SEC v. Bernard H. Butts, Jr.; Fotios Geivelis Jr.; Worldwide Funding III Limited LLC; Douglas J. Anisky; Sidney Banner; Express Commercial Capital LLC, et al., Southern District of Florida (Jan. 1, 2013) — Complaint

UNJTED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Secmities a 
nd Exchange Commission, 
Plaintiff, 
FILED by_ __D.C. 
V. 
Case No. 
AUG 2 9 2013 
Bernard H. Butts,  Jr. , 
Fotios Geiveli s, Jr. , also known 
as Frank Anastasio"lf 
Worldwide Funding Ill Limited LLC, .ll 
Douglas J.  Anisky, 
Sidney Banner, 
UNDER SEAL 
Express Commercial Capital LLC, 
James Baggs, 
Defendants, 
Bernard 
H. Butts,  Jr. PA, 
Butts Holding Co rp oratio n, 
,f MCALILEY 
Margaret A. Hering, 
Global Worldwide Funding Venture
s, Inc. , 
PW Consulting Group LLC, 
Relief Defendants. 
PLAINTIFF'S COMPLAINT FOR SECURITIES FRAUD, 
INJUNCTION AND OTHER RELIEF 
Plaintiff Securities and Exchange Commission ("SEC") alleges for its complaint against 
defendants Florida attorney Bernard H. Butts, Jr. , Fotios Geivelis Jr. , who used the alias Frank 
Anastasio, and his company Worldwide Funding III Limited 
LLC (" Worldwide Funding"), and 
sales agents D ougla s J. Anisky, Sidney Banner and his company Express Commercial Capital 
LLC 
("Express Commercial"),  and Jam es Baggs; and relief defendants Bernard 
H. Butts, Jr. PA 
(" Butts PA "), Butts Holding Corporation (" Butts Holding"), Margaret A. Hering, Global 
Worldwide Funding Ventures, Inc. ("Global Ventures"), and 
PW Consulting Group LLC ("PW 
Consulting"): 
I. SUMMARY 
I. From at l  east April 2012  through the present, Florida attorney Bernard H. Butts, Jr., 
Fotios Geivelis Jr. , who used the alias Frank Anastasio, and his company Worldwide Funding, 

and sales agents Anisky, Banner and his company Express Co mmercial, and Baggs obtained 

millions 
ofdollars by defrauding investors through the offer and sale ofinvestments in a 

fictitious prime bank ins
tmment trading program. 

2. G eive
lis·and Butts paid sales agents including Anisky, Ba1mer, Express Commercial, and 
B aggs to Jure inves tors through the Internet,  telephone, and personal contact into the scheme 
with promises ofextraordinary profits. As part of the scheme, defendants told investors tha t an 
investment 
ofbetween USD $60,000 and $90,000  would genera  te profits of a t least €6,660,000 
(Euro) within 
15 to  45 business days and continue to earn profits of approximately 14% per week 
for 40 to 42 weeks. 
3. Defendants falsely promised that when an in
vestor's funds  were deposited into Butts' 
attorney trust account, Butts would not release the f1mds until he received proof from the 
receiv ing bank 
that a  € 10,000,000 Standby Letter ofCJ·edit ("SBLC") had been deposited into a 
secmities .trading 
program which was to generate  th e profits for the  investors. 
4. Defendants did n
ot disclose that instead ofusing the funds to obtain SBLCs, they 
misappropriated 
inves tors' funds with Geivelis and Butts each ta king approx im ately 45% and 
paying approximately 10% to the sales agents. Contrary to th e defen dants' re presentations, the 
acquisition ofthe SBLCs never occurred, no loans were obtained, and no pro mised returns  were 
earned in a trading program 
or paid to investors .  Over more than a year, the defendants obtained 
at least $3.5 million from approximately forty-five investors nationwide and 
in fo re  ign countries 
by making false and misleading statements or omitting mate1ial facts in the offer and sale of 
these unregistered securities. 
5. 
To keep the scheme going, Geivelis and Butts also made lulling statements to inves tors, 
representing that the trading program was succe
ssful and that payments  to inves tors were 
imminent. 
6. 
Through these actions, Geivelis, Worldwide Funding, Butts, Anisky, Ba1mer, Express 
Commercial, and 
Baggs v iolated, and unless restrained and enj oined will continue to  violate, the 
antifraud provisions 
of Section 17(a) ofthe Securities Act of 1933 (" Securities Act"), 15 U.S.C. 
§ 77q(a), Section lO(b) of the Securities Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. § 
78j(b), and Rule lOb-5 ,  17 C.F.R. § 240.10b-5. 
7. In addition, Geivelis, Worldwide Funding, Butts, Anisky, B anner, Express Commercial, 
and Baggs offered and sold securities in the form 
ofinvestment contracts, which were no t 
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registered w ith the SEC a t  the  tim e  th ey were sold ,  in  vio lation of the securities registration 
provisions ofSection5(a) an d  (c) of the Securities Act,  15  U.S .C. § 77e(a) and (c), and  unless 

restrained  and  e
njoined  will continue  to viola te these secu rities registration p rovisions. 

8. Geive
lis, Butts, A ni sky, Express Comm ercial, Ba nner, and Baggs also acted as broker-
dealers in vio lation 
ofthe  registration provisions of Section  15(a)( I) of the  Exchange Act, 15 
U.S.C. 
§ 78o(a)(l), and u nless res trained  and enjo ined  will continue  to violate the brok er-d ea ler 
registration  provisions . 
9. Reli
efdefendants Bernard H. Bu tts,  Jr. PA, Butts Ho ld ing Corporation, G lobal 
Worldwide Funding Ventures, Inc., Marga ret A. Hering, and PW Consulting  Group LLC 
received  investors' fund s  to  which  they had no  legiti mate claim and were u njustly enriched. 
II. JURISDICTION AND VEN UE 
10. The SEC brings thi s acti on u nder Section 20(b) of the Securities Act, 15 U.S.C. § 77t(b) 
a
nd Sec ti on 2 1(d) and (e) ofthe Exchange Act,  15 U.S.C. § 78u(d) and (e), to restrain and  enjoin 
the defenda
nts  from engaging  in the acts, prac tices and courses ofbus iness d escribed  in thi s 
Co
mplaint, and acts, practi ces an d co urses o f business of similar purp01t and object. T h e 
Co
mmission  seeks perman ent injunc ti ons,  di sgorgeme nt ofill-go tten gains  derived fro m the 
co
nduct alleged  in the Complaint plus prejudgm ent in terest, and  thi rd-tier civil penalties w1der 
Section 
20( d )  of the Securities Act,  15 U.S.C. § 77t(d) and Section 2 1 ( d)(3) of the Exchange Act, 
15 U.S. C. § 78u(d)(3). 
11. Tllis Court has jurisdiction  under Section  22(a) of  the  Securi ties Act, 15 U.S. C . § 77v(a) 
and 
Section 27 o f the Exch ange Act, 15 U.S.C. § 78aa. The defendants, directly or indirectly, 
made u se o f the  m
eans  a nd  instrumenta li ties of interstate commerce or ofthe m ails, in 
co
nnection with the acts, practi ces and courses o f bus in ess a lleged in the Complaint. 
12. Certain 
ofthe acts, practi ces, and  co urses of business constituting violations o f law 
alleged  in the Complaint occurred  within  the Southern District of F lorida. In addition, Butts 
Banner, and A nisky reside in the Southern District ofFlorida . Express C ommercial conduc ts 
busine
ss fro m the Southern District ofF lorida . 
III. DEFENDANTS 
13. Defend ant Bernard H. Butts, Jr ., born in 194 1, is an attorney admitted to practice law in 
Florida. H e r
esides and tran sacted  business in M iam i,  Flori da. He entered  in to numerous  escrow 
3 


agreements with Worldwide Funding, Geivelis and investors from his offices in Miami, Florida. 
14. 
Defendant Fotio s Geivelis, Jr., bom in 1979, is a  resident ofTampa, Florida and  used the 
nam e 
"Frank Anastas io" in dealing with in vestors. Geivelis  transacted business in Miami, 
Flo
rida by entering  into numerous escrow agr eements with Butts and the investors related to the 
transactions 
at issue in this case. 
15. 
Defendant Worldwide Funding III Limited LLC is a  Florida limited liability company 
organized on March  1, 2012, w ith its principal place of bu siness in Fort Myers, Florida. 
Worldwide Funding transacted business in Miami, Florida by entering into numerous escrow 
agreeme
nts with Butts and the investors related to the transactions at issue in this case. Geivelis 
is  the sole 
managing member and owner ofWorldwide Funding LLC. 
16. 
Defendant Douglas J. Anisky, bom in 1957, is a resid ent ofDelray Beach, Florida. H e 
is a 
sales agent that finds in vestors for Worldwide Funding and receives transaction based 
commissions. H e  tTansacted business in Miami, Florida by participating in telephone conference 
call s am ong investo rs, Geivelis, B utts and himself, and receiving commissions from Butts' l!us t 
account 
in Miami, Fl orida. 
17. D
efendant Sidney Banne r , bom in  1927, is a r es ident ofDelray Beach, Florida. He is  a 
sales agent that finds  investors fo r Worldwide Funding and other investment programs and 
receives transaction-based commissions. H e  transacted business in Miami, Florida by arranging 
and participating in telephone conference call s among investors, Geivelis, Butts and himself, and 
receiving commissions from B utts' llust account in Miami, Florida. 
18. D
efendant Express Commercial Capital LLC is a  Fl01ida limited liability company that 
conducts business from Delray Beach, Florida. Express Commercial is a bro ker that fmds 
investors for 
Worldwide Funding and other inves tment programs and r eceives n·ansaction-based 
commissions from Butts '  trust account in Miami, Florida. Banner and his wife  are managing 
members 
ofExpress Commercial. Express Commercial, through Banner, transacted business in 
M ia mi,  Florida 
by arranging and participating in telephone conference calls among investors, 
Geivelis, Butts 
and himself, and receiving commissions from Butts' trust account in Miami, 
Florida. 
19. D efendant 
James Baggs,  born in 1942, is a  resident ofLake Forest, California. Baggs is 
a sales agent that finds 
investors  for Worldwid e Funding and other investment programs and 
receives transaction-based conm1issions from a bank account he ld in the name ofBemard H. 
4 


Butts Jr. P.A. in Miami, Florid a. 
20. Relief defendant 
Bernard H. Butts Jr. P.A. is a F lorida corpo ration. It does business as 
"The Law Offices of Butts 
& Mertz" and it s principal place of ~usiness is in Miam i, Florida. 
Butts is  the owner 
of Butts PA. 
21. Reli
efdefendant Butts Holding Corporation is a Florida corporation with a principal 

place 
of business in Miami, Florida. Butts is  the president and only officer of Butts Holding. 

