropriating their investments.  

40. By reason of the foregoing, Igbara, directly or indirectly, singly or in concert, has 

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violated and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. 

§ 77q(a)]. 

SECOND CLAIM FOR RELIEF 
Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder 

 
41. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 36. 

42. Igbara, directly or indirectly, singly or in concert, in connection with the purchase 

or sale of securities and by the use of means or instrumentalities of interstate commerce, or the 

mails, or the facilities of a national securities exchange, knowingly or recklessly (i) employed 

one or more devices, schemes, or artifices to defraud, (ii) made one or more untrue statements of 

a material fact or omitted to state one or more material facts necessary in order to make the 

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

and/or (iii) engaged in one or more acts, practices, or courses of business which operated or 

would operate as a fraud or deceit upon other persons. 

43. Igbara violated Section 10(b) of the Exchange Act and Rule 10b-5 thereunder by, 

among other things, knowingly or recklessly making material misrepresentations to Halal 

Capital’s investors about the use of money Halal Capital raised and misappropriating their 

investments.  

44. By reason of the foregoing, Igbara, directly or indirectly, singly or in concert, has 

violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] 

and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

  

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PRAYER FOR RELIEF 
 

 WHEREFORE, the Commission respectfully requests that the Court enter a Judgment: 

I. 

Permanently enjoining Igbara from violating, directly or indirectly, Securities Act Section 

17(a) [15 U.S.C. § 77q(a)] and Exchange Act Section 10(b) [15 U.S.C. § 78j(b)] and Rule 10b-5 

thereunder [17 C.F.R. § 240.10b-5];  

II. 

Ordering Igbara to disgorge all ill-gotten gains he received directly or indirectly, with 

prejudgment interest thereon pursuant to Exchange Act Sections 21(d)(3), 21(d)(5) and 21(d)(7) 

[15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; 

III. 
 

Ordering Igbara to pay civil monetary penalties pursuant to Section 20(d) of the 

  

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11 

Securities Act [15 U.S.C. § 77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 

78u(d)(3)]; and 

IV. 

Granting any other and further relief this Court may deem just and proper. 

Dated: New York, New York 
November 2, 2022 

/s/ Thomas P. Smith, Jr. 
THOMAS P. SMITH, JR. 
CO-ACTING REGIONAL DIRECTOR  
Sheldon L. Pollock 
Sandeep Satwalekar 
Brian A. Kudon 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street, Suite 20-100 
New York, New York 10004 
(212) 336-1055 (Kudon)
[email protected]

Case 1:22-cv-06669   Document 1   Filed 11/02/22   Page 11 of 11 PageID #: 24

mailto:[email protected]

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	topmostSubform[0].Page1[0].defCty[0]1: Bergen County
	topmostSubform[0].Page1[0].attorneysPL[0]1: Thomas P. Smith, Jr., Sheldon Pollock, Sandeep Satwalekar, Brian A. Kudon, U.S. Securities and Exchange Commission,100 Pearl Street, Suite 20-100, New York, NY 10004, (212) 336-1055 (Kudon)
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