22. 
Reliefdefendant Margaret A. Hering, age 70 , is a resid ent of Miami , Florida and is 

Butt
s' wife. 

23 . Reli ef defendant Global Worldwide Funding Ventures, Inc. is a  Flo rida corporation 
with a principal place 
of business in Fort Meyers, Florida. Geivel is is the president and onl y 
officer 
of Globa l Ventures. 
24. Relief defendant 
PW Consulting Group LLC is a Florida limited liabi lity company with 
its principal place 
of business in Delray Beach, Florida. Anisky is  the managing member ofPW 
Consultin
g. 
IV. OFFER AND SALE OF UNREGISTERED SECURITIES 
25. In March 2012, Geivelis  formed Worldwide Funding with its principa l office in Fort 
Myers , Florida. 
26. In May 20 12, Geivelis opened a bank acco unt for Wo
rldwide Funding with JPMorgan 
Chase Bank, N.A. (" Worldwide Chase account") in Midland Park, New J ersey, w ith an initial 
depos it 
of $40. The bank account s tatements were mailed to a house where Geivelis lived in 
Wyckoff, New J ersey until approximately 
April 2013, when Geivelis moved  to Tampa, Florida. 
Geivelis was th e sole  signatory o n  th e account and controlled the funds in th e Wo rld wide Chase 
account. 
27. Worldwide Funding has  a website at www.worldwidefund ingiii.c
om created by G eivelis, 
which states it  is a "commercial funding brokerage and consulting firm. " 
28. From in 
or about April2012 and continuing to date,  Worldwide Fundi ng, Geivelis, and 
Butts as Geivelis' partner, and their sales agents: Anisky, Express Conunercial, Banner and 
Baggs offered and so ld securiti
es in the form of investment contracts in a fraudu lent prime bank 
scheme. 
29. The investments contracts offered by the defendants  were sec
urities. The investment 
con trac ts required inves tors  to invest between $60,000 and $90,000, which was transfe
rred to 
5 


Butts '  attorney trust account fo r th e bene fit of Wo rld wid e Fund ing. Geivelis and Wo rldw id e 
Funding were to use th e  investors' 
fu nds  to pay banking charges to lease Stand by Letters of 
Credit (" SBLC") in the amount of€1 0,000,000 from a banking grou p in Europe.  Geivelis and 
W orldw ide we re to lever
age th e SBLC to invest in a sec uriti es trading program tha t was to 
generate a rate 
of return of approximately  14% per week. Investors' profits were to come from 
the 
effo11s of Geivelis, Wo rldw ide Funding, and th e trading program . 
30. Worldwide Funding  through 
Geive lis as its managing member, Butts , Ani sky, Express 
Co
mmercia l through  its m anaging m ember Ba1mer, and Baggs communicated with investors 
thro ugh electronic mail  (
"ema il")  and telephone ca ll s .  World w ide Funding and Geivelis,  and 
Ex
press Commercial and Banner also have websi tes tha t offer th e investments. 
3 1. Since April 20 12, Wo rldw ide Fund ing, Geivelis and Butts also distributed offering 
m ate
rials  to in vestors th at describ ed  th e investment, includi ng Worldwide Funding's A greem ent, 
Escrow Agreement, Financ ial Serv i
ce Agreement, Trading Agreemen t and Settl ement 
Statements. 
32. Worldwide Funding, Geiveli s, and Butts represented in the offerin g materials and in 
conversations with investo rs  t   ha t an  inves tor paid $60 ,000 to $90,000 to Worldwide Funding for 
bank charges to lease an SB LC in the amount of € 10,000,000 from a banking group in Europe. 
They also represented th at the  investor' s  fund s were held in Butts PA 's attorn ey tmst account, 
and would not be released until delivery 
of th e SBLC was co nfirmed by the receiving bank, 
Barclays Bank 
in the United Arab Emirates. In addi tion, they represented that they arranged for 
a  third-party to transfer  the  S
BLC to Barc lays Bank, which would acknow ledge receipt of the 
SBLC. 
They also represented the SB LC was  used  to  acquire a loan, with th e fund s from the loan 
placed  in a securities trading 
program th at generated a return on in vestment of approx imately 
14% per w eek for a
pproximately 42  weeks. 
33. Worldwide Funding, Geiveli s, and Butts used sales agents  to solicit investors for the 
W orldwide Funding trading prog ram and p
aid th em approximate ly 10% of the investor's funds 
that we re invested. 
34. 
From at least April 20 12  to presen t, Anisky offered Worldwide Funding' s in vestment 
contracts  to at l  east t  en investors, communicated with investors and the other defend ants  through 
the Internet, em ails or tele
phone calls, and received  transaction based compensation fro m the 
sales made to inves tors,  w hi ch was paid  into  the  bank acco unt 
of PW Consulting. 
6 


35. From at least January 20 13 to the present, Express Commercial, Banner, and Baggs also 
offered Worldwide 
Funding's investment contracts  to at least eleven investors, communicated 
with investors  a
nd the other defendants  through the Internet, emails or telephone calls, and 
received  transaction based compensation from their sales made to investors. 
36. From 
April 2012 to date, Worldw ide Funding, Geivelis, and Butts offered and sold 
Worldwide 
Funding's inves tm ent contracts to at least forty-five investors and received directl y 
or indirectly approximatel y $3,687,701 from the sale of these investment contracts. The sales 
were 
made in Miami Florida when investors  transferred  their funds to Butts' attorney trust 
account. 
3
7. No registration s tatement was filed with  the SEC or in effect for the offer or sale of 
World wide Funding 's securities by th e defendants. 
V. DEFENDANTS ENGAGED IN A SCHEME TO 

DEFRAUD INVESTORS 

38. Worldw ide Funding, Geivelis, Butts, Anisky, Express Commercial, Banner, and Baggs 
used 
an artifice,  device or scheme to defi·aud investors by offering or selling investments in a 
fictitious trading 
program for prime bank ins truments. Investors were lured into the scheme with 
the promi
se of€ l 0  millio n non-recourse loans to use for their business or humanitarian projects 
and ex traordinary rate 
of return of approxima tely 14% per week from an international trading 
program. In fact, no 
Worldwide Funding  trading program existed and the defendants did not 
obtain SBLCs  to leverage 
in an international trading program to produce the tremendous returns 
promjsed by the d efendants. 
39. Prime 
bank trading programs such as those offered by Worldwide Funding, Geivelis, 
Butts, Anisky, Express Commercial, Banner, and Baggs are fictitious . The Securities Exchange 
Commission, the 
Federal Reserve Bank, the International Monetary Fund and numerous other 
federal and international authori ties have all publicly denounced the
se bank inst:mment program 
frauds in easily obtainable information. 
40. Worldwide Funding  a
nd Geivelis engaged in deceptive acts in furtheranc e of the scheme 
by offering and selling investments in a fictitious trading program and by creating false 
Worldwide Funding 
offeting materials and agreements that made it appear they were offering a 
re al investm ent when 
they never acquired  the SBLCs or participated in the trading program as 
represented. 
The offering m aterials were just a device to obtain investor money for defendants ' 
7 

persona l benefit. Worldwide Funding and Geivelis misappropriated investor funds and did no t 

use them 
to pay  banking  fees to acquire SBLC. 

41. Butts engaged  in deceptive ac ts  in furtherance of the schem e  by offe1ing  and selling 
investme
nts in a fictitious  trading  program, entering  into  the Escrow Agreements  in w hich he 
agreed  to  only  release the investors' 
f1mds after receiving proof that  the bank had received the 
SBLC, and representing that he was no t compensated for his work as an escrow agent. Contra ry 
to hi s agreement, 
Butts released  the investors'  funds  without proof tha t SBLCs were acqu ired. In 
addition, Butts 
misappropriated  investors  '  funds by tran sferring approximately 45 % to 
Worldw ide and Geivelis, 45% to accounts for the  benefit ofButts, and I 0% to the sa les agents as 
undi sclosed  compensation. 
42. Anisky, Express Commercial, Banner, and Baggs engaged in deceptive acts in 
furtherance 
ofthe  scheme by offering  and selling  investments in a  fictitiou s  trading p rogram, and 
receiving undi 
sclosed compensa tion ofapproximately I 0% of the in vesto rs' fund s. 
43. A lthough Worldwide Funding, Geivelis and Butts represented that investors' fund s were 
to be u
sed  to pay bank charges to acquire the SBLC, they misappropri ated the fund s dis tTibuting 
them  to 
Worldwide Funding ' s bank account for Geivelis '  p ersonal benefi t, to  vari ous accounts 
contro lled by Butts, to  the sales agents and the reliefdefendants. 
44. Butts paid Worldwide Funding and Geivelis approximately $ 1,883,375 into  the 
W orldwide Chase 
account ending  in 273 5 from investors' funds received into the Butts PA trust 
accounts. 
45. Butts and Butts PA p aid approximately $662,800 of investors' fund s received into  the 
Butts 
PA trust account to an account a t Sabadell in the name of Bernard H . Butts PA ending  in 
9 124. 
46. 
Butts paid approximately $3 13,500 to Butts Holding' s  account a t Well s Fargo Bank 
ending  in 998 1 from investors' fund s received into  the Butts PA trust accounts. 
47. Butts paid approximately $4 17,000 to his Wells Fargo Bank account ending in 2779 from 
invest
ors' fund s received into  the Butts PA trust accounts. 
48. Butts paid approxima tely $ 104,000 to his JP Morgan  Chase ch eckin g account ending  in 
9690 fro m investors '  funds  received into the Butts PA trust accounts. 
49. Butts paid approximately $ 100,000 to his and Margaret Hering's Credit Suisse Bank 
acco unts  ending  in 11 39 or 2385. 
8 


50. Butts paid approximately $25,000 to his HBSC Bank  account ending in 3879 from 

investors '  funds received into the Butts PA tru st accounts. 

51. 
Butts paid approximately $40,000 to his account with AETRS Cardmember D epository 
in 
New Delhi, India. 
52. 
Butts paid approximately $24,960 to Global Ventures account at Chase ending  in 9900 

from inv
estors' funds received into the Butts P A trust accounts. 

53. 
Butts paid Anisky approximately $86,768 in in ves tors' funds to Anisky' s company PW 
Consulting's Bank Atlantic account ending  in 8 107 from the Butts PA trust account. 
54. 
Butts paid Banner approximately $9 1,250 to Banner' s company  Express Commercial's 
account at Chase endin g  in 13 86 from the Butts PA trust account. 
55. 
Butts paid Baggs approximate ly $4,970 to Baggs'  company Capital Express fro m 
investors '  funds received into  the 
Butts PA trust account. 
56. Geivelis and Butts a cted w ith 
scienter because they knew tha t n o Worldwide Funding 
trading program existed, b
ecause  they misapprop1iated all of the investors'  funds for their own 
personal benefit and did not use any investors' funds to obtain a ny SBLCs.  Geiveli s and Butts 
a lso 
knew that they had never completed  a loan  transactio n or provided eith er  the promised  loan 
proceeds or retum on investment back to  the inves tor. Geivelis' know ledge is attributed to 
Worldwide Funding. 
57. Anisky, Ba
nner, and Baggs acted with scienter because they each knew, or  were reckless 
in 
not knowing, that the prime bank instrument trading program did not exist because ofthe 
extraordinary and unrealistic  returns th
ey cla imed  were paid , w hen  they h ad no s ubstantive 
support for their statements . Banner' s  knowledge is attributed to Express Commercial. 
5 8. 
The defendants used Interne t websites, e  mails, te lephone calls, and wire transfers  in 
connection with 
the offer and sale ofthe investments  in the fictitious Worldwide Funding trading 
program. 
VI. DEFENDANTS MADE FALSE AND MISLEADING 

STATEMENTS 
OR OMISSIONS OF MATERIAL FACT 

59. From at least April 2012  to  the  present, World wide Funding, G eivelis, Butts, A nisky, 
Express Commercial, Banner and Baggs offe red and sold the Worldwide Funding trading 
program to  in
vestors over the Internet, through emails  and te lephone calls, and receiv ed 
inves
tors '  fund s into the Butts P A trust account through  wire transfers. 
9 


60. Since April 20 12, Worldwid e Funding, Geiveli s, Butts, Anisky, Express Commercia l, 

Banner, a nd 
Baggs distribu ted offe rin g materials  to inves tors which described the investment. 

61. Since April 2012, 
World wide Funding, Geiveli s,  Butts,  Anisky, Express Commercial, 
Banner, and Baggs  made 
fal se and mis leading statem ents and omitted material fac ts in their' offer 
or sa le 
of investmen t con tracts in Wo rld w ide Funding 's fictitiou s  trading program. 
62. Since 
April 2012, in co nversations and emails with investors and offering  materia ls, 
Worldwide Funding, Geivelis,  Butts, Anisky, Express Conunerc ial, Banner, and Baggs described 
the Worldwide Funding trading program and represented among o ther  things th at the investor's 
funds of between $60,000 and $90,000 were used to acquire a SBLC from a banking group in 
Europe. An investor would receive an initial r  eturn ofapproximately €6 .6 m illio n Euros within 
15 to 45 banking days. 
63. In co nference ca ll s with investors  th at occurred since 
April2012, W orld w ide Fund ing, 
Geiveli
s, and Butts also represented that afte r th e initial payout, an investor would receive a 
weekly return on in vest
ment of approximately 14% over the next 40 to 42 weeks .  Geivelis 
explained that the r
eturns  were generated by leveraging the face value of the SBLC and  us ing th e 
leveraged funds in a sec urities trading program. Butts confirm ed these represent
ations in the 
conference calls with investors. 
These same misrepresentations also appeared in Worldwide 
Funding
's offering materials th at Geivelis prepared and signed. 
64. 
The defendants' material representations about the existence of the Worldwide Fundi ng 
trading program were fa l
se and mis leading because the trading program did not exist. 
65. Since April 20 12, Worldwide Funding, Geivelis, Butts, Anisky, Express Commercial, 
Banner, and Baggs represented in ema
ils and conversations with investors that an investor's 
fund s were sa.fe and secure  beca use they rema ined in Butts' attorney tm st account until the 
SBLC was secured and validated . 
66. Butts,  Geive
lis and Worldwide Fund ing also made similar misrepresentations about the 
safety and security 
of inv estor's fund s in the Escrow Agreement they signed with the investor. 
In the Escrow Agreement, Butts,  Geivelis,  and Worldwide Funding represented that the 
investor
's " Funds sha ll be held in escrow until Worldwide Funding ... has performed p er the 
contract between them and [inves tor], attached hereto and 
made a part hereof. "  They represented 
that Butts agreed " to act 
as escrow agent without compensation under this agreement and to 
disburse th e Funds 
in accordance w ith the terms and conditions hereinafter set fo rth ." They 
10 


rep resented that Butts  was interested in the transaction as th e partner o fGeivelis and Worldwide 
Funding.  But th
ey fail ed to disclose that Butts immediately withdrew approximately 45% of the 
in ves tor
's funds as  his personal compensation. 
67. In th e Worldwide Funding Agreement signed by 
Geiveli s on  behalfof Wo rld wide 
Funding that was m ade part 
of the Escrow A greement, Worldwide Funding, Geiveli s and Butts 
represented that an in ves
tor's fund s will be used " to pay certa in bank charges of approximately 
USD $60,000.00 
.. . for acquiring [an] instnm1ent and deli vering the instrument to the program 
providers trading acco unt." 
They represented, "Upon authentication instrument provider will 
issue an 
MT-760 cash backed SBLC to program providers account in Barclay's UAE.... The 
receiving  bank wi ll send a responsive SWIFT Wire transmiss ion to se nding bank ac knowledging 
its receipt. 
... In the event [the documents are] not authenti cated and validated by the receiving 
bank and its Client\account beneficiary, then such fund s shall in no event be released  by the 
escrow 
agent's account. ... The receiving bank must send a responsive SWIFT transmission to 
acknow ledge it receipt 
of the sam e." 
68. Contrary to these repre
sentations of Worldwide Funding, Geivelis, Butts, Ani sky, 
Express Commercial, 
Banner, and Baggs in the Worldw ide Funding Agreement and Escrow 
Agreement, or  in conversations  with investors,  investors '  fund s were not safe and secure because 
B utts immedi ately rel eased the 
funds to Worldwide Funding and Geiveli s,  himself, and the sa les 
agents. No funds  were used to acquire SBLC and B utts recei
ved no acknowledgement from the 
receiving 
bank that a SBLC was ever delivered. 
69. 
The defendants '  material representations about the safety of investors' fund s to be held 
and remain in the escrow acco
unt were fal se and misleading. 
70. Wo rld w ide Funding, 
Geivelis, Butts, A11isky, Express Commerc ial, Banner, and Baggs 
made fal se and 
mislead ing statements ofm aterial fact in conversations with inves tors and in the 
offering materials  that investor 
's fund s were to be used to acquire a SBLC. 
7 
1. Con trary to their representations,  Gei veli s, Worldwide Funding, Butts Anisky, Express 
Co mmercial, Banner, and Baggs did not u
se investors' fund s  to pay bank charges to acquire a 
SBLC. 
72. Geiveli s and Butts knew their statements about th e use 
of inves tors '  fund s  were m aterial, 
false and misleading. 
Geivelis' knowledge is attributed to Wofld w ide Funding.  T hey fail ed to 
disclose th at they misappropriated all 
of an in vestor's fun ds to pay them selves and the sales 
I 1 


agents, and that no  funds were used to pay bank charges to acquire SBLCs. 
73. After an investor depos ited funds into Butts '  trust accoun t, Bu tts immediately disbursed 
the fund s as compensation to the defendants. He d istributed approximately 45% to the 
Worldwide Chase account for th e benefi t 
ofGeivelis, I 0% to the broker, and 45% to Butts' 
perso nal account
s. Butts knew th at he used at leas t 45% of in vestors' funds for his own persona l 
benefit and that none 
of the  fund s he received were used to pay bank charges to acquire a SBLC 
as represented to investors. 
74. As the sole 
manager and owner of Worldw ide Funding and signatory on the Worldwide 
Chase account, Geivelis knew th at he used at least 
45% of investors' funds for his personal 
benefit a
nd that none of the funds were used to pay bank charges to acquire a SBLC as 
represented to investors. 
Geivelis used investor funds for numerous personal expenses, including 
gambli
ng and travel. 
75. . Butts and Geivelis  knew that the app rox imately  I 0% of in vestors' fu nds paid to the 
brokers was n
ot for payment of bank charges to acquire SB LCs as represented to investors. 
76. Anisky, Express Commercial, Banner and Baggs knew th e ir statements about the u
se of 
an  investor's funds were fa lse becau se they received approximately  I 0% of the investor's funds, 
contrary to their re
presentation that the f·unds wou ld  be used to acquire a SBLC. Their 
representations that as intermediaries th
ey received a commission after the transaction and 
trading was completed 
were also false because they were compensated out of investors'  funds 
before an y SBLC was 
ever purchased. 
77. During at least one 
of the conference ca ll s with in vestors, Geivelis and Butts  represented 
that 
Geivelis had completed thirty  SBLC transactions. Geivelis knew that statement was false as 
he had completed no  transactio n
s. Butts  knew, or  was reckless in not know ing, the statement 
was false because the agreements  with in ves tors provid ed  that any earnings from the trading 
program 
were to be paid into his attorney trus t account for distribution to the investors, and  that 
never happened. 
78. Ani s
ky is engaged in th e business of induci ng in vestors or attempting to induce investors 
to purcha
se securities, including the investment contracts offered by Worldwide Funding. 
79. From 
at least June 20 12 .through October 20 12, Anisky offered investm ents in the 
Worldw ide Funding  trading program through emails sent 
over the Internet and telephone calls. 
80. Ani sky offered 
an in ves tment of $60,000 to obtain a  $ 10,000,000 non-recourse loan 
12 


through Wo rldw ide Funding  trading progra m.  Among oth er things, he represented the $60,000 
was used to cover 
the costs  to acquire th e banking instrument and tha t th e $60,000 deposit was 
held under an Escr
ow Agreem ent with Butts  PA , whi ch was full y insured and ref1mdable. He 
re
presented  the escrowed funds are released after confim1ation  of th e acqui sition of th e 
instrument from the i
ssuing bank. He represented the process took 15 intem ational banking days 
until the  investor r   eceived the fund 
s. While  the documents he sent investors disclosed that  as 
' 
the intermediary  in the  tran sactio n, he would receive 10% of proj ect net funding and 10% ofnet 
trading profit s for one  year, he fai led to di sclose the 
materi al fact that he received approximately 
1
0% of th e investor 's funds immediately from the escro w account. 
8
1. If an inves tor was interes ted in the Worldwide Funding trading program, Anisky arranged 
f
or a  telephone confere nce call  among Geivelis, Butts,  Ani sky  and the investor. 
82. Anisky offered the investment to at l  east ten inves tors who  invested approximately 
$960,000. 
83. Butts paid A
nisky approximately 9% of the inves tor's funds received  into the Butts PA 
bust account. In to tal, Butts pa id approximately $86,768 to PW Consulting for the benefit of 
Anisky. 
84 . A ni sky 
obtained  investo rs' funds by mean s of fal se and misleading statements or 
omissio ns 
ofmaterial fact made about the investment in the Worldwide Funding trading 
program . 
8
5. Ba nner and Express C onunercial are engaged in the business of  inducing investors or 
attempting to indu
ce inves tors  to purchase securities, including the invesllnent contracts offered 
by Worldw ide Funding. 
86. Fro m at l  east J  a
nuary 20 13 tlu-ough August 20 13, Banner an d Express Commercial 
o
ffered invesllnent con tracts in W orldwide Funding's trading program which he named the 
"F A
27" program. 
87. Ba
nner, as  the  ma naging m emb er of Express Commercial, sent emails,  newsletters, 
posted 
information on  the Express Commercial 's website at www.expcomcap.com and spoke 
with investors by tele
phone about an invesllnent in the Worldw ide Funding's FA27 Proj ect 
Funding, Infras tructure 
Humanitari an & Environmental Program. 
88. B a
nner and Express Commercial made false and misleading statements ofmaterial fact in 
th eir em ails and newsle tters sent to  investors since January 20 13, amo ng other tl1ings, th at in th e 
13 


F A27 program: 
" The provider group [World wide Funding and Geivelis] purchases th e  ten 
(1OM)  SBLCs 
fro m top major banks  for cash in the nam e of the cli ent. For one yea r th e client controls 
thi s SBLC for the monetization 
& trade po1tion of thi s infrastruc ture Humanitarian & 
Enviro1m1ental Program (IHEP). The escrow agent for th e FA27 IHEP program is a 
practicing attorney in Miami, Fl orida for over 40 years.  The attorney is a partner and 
manag
ing director of the trading organization & the FA27 IHEP funding entity. The 
trad er has 23+ years 
ofexperience & is licensed with 27 banks worldwide  to do  th e lines 
of credit for th e trade." The SBLC is monet ization at 80% providing net proceeds to the 
client 
of$6,660,000 Euros . The SB LC is " leveraged up 3 to 5  tim es which max imi zes 
th e trading amount to a minimum 
of 30M to 50M trad e because th e I OM SBLC is cash 
backed. 
The trad e is normally 40 weeks. T he trader's contract states a  50% I 50 % split 
with  th e client. 
The Trader Co ntract will sta te the hi storical returns .  Each cash-backed 
1OM SBLC has a hard cost of 90K deposited into the Florida atto rney's insured Escrow 
Account. All other client's costs are charged to the monetization & trade funding returns . 
'rhe 90K is p aid after your proj ect is approved & contracts are offered to the client. " 
Banner outlined  the 
procedures to get started included to sign and return to the sender an Express 
Co
mmercial NCND; ca ll or email the sender to answer questions a bout th e IH EP program; 
request a F A27 client infom1ation fom1 and executive summ ary and; set up a co nference 
call 
with  the Escrow attom ey, Funder  and th e send er. Bam1er disclosed he received co-bro ker's fees 
of  "2. 5% 
ofclient's 6 .6M euros" after the SBLC was mon etized and "2.5% ofclients ne t 40 
week PPP trade 
paid to broker." But he did not disclose h e immediately received approximately 
10% of investor's fund s  before the SBLC was acquired. 
89. Banner  identified  the provider of th e FA27 program as Wo rldw ide Funding and Frank 
Anastasi
o; the attomey and escrow agent as Bem a rd H. Butts Jr. ; and tha t Butts is  the pmtner of 
Anas tasio the managing director o f th e trading organization. 
90. Wh
en an inves tor contacted Banner about th e FA27 program , Banner arranged for a 
co
nference call an1ong the investor, Geivelis,  Butts, and Banner. Banner and Express 
Conunercial 
offered the investment to at  l  east ten investors who invested approx imately 
$9 
19,955 . 
9
1. Butts immediately paid Banner approximately 10% th e investor's fund s  received  into the 
Butts 
PA trust account. In total, Butts paid approx imately $9 1,25 0  to  Express Comme rcia l for 
the benefit 
of Ba nner. 
14 


92. Banner obtained investors' fund s by means of false and mis leading statements  or 
omiss ions 
of material fact made about the investment in the Worldwide Funding trad ing 
program. 
93. Baggs is  engaged in the 
bus iness of inducing in vestors or attempting to induce inves tors 
to purchase securities, 
including th e investment contracts offered by Worldwide Funding. 
94. 
In or about January 2013, Baggs learned of the  Worldwide Funding' s  investment 
program from Barmer. Banner told 
Baggs  tha t an inv estment cost $80,000 a nd was completely 
safe because the fund s  were paid into Butt
's attorney tTUst account in Miami, Florida. Banner 
told Baggs the  initial payout was approximately $6,600,000 to the  investor a nd thereafter weekly 
payments 
of between $2 million and $4 milli on wo uld accm e for approximately 40 weeks. 
Banner said th a t Anastasio (Geive
lis) and Bu tts were paitners; Anastasio (Geivelis) started the 
program and made it work. 
95. Baggs had several telephone ca lls and ema
ils w ith Butts, Geiveli s and Banner who each 
confirmed the details 
of the program. Geivelis, Butts and Barmer to ld Baggs that the initial 
monies from th e customer wo uld be u sed to proc
ure a € I0 millio n SBLC from a major world 
class bank. That that letter 
ofcredit would be leveraged up to €30 million to €50 million and 
those funds would 
be used to go into a trading program. Investors' returns were to be generated 
from trading profits. A ll  t
hree assured Baggs  that the investors' money was safe in the attorney's 
trust  account and there would be no losses. 
96. 
Banner and Baggs agreed to split any comm iss ions from Baggs introducing investors to 
the 
program. 
97. 
In or about February 5, 20 13, Baggs  began offering the Worldwide Funding investment 
program to investors tlu·ough emails and te lephone ca 
lls  with investors repeating the 
mi srepresentations made to him by Geivelis, Butts and Banner. 
98. Baggs did 
not have any reasonab le basis on whi ch  to believe that the Worldw ide Funding 
trading program describ ed by Geivelis, Butts, and Banner existed. 
99. Baggs 
offered the Worldwide Funding investment to at leas t one investor who invested 
$80,000, which was w 
ired to Butts PA on or about February 19, 20 13. 
100 . 
Butts paid Baggs and Banner approximately 10% of the investor's funds received into the 
Butts  PA trust account. Butts wired $4,970 to 
Baggs' entity Capital Express Corporation and 
$4,970 to Banner
's entity Express Commerc ial. 
15 


10I. Geivelis, Butts, An isky, Ba1mer, Express Conu11ercia l and Baggs told most inves tors that 
they wo uld receive  the  initial proceeds from the €I 0,000,000 Euro  loan within fifteen to  forty­
five wo rking  days. 
102. 
After the Oiigina l  investmen ts were made and continuing  through at least August 9; 20 13, 
Worldwide Funding, Geivelis and Butts made fa lse s tatements  to investors  to  lull them into 
remaining in the investmen t program because payment ofthe clain1ed extraord inary returns on 
their investments were  inuninent, but that issues w ith the various financial institutions were 
causing 
delays. 
103. F
or example, on October 30, 20 12, Worldwide Funding and Geivelis sent a Jetter to " all 
participants  in th e  projec t  funding humanitarian p r
ogram" providing an update falsely 
representing 
"the  new ex it buyer is con tracted . .. and they have provided the necessary bank 
confirm ations 
... . At this  tim e .. . the 2 parties a re completi ng the final paperwork and  are 
preparing th e  trade to the fina l banking stage prior to di sb
ursing to th e first 3 waives ofproject 
owners. 
We will ha ve ano ther upda te  tomorrow as to  where the payouts stand . ... We 
understand  time is of the essence and it is unfortuna te  that after all this time our exit buyer 
backed o
ut last minute.... [F]unding  for waive 1, 2, and 3  th en  waive 4  and 5 will go into 
disburseme
nt state. The a ntic ipated time frame  wou ld be 7-10  days fro m the day waive 3 is 
funded." 
I 04. 
On November  15, 20 12, Worldwide Funding  and Geivelis sent another letter to all 
participants 
falsely representing, "th e first 4 wires were being cleared and . .. w ill be passed  on 
to  Bernard Butts P.A. 
We cannot advise how long this process is, however from experience of 
domestic transfers usually  it  is  a very quick tum around." 
105. 
On December 19,20 12, Worldwide Funding and Geivelis sent another letter to all 
participants  falsely rep resenting, they had forwarded information to  the bank fo r review which 
was 60% complete. "The draw request for fun ds will be completed once all fil es are app roved. 
Once the bankers are 
complete we will sign  the draw request and the Funds will be transferred 
accordingly  to 
JP Morgan Chase WWF III account in which I will turn the funds around same 
day ...." 
I 06. 
Butts also sen t various text messages to investors promising  that payments were 
imminent. 
107. F
or example, on March  25, 2013, Butts sen t a  text m essage falsely stating, " Fincen has 
16 


released Wells and they have no restrictions on  lransfening  f·unds  to Chase and Frank It's not if 
but when .... Raj and his time estimate  is  as he outlined. As soon as the fund s are trans ferred he 
will 
communicate to alL" 
I 08. 
On Jul y 3, 2013, Geiveli s emailed an investor false ly s tating  the  investor' s  funding was 
scheduled for release around 
July 12, 2013 
I 09. On July 9, 2013, Geivelis emailed an inves tor fal sely stating, "I was not authorized to 
release  your 
payment yet but I  was told end of last week that we w ill process it in the  next couple 
days and paym e
nt w ill be made to your ... account" 
110. On 
August I, 2013, Geivelis emailed an investor fal sel y stating, "You will be funded no 
later than August 12, 2013." 
11 1. Geivelis  and Butts continued to lull investors through  August 2013. ­
VII. BROKER AND DEALER 
112. From at least April 2012, Geivelis, Butts, Ani sky, Banner, Express Commercia l and 
Baggs engaged in the business of inducing or attempting to induce the purchase or sale ofthe 
securities. 
11 3. Geiveli s, Butts, Anisky, Banner, Express Commercial and Baggs each used interstate 
co
mmerce, send ing  emails and speaking by telephone w ith investors about the Worldwide 
Funding  trading  program. 
114. Geivelis and 
Butts were parh1ers in the offer and sale of the investment contracts of 
Worldw ide Funding. Each  received transaction-based compensatio n ofapproximately 45% of 
the money that investors' invested with Worldwide Funding. 
11 5. Anisky; Banner and Express Commercial; and Baggs offered the investment contracts of 
Worldwide Funding. Each  receiv ed transaction- based compensation ofapproxin1ately  10% of an 
inves
tor' s funds, with Banner and Baggs sharing  the 10% for the investor tha t Baggs introduced. 
11 6. Geivelis, Butts, Anisky, Banner, Express Commercial and Baggs were not reg istered as 
brokers, 
or associated with a  broker-dealer registered with the SEC while they induced or 
attempted to indu
ce the purchase or sale of securities. 
17 


FIRST CLAI M FOR RELIEF 
Fraud-Violations of Securities Act Section 17(a) 
[15 U.S.C. § 77q(a)] 
11 7. The SEC realleges paragi·aphs  1 through 11 6  above. 
118. D efendants Worldwide F unding, 
Geivelis , Butts, Anisky, Express Commercial, Banner, 
and 
Baggs directly and indirectly, w ith scienter, in the offer or sale ofsecurities, by u se of the 
means 
or instruments of transportation or communication in interstate commerce or by use ofthe 
m ai ls, employed a device, 
sch em e, or artifice to d efraud; obtained money or property by m eans 
ofuntrue statements ofmaterial fact or omissions  to  state material facts necessary in order to 
m
ake the statem ents made, in light of th e circumstances under w hich they were made, not 
misleading; or engaged  in transactio ns, practices, or courses of business which have been or are 
operating  as a fraud or deceit upo n  the purc hasers of the securities. 
119. re 
120. D efendants  Worldwide 
Funding, Geivelis, B utts Anisky, Express Commerc ial, Banner, 
and 
Baggs violated and unless restrained and enjoined will in the future violate Securities Act 
Section 17(a)(1) , (2) and (3). 
12 
1. Altem atively, Butts know ing ly aided and abetted the violations by Worldwide Funding 
and 
Geivelis ofSecurities Act Section 17(a)( I), (2) and (3). He provided s ubstantial assistance 
in th
eir commission ofthe primary  violation by acting as the escrow agent to receive investors' 
funds, distributing funds  to the defendants 
and  reliefdefendants although no SBLCs were 
acquired, and be and th e other defendants were no t to be compensated until after the trading 
program was complete. He also lulled investors into not tem1inating their investments, reassuring 
them that their returns were imm inent. 
SECOND CLAIM FOR RELIEF 

FRAUD-VIOLATIONS OF EXCHANGE ACT SECTION lO(b) AND RULE lOb-S 

[15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-S] 

122. T h e SEC realleges paragraphs  1 through 116  above. 
123. Defendants 
Worldwide Funding, Geivelis, Butts, Ani sky, Express Commercia l, Banner, 
and 
Baggs, directly or indirectly, with scienter, in connection with the purchase or sale of 
securities, 
by the  use ofm eans or. instrumenta li ties of interstate commerce, the mails, or any 
faci lity ofa  nationa l securities exchange, employed devices, schemes, or artifices to defraud; 
18 


made un true statements of material fac t or omitted  to sta te mate1ial facts necessary in order to 
make the statements m ade, in light of th e circum stances under which th ey were made, not 
misleadi ng; o r engaged  in acts, practices, or co
urses of business which opera  ted or would operate 
as a fraud 
or deceit upon an y person; in violation ofExchange Act Section  IO(b) and Ru le  I Ob-5. 
124. Defe ndants Worldw ide Funding, Geivelis, Butts Anisky, Express Commercial, Banner, 
ru1d Baggs vio lated and unless restrained and enjoined will in the futme v iolate Exchange Act 
Section  IO(b) and Rule IOb-5. 
125. Alte rnative ly, 
Butts knowing ly aided and abetted the violations 'by Worldwide Funding 
and Geivelis 
ofExchange Act Section  lO(b) and Ru le  l Ob-5. H e provided  substantial assistance 
in th eir commi ssion of the primary vio lation by acting as the escrow agent to receive investors' 
funds , distributi ng funds  to  th e defend ants and rel
iefdefendants  although  no SBLCs were 
acquired, and he and th e o ther defenda
nts were not to be compensated until after the trading 
program was comple t
e. He also lull ed investo rs into not tem1inating their investments, reassuring 
th em that their re  turns were imminent. 
TIDRD CLAIM FOR RELIEF 

OFFERS AND SALES OF UNREGISTERED SECUIUTIES ­
VIOLATIONS OF SECURITIES ACT SECTIONS S(a) AND S(c) 

115 U.S.C. §§ 77e(a) and 77e(c)] 

126. 
The SEC realleges paragraphs  1 through 11 6 above. 
127. Defendan ts 
Worldwide Funding, Geivelis, Butts Anisky, Express Commercial, Banner, 
and Baggs, 
directly or indirectl y, have made use of the m eans or instruments oftransporta tion or 
communication in interst
ate commerce or of the mails to sell securities, when no registration 
statem ent was 
in effect w ith the Commission as to such securi ties, and have m ade use ofthe 
means or 
instrum ents of tra  nsportation or communication in interstate commerce or of the mails 
to offer to sell such securiti es when no registration statement had been filed with the 
Commission as to such  securiti es. 
128. T
here were no appli cable exemptions from registration, and  Defendants Worldwide 
Funding, Geivelis, 
Butts Anisky, Express Commercial, Banner, and Baggs therefore violated, 
a nd unless restrained a
nd enj oined wi ll in the future violate Sections 5(a) and 5(c) of the 
Securi
ties Act. 
19 


FOURTH CLAIM FOR RELIEF 

OFFERS AND SALES OF SECURlTIES BY AN UNREGISTERED BROKER-DEALER 
VIOLATIONS 
OF EXCHANGE ACT SECTION lS(a) 
115 U.S.C. § 78o(a)] 
129. The SEC  realleges paragraphs 1 through 11 6 above. 
130. Defendants Geivelis, Butts Anisky, Express Commercial, Banner, and Baggs, while 
e
ngaged in the  business of effecting transactions in securities for the account ofo th ers, m ade use 
of the mail s 
or the means or instrumentalities of interstate commerce to effect transactions  in, or 
to induce or attempt to induce the purchase or sale of, a security w ithout being registered  in 
accordance with Section 15(a) 
of the Exchange Act. 
131. Defendants Gei velis,  Butts Anisky, Express Commercial, Banner, a
nd Baggs, have 
violated, and w1less restra
ined and enjoined will in the  future violate Section 15(a) of the 
Exchange Act. 
FIFTH CLAIM FOR RELIEF 

UNJUST ENRICHMENT OF RELillF DEFENDANTS 

132. The SEC realleges paragraphs  1 through 11 6 above. 
133. Rel
ief defendants B ernard H. Butts Jr. PA, Butts Holding Corporation, Globa l 
Worldwide Fw1ding Ventures, Inc. , 
Margaret A. Hering, and PW Consulting Group LLC, each 
obtained funds as 
part, and in furtherance ofthe securities vio lations alleged above w ithout a 
legitimate claim to th
ose funds, and und er those ci1·cum stan ces it is  not j ust, equitabl e or 
conscionable for them to retain the funds. Bernard H. Butts Jr. P A, Butts Holding Corporation, 
Global Worldwide Funding Ventures, Inc., Margaret 
A. Hering, and PW Consult ing Group Inc. 
were unjus
tly enriched. 
134. Bernard H. Butts Jr. PA, Butts H olding Corporation, Gl obal Worldwide Funding 
Ventures, Inc., Margaret A. Hering, and PW Consulting Group Inc. should each  be ordered to 
di sgo rge the funds th
ey received  as a result of the defendants '  violations of the federal securities 
laws. 
PRAYER FOR RELIEF 

The SEC respectfull y requests th at this Court: 

I. 
Enter an Order finding that D efendants  Worldw ide  Funding,  Geiveli s, Butts, A ni sky, 
20 


Express Commerc ial , Banner, a nd B aggs committed  the  v io lations a lleged in this  complaint, and 
unless res trained will continue  to do  so. 
II. 
Enter an injunction, pursuant to Rule 65(d) of  the F ederal Rules  of Civil Procedure, 
pem1anently restraining and enjo ining  D efendants  W o rldwide Funding, Geivelis, Butts, A nisky, 
Express Commercial,  B a nner, and Baggs from furth e r  v io lati on s  o f the  law and mles a lleged  in 
this compla int. 
III. 
Enter an Order requmng Defendants Worldwide Funding, Geivelis , Butts, Anisk y, 
Express Commercial, Banner,  and Baggs  to prepare accountings of a ll funds received from 
investors  identifying the nam e  of each  investor,  the dollar amount received, elate o f  receipt, and 
how those funds were spent. 
I V. 
Enter an Order requmng Defenda nts Wo rld w ide Funding, Geivelis, Butts, Anisky, 
Express Commercial,  B anner, a nd Baggs to d isgorge all ill-gotten gains  in the form of any 
benefits of any kind derived from the  illegal  conduc t  a lleged in this complaint, together w ith 
prejudgment and post judg m ent interes t and to  re patriate  to the registry of the Court a ny investor 
funds b eing held in foreign jurisdictions. 
V. 
Enter an Order requ iring Defendants Worldwide Funding, Geivelis, Butts , Anisky, 
Express Commercial , Banner, and Baggs to pay third tier civil money penalties pursuant to 
Securities A ct Section 20(d) [15 U.S.C. § 77t(d)) and Exchange Act Section 2 1(d) [15 U .S.C. § 
78u(d)) . 
VI. 
Enter an Order requiring Bernard H . Butts, Jr. PA; Butts Holding Corporation; Global 
Worldwide Funding Ventures, Inc. ; Margaret A. Hering; and PW Con sulting Group LLC to 
disgorge funds  that they  received that w ere  the proceeds of illegal activities ofothe r defendants. 
2 1 


VII. 
Order such other rei ief as thi s Court deems necessary and appropriate. 
DATED: August 29, 2013 
Respectfu ll y submitted, 
s/L
eslie J. Hughes 
Lesli e 
J. Hughes, (Special Bar No. A5500503) 
Securities and Exchange Commission 
180 1 Ca 
lifornia Street, Suite 1500 
Denver, Colorado 80202 
Main numb
er 303-844-1000 
Direct number 303-844-1086 
Fax number 303-844-1 068 
Email: HughesLJ@ sec.gov 
22 

UNJTED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Secmities a nd Exchange Commission, 

Plaintiff, 
FILED by_ __ D.C. 

V. Case No. 
AUG 2 9 2013 

Bernard H. Butts, Jr. , 
Fotios Geiveli s, Jr. , also known as Frank Anastasio"lf 
Worldwide Funding Ill Limited LLC, .ll 
Douglas J. Anisky, 
Sidney Banner, UNDER SEAL 
Express Commercial Capital LLC, 
James Baggs, 

Defendants, 

Bernard H. Butts, Jr. PA, 
Butts Holding Co rporatio n, ,f MCALILEY 
Margaret A. Hering, 
Global Worldwide Funding Ventures, Inc. , 
PW Consulting Group LLC, 

Relief Defendants. 

PLAINTIFF'S COMPLAINT FOR SECURITIES FRAUD, 
INJUNCTION AND OTHER RELIEF 

Plaintiff Securities and Exchange Commission ("SEC") alleges for its complaint against 

defendants Florida attorney Bernard H. Butts, Jr. , Fotios Geivelis Jr. , who used the alias Frank 

Anastasio, and his company Worldwide Funding III Limited LLC ("Worldwide Funding"), and 

sales agents Dougla s J. Anisky, Sidney Banner and his company Express Commercial Capital 

LLC ("Express Commercial"), and Jam es Baggs; and relief defendants Bernard H. Butts, Jr. PA 

("Butts PA "), Butts Holding Corporation ("Butts Holding"), Margaret A. Hering, Global 

Worldwide Funding Ventures, Inc. ("Global Ventures"), and PW Consulting Group LLC ("PW 

Consulting"): 

I. SUMMARY 

I. From at least April 2012 through the present, Florida attorney Bernard H. Butts, Jr., 

Fotios Geivelis Jr. , who used the alias Frank Anastasio, and his company Worldwide Funding, 



and sales agents Anisky, Banner and his company Express Co mmercial, and Baggs obtained 


millions of dollars by defrauding investors through the offer and sale of investments in a 


fictitious prime bank instmment trading program. 


2. G eiveli s·and Butts paid sales agents including Anisky, Ba1mer, Express Commercial, and 

Baggs to Jure inves tors through the Internet, telephone, and personal contact into the scheme 

with promises of extraordinary profits. As part of the scheme, defendants told investors that an 

investment of between USD $60,000 and $90,000 would genera te profits of at least €6,6 60,000 

(Euro) within 15 to 45 business days and continue to earn profits of approximately 14% per week 

for 40 to 42 weeks. 

3. Defendants falsely promised that when an investor's funds were deposited into Butts' 

attorney trust account, Butts would not release the f1mds until he received proof from the 

receiv ing bank that a € 10,000,000 Standby Letter ofCJ·edit ("SBLC") had been deposited into a 

secmities .trading program which was to generate the profits for the investors. 

4. Defendants did not disclose that instead ofusing the funds to obtain SBLCs, they 

misappropriated inves tors' funds with Geivelis and Butts each ta king approx im ately 45% and 

paying approximately 10% to the sales agents. Contrary to the defen dants' representations, the 

acquisition of the SBLCs never occurred, no loans were obtained, and no pro mised returns were 

earned in a trading program or paid to investors. Over more than a year, the defendants obtained 

at least $3.5 million from approximately forty-five investors nationwide and in fo reign countries 

by making false and misleading statements or omitting mate1ial facts in the offer and sale of 

these unregistered securities. 

5. To keep the scheme going, Geivelis and Butts also made lulling statements to inves tors, 

representing that the trading program was successful and that payments to inves tors were 

imminent. 

6. Through these actions, Geivelis, Worldwide Funding, Butts, Anisky, Ba1mer, Express 

Commercial, and Baggs violated, and unless restrained and enj oined will continue to violate, the 

antifraud provisions of Section 17(a) of the Securities Act of 1933 (" Securities Act"), 15 U.S.C. 

§ 77q(a), Section lO(b) of the Securities Exchange Act of 1934 ("Exchange Act"), 15 U.S.C. § 

78j(b), and Rule lOb-5 , 17 C.F.R. § 240.10b-5. 

7. In addition, Geivelis, Worldwide Funding, Butts, Anisky, Banner, Express Commercial, 

and Baggs offered and sold securities in the form of investment contracts, which were no t 

2 




registered w ith the SEC at the tim e they were sold , in violation of the securities registration 

provisions ofSection5(a) an d (c) of the Securities Act, 15 U.S .C. § 77e(a) and (c), and unless 


restrained and enjoined will continue to violate these secu rities registration p rovisions. 


8. Geivelis, Butts, Ani sky, Express Comm ercial, Ba nner, and Baggs also acted as broker-

dealers in vio lation of the registration provisions of Section 15(a)( I) of the Exchange Act, 15 

U.S.C. § 78o(a)(l ), and u nless res trained and enjo ined will continue to violate the broker-d ealer 

registration provisions . 

9. Reliefdefendants Bernard H. Bu tts, Jr. PA, Butts Hold ing Corporation, Global 

Worldwide Funding Ventures, Inc., Marga ret A. Hering, and PW Consulting Group LLC 

received investors' fund s to which they had no legiti mate claim and were u njustly enriched. 

II. JURISDICTION AND VEN UE 

10. The SEC brings thi s action u nder Section 20(b) of the Securities Act, 15 U.S.C. § 77t(b) 

and Section 2 1(d) and (e) of the Exchange Act, 15 U.S.C. § 78u(d) and (e), to restrain and enjoin 

the defendants from engaging in the acts, prac tices and courses of bus iness d escribed in thi s 

Complaint, and acts, practices an d co urses o f business of similar purp01t and object. T he 

Commission seeks permanent injunctions, di sgorgeme nt of ill-go tten gains derived fro m the 

conduct alleged in the Complaint plus prejudgm ent in terest, and third-tier civil penalties w1der 

Section 20( d) of the Securities Act, 15 U.S.C. § 77t(d) and Section 2 1 ( d)(3) of the Exchange Act, 

15 U.S. C. § 78u(d)(3). 

11. Tllis Court has jurisdiction under Section 22(a) of the Securi ties Act, 15 U.S. C. § 77v(a) 

and Section 27 o f the Exchange Act, 15 U.S.C. § 78aa. The defendants, directly or indirectly, 

made u se o f the means and instrumenta lities of interstate commerce or of the mails, in 

connection with the acts, practi ces and courses o f bus iness alleged in the Complaint. 

12. Certain of the acts, practices, and co urses of business constituting violations of law 

alleged in the Complaint occurred within the Southern District of F lorida. In addition, Butts 

Banner, and Anisky reside in the Southern District of Florida . Express C ommercial conducts 

business fro m the Southern District of F lorida . 

III. DEFENDANTS 

13. Defend ant Bernard H. Butts, Jr ., born in 194 1, is an attorney admitted to practice law in 

Florida. H e resides and tran sacted business in M iami, Florida. He entered in to numerous escrow 

3 




agreements with Worldwide Funding, Geivelis and investors from his offices in Miami, Florida. 

14. Defendant Fotio s Geivelis, Jr., bom in 1979, is a resident ofTampa, Florida and used the 

name "Frank Anastasio" in dealing with investors. Geivelis transacted business in Miami, 

Florida by entering into numerous escrow agreements with Butts and the investors related to the 

transactions at issue in this case. 

15. Defendant Worldwide Funding III Limited LLC is a Florida limited liability company 

organized on March 1, 2012, w ith its principal place of bu siness in Fort Myers, Florida. 

Worldwide Funding transacted business in Miami, Florida by entering into numerous escrow 

agreements with Butts and the investors related to the transactions at issue in this case. Geivelis 

is the sole managing member and owner of Worldwide Funding LLC. 

16. Defendant Douglas J. Anisky, bom in 1957, is a resident of Delray Beach, Florida. He 

is a sales agent that finds in vestors for Worldwide Funding and receives transaction based 

commissions. H e tTansacted business in Miami, Florida by participating in telephone conference 

calls among investo rs, Geivelis, B utts and himself, and receiving commissions from Butts' l!us t 

account in Miami, Florida. 

17. Defendant S idney Banner , bom in 1927, is a resident of Delray Beach, Florida. He is a 

sales agent that finds investors fo r Worldwide Funding and other investment programs and 

receives transaction-based commissions. He transacted business in Miami, Florida by arranging 

and participating in telephone conference call s among investors, Geivelis, Butts and himself, and 

receiving commissions from B utts' llust account in Miami, Florida. 

18. Defendant Express Commercial Capital LLC is a Fl01ida limited liability company that 

conducts business from Delray Beach, Florida. Express Commercial is a bro ker that fmds 

investors for Worldwide Funding and other inves tment programs and receives n·ansaction-based 

commissions from Butts ' trust account in Miami, Florida. Banner and his wife are managing 

members of Express Commercial. Express Commercial, through Banner, transacted business in 

Miami, Florida by arranging and participating in telephone conference calls among investors, 

Geivelis, Butts and himself, and receiving commissions from Butts' trust account in Miami, 

Florida. 

19. D efendant James Baggs, born in 1942, is a resident of Lake Forest, California. Baggs is 

a sales agent that finds investors for Worldwide Funding and other investment programs and 

receives transaction-based conm1issions from a bank account held in the name of Bemard H. 

4 




Butts Jr. P.A. in Miami, Florid a. 

20. Relief defendant Bernard H. Butts Jr. P.A. is a F lorida corpo ration. It does business as 

"The Law Offices of Butts & Mertz" and its principal place of ~usiness is in Miam i, Florida. 

Butts is the owner of Butts PA. 

21. Relief defendant Butts Holding Corporation is a Florida corporation with a principal 


place of business in Miami, Florida. Butts is the president and only officer of Butts Holding. 


22. Reliefdefendant Margaret A. Hering, age 70 , is a resid ent of Miami , Florida and is 


Butts' wife. 


23 . Reli ef defendant Global Worldwide Funding Ventures, Inc. is a Flo rida corporation 

with a principal place of business in Fort Meyers, Florida. Geivel is is the president and onl y 

officer of Globa l Ventures. 

24. Relief defendant PW Consulting Group LLC is a Florida limited liabi li ty company with 

its principal place of business in Delray Beach, Florida. Anisky is the managing member ofPW 

Consulting. 

IV. OFFER AND SALE OF UNREGISTERED SECURITIES 

25. In March 2012, Geivelis formed Worldwide Funding with its principa l office in Fort 

Myers , Florida. 

26. In May 20 12, Geivelis opened a bank acco unt for Worldwide Funding with JPMorgan 

Chase Bank, N.A. (" Worldwide Chase account") in Midland Park, New J ersey, w ith an initial 

depos it of $40. The bank account s tatements were mailed to a house where Geivelis lived in 

Wyckoff, New J ersey until approximately April 2013, when Geivelis moved to Tampa, Florida. 

Geivelis was the sole signatory o n the account and controlled the funds in th e Wo rld wide Chase 

account. 

27. Worldwide Funding has a website at www.worldwidefund ingiii.com created by G eivelis, 

which states it is a "commercial funding brokerage and consulting firm. " 

28. From in or about April2012 and continuing to date, Worldwide Fundi ng, Geivelis, and 

Butts as Geivelis' partner, and their sales agents: Anisky, Express Conunercial, Banner and 

Baggs offered and so ld securities in the form of investment contracts in a fraudu lent prime bank 

scheme. 

29. The investments contracts offered by the defendants were securities. The investment 

con trac ts required inves tors to invest between $60,000 and $90,000, which was transferred to 

5 


http:ingiii.com
www.worldwidefund


Butts ' attorney trust account fo r the bene fit of Wo rld wid e Fund ing. Geivelis and Wo rldw id e 

Funding were to use the investors' fu nds to pay banking charges to lease Stand by Letters of 

Credit (" SBLC") in the amount of€ 1 0,000,000 from a banking grou p in Europe. Geivelis and 

W orldw ide we re to leverage the SBLC to invest in a sec uriti es trading program tha t was to 

generate a rate of return of approximately 14% per week. Investors' profits were to come from 

the effo11s of Geivelis, Wo rldw ide Funding, and the trading program . 

30. Worldwide Funding through Geive lis as its managing member, Butts , Anisky, Express 

Commercia l through its m anaging m ember Ba1mer, and Baggs communicated with investors 

thro ugh electronic mail ("ema il") and telephone ca lls . World w ide Funding and Geivelis, and 

Express Commercial and Banner also have websi tes tha t offer the investments. 

3 1. Since April 20 12, Wo rldw ide Fund ing, Geivelis and Butts also distributed offering 

m aterials to investors that describ ed the investment, includi ng Worldwide Funding's A greem ent, 

Escrow Agreement, Financ ial Service Agreement, Trading Agreemen t and Settl ement 

Statements. 

32. Worldwide Funding, Geiveli s, and Butts represented in the offerin g materials and in 

conversations with investo rs tha t an inves tor paid $60 ,000 to $90,000 to Worldwide Funding for 

bank charges to lease an SB LC in the amount of € 10,000,000 from a banking group in Europe. 

They also represented that the investor' s fund s were held in Butts PA 's attorney tmst account, 

and would not be released until delivery of the SBLC was co nfirmed by the receiving bank, 

Barclays Bank in the United Arab Emirates. In addi tion, they represented that they arranged for 

a third-party to transfer the SBLC to Barc lays Bank, which would acknow ledge receipt of the 

SBLC. They also represented the SB LC was used to acquire a loan, with the fund s from the loan 

placed in a securities trading program that generated a return on investment of approx imately 

14% per w eek for approximately 42 weeks. 

33. Worldwide Funding, Geiveli s, and Butts used sales agents to solicit investors for the 

W orldwide Funding trading prog ram and paid them approximate ly 10% of the investor's funds 

that we re invested. 

34. From at least April 20 12 to presen t, Anisky offered Worldwide Funding' s investment 

contracts to at least ten investors, communicated with investors and the other defend ants through 

the Internet, em ails or telephone calls, and received transaction based compensation fro m the 

sales made to inves tors, w hich was paid into the bank acco unt of PW Consulting. 

6 




35. From at least January 20 13 to the present, Express Commercial, Banner, and Baggs also 

offered Worldwide Funding 's investment contracts to at least eleven investors, communicated 

with investors and the other defendants through the Internet, emails or telephone calls, and 

received transaction based compensation from their sales made to investors. 

36. From April 2012 to date, Worldw ide Funding, Geivelis, and Butts offered and sold 

Worldwide Funding's inves tm ent contracts to at least forty-five investors and received directl y 

or indirectly approximatel y $3,687,701 from the sale of these investment contracts. The sales 

were made in Miami Florida when investors transferred their funds to Butts' attorney trust 

account. 

37. No registration s tatement was filed with the SEC or in effect for the offer or sale of 

World wide Funding 's securities by the defendants. 

V. DEFENDANTS ENGAGED IN A SCHEME TO 

DEFRAUD INVESTORS 


38. Worldw ide Funding, Geivelis, Butts, Anisky, Express Commercial, Banner, and Baggs 

used an artifice, device or scheme to defi·aud investors by offering or selling investments in a 

fictitious trading program for prime bank ins truments. Investors were lured into the scheme with 

the promise of € l 0 millio n non-recourse loans to use for their business or humanitarian projects 

and ex traordinary rate of return of approxima tely 14% per week from an international trading 

program. In fact, no Worldwide Funding trading program existed and the defendants did not 

obtain SBLCs to leverage in an international trading program to produce the tremendous returns 

promjsed by the defendants. 

39. Prime bank trading programs such as those offered by Worldwide Funding, Geivelis, 

Butts, Anisky, Express Commercial, Banner, and Baggs are fictitious . The Securities Exchange 

Commission, the Federal Reserve Bank, the International Monetary Fund and numerous other 

federal and international authori ties have all publicly denounced these bank inst:mment program 

frauds in easily obtainable information. 

40. Worldwide Funding and Geivelis engaged in deceptive acts in furtheranc e of the scheme 

by offering and selling investments in a fictitious trading program and by creating false 

Worldwide Funding offeting materials and agreements that made it appear they were offering a 

real investm ent when they never acquired the SBLCs or participated in the trading program as 

represented. The offering m aterials were just a device to obtain investor money for defendants ' 

7 



personal benefit. Worldwide Funding and Geivelis misappropriated investor funds and did no t 


use them to pay banking fees to acquire SBLC. 


41. Butts engaged in deceptive ac ts in furtherance of the scheme by offe1ing and selling 

investments in a fictitious trading program, entering into the Escrow Agreements in w hich he 

agreed to only release the investors' f1mds after receiving proof that the bank had received the 

SBLC, and representing that he was no t compensated for his work as an escrow agent. Contra ry 

to hi s agreement, Butts released the investors' funds without proof that SBLCs were acqu ired. In 

addition, Butts misappropriated investors ' funds by tran sferring approximately 45 % to 

Worldw ide and Geivelis, 45% to accounts for the benefit ofButts, and I 0% to the sales agents as 

undi sclosed compensation. 

42. Anisky, Express Commercial, Banner, and Baggs engaged in deceptive acts in 

furtherance of the scheme by offering and selling investments in a fictitiou s trading p rogram, and 

receiving undi sclosed compensa tion of approximately I 0% of the in vesto rs' fund s. 

43. A lthough Worldwide Funding, Geivelis and Butts represented that investors' fund s were 

to be used to pay bank charges to acquire the SBLC, they misappropri ated the fund s dis tTibuting 

them to Worldwide Funding' s bank account for Geivelis ' personal benefi t, to various accounts 

contro lled by Butts, to the sales agents and the reliefdefendants. 

44. Butts paid Worldwide Funding and Geivelis approximately $ 1,883,375 into the 

W orldwide Chase account ending in 273 5 from investors' funds received into the Butts PA trust 

accounts. 

45. Butts and Butts PA paid approximately $662,800 of investors' fund s received into the 

Butts PA trust account to an account at Sabadell in the name of Bernard H . Butts PA ending in 

9 124. 

46. Butts paid approximately $3 13,500 to Butts Holding' s account at Well s Fargo Bank 

ending in 998 1 from investors' fund s received into the Butts PA trust accounts. 

47. Butts paid approximately $4 17,000 to his Wells Fargo Bank account ending in 2779 from 

investors' fund s received into the Butts PA trust accounts. 

48. Butts paid approximately $ 104,000 to his JP Morgan Chase checkin g account ending in 

9690 fro m investors ' funds received into the Butts PA trust accounts. 

49. Butts paid approximately $ 100,000 to his and Margaret Hering's Credit Suisse Bank 

acco unts ending in 11 39 or 2385. 

8 




50. Butts paid approximately $25,000 to his HBSC Bank account ending in 3879 from 


investors ' funds received into the Butts PA tru st accounts. 


51. Butts paid approximately $40,000 to his account with AETRS Cardmember D epository 

in New Delhi, India. 

52. Butts paid approximately $24,960 to Global Ventures account at Chase ending in 9900 


from investors' funds received into the Butts P A trust accounts. 


53. Butts paid Anisky approximately $86,768 in inves tors' funds to Anisky's company PW 

Consulting's Bank Atlantic account ending in 8 107 fro m the Butts PA trust account. 

54. Butts paid Banner approximately $9 1,250 to Banner's company Express Commercial's 

account at Chase ending in 13 86 from the Butts PA trust account. 

55. Butts paid Baggs approximate ly $4,970 to Baggs' company Capital Express fro m 

investors ' funds received into the Butts PA trust account. 

56. Geivelis and Butts acted w ith scienter because they knew that n o Worldwide Funding 

trading program existed, because they misapprop1iated all of the investors' funds for their own 

personal benefit and did not use any investors' funds to obtain any SBLCs. Geivelis and Butts 

also knew that they had never completed a loan transactio n or provided either the promised loan 

proceeds or retum on investment back to the inves tor. Geivelis' know ledge is attributed to 

Worldwide Funding. 

57. Anisky, Banner, and Baggs acted with scienter because they each knew, or were reckless 

in not knowing, that the prime bank instrument trading program did not exist because of the 

extraordinary and unrealistic returns they claimed were paid , w hen they had no substantive 

support for their statements. Banner's knowledge is attributed to Express Commercial. 

58. The defendants used Internet websites, emails, telephone calls, and wire transfers in 

connection with the offer and sale of the investments in the fictitious Worldwide Funding trading 

program. 

VI. DEFENDANTS MADE FALSE AND MISLEADING 

STATEMENTS OR OMISSIONS OF MATERIAL FACT 


59. From at least April 2012 to the present, World wide Funding, G eivelis, Butts, A nisky, 

Express Commercial, Banner and Baggs offered and sold the Worldwide Funding trading 

program to investors over the Internet, through emails and telephone calls, and received 

investors ' fund s into the Butts P A trust account through wire transfers. 

9 




60. Since April 20 12, Worldwid e Funding, Geivelis, Butts, Anisky, Express Commercia l, 


Banner, a nd Baggs distribu ted offe rin g materials to inves tors which described the investment. 


61. Since April 2012, World wide Funding, Geiveli s, Butts, Anisky, Express Commercial, 

Banner, and Baggs made fal se and mis leading statem ents and omitted material fac ts in their' offer 

or sa le of investmen t con tracts in Wo rld w ide Funding 's fictitiou s trading program. 

62. Since April 2012, in co nversations and emails with investors and offering materials, 

Worldwide Funding, Geivelis, Butts, Anisky, Express Conunerc ial, Banner, and Baggs described 

the Worldwide Funding trading program and represented among o ther things that the investor's 

funds of between $60,000 and $90,000 were used to acquire a SBLC from a banking group in 

Europe. An investor would receive an initial return ofapproximately €6 .6 m illio n Euros within 

15 to 45 banking days. 

63. In co nference ca lls with investors that occurred since April2012, W orld w ide Fund ing, 

Geivelis, and Butts also represented that afte r the initial payout, an investor would receive a 

weekly return on in vestment of approximately 14% over the next 40 to 42 weeks . Geivelis 

explained that the returns were generated by leveraging the face value of the SBLC and us ing the 

leveraged funds in a sec urities trading program. Butts confirm ed these representations in the 

conference calls with investors. These same misrepresentations also appeared in Worldwide 

Funding's offering materials that Geivelis prepared and signed. 

64. The defendants' material representations about the existence of the Worldwide Fundi ng 

trading program were fa lse and mis leading because the trading program did not exist. 

65. Since April 20 12, Worldwide Funding, Geivelis, Butts, Anisky, Express Commercial, 

Banner, and Baggs represented in emails and conversations with investors that an investor's 

fund s were sa.fe and secure beca use they rema ined in Butts' attorney tm st account until the 

SBLC was secured and validated . 

66. Butts, Geivelis and Worldwide Fund ing also made similar misrepresentations about the 

safety and security of inv estor's fund s in the Escrow Agreement they signed with the investor. 

In the Escrow Agreement, Butts, Geivelis, and Worldwide Funding represented that the 

investor's " Funds sha ll be held in escrow until Worldwide Funding ... has performed p er the 

contract between them and [inves tor], attached hereto and made a part hereof. " They represented 

that Butts agreed " to act as escrow agent without compensation under this agreement and to 

disburse the Funds in accordance w ith the terms and conditions hereinafter set fo rth ." They 

10 




rep resented that Butts was interested in the transaction as the partner o fGeivelis and Worldwide 

Funding. But they fail ed to disclose that Butts immediately withdrew approximately 45% of the 

in ves tor's funds as his personal compensation. 

67. In the Worldwide Funding Agreement signed by Geiveli s on behalfof Wo rld wide 

Funding that was m ade part of the Escrow A greement, Worldwide Funding, Geiveli s and Butts 

represented that an investor's fund s will be used " to pay certa in bank charges of approximately 

USD $60,000.00 .. . for acquiring [an] instnm1ent and delivering the instrument to the program 

providers trading acco unt." They represented, "Upon authentication instrument provider will 

issue an MT-760 cash backed SBLC to program providers account in Barclay's UAE.... The 

receiving bank wi ll send a responsive SWIFT Wire transmiss ion to se nding bank ac knowledging 

its receipt. ... In the event [the documents are] not authenti cated and validated by the receiving 

bank and its Client\account beneficiary, then such fund s shall in no event be released by the 

escrow agent's account. ... The receiving bank must send a responsive SWIFT transmission to 

acknow ledge it receipt of the sam e." 

68. Contrary to these representations of Worldwide Funding, Geivelis, Butts, Ani sky, 

Express Commercial, Banner, and Baggs in the Worldw ide Funding Agreement and Escrow 

Agreement, or in conversations with investors, investors ' fund s were not safe and secure because 

B utts immedi ately rel eased the funds to Worldwide Funding and Geivelis, himself, and the sa les 

agents. No funds were used to acquire SBLC and B utts received no acknowledgement from the 

receiving bank that a SBLC was ever delivered. 

69. The defendants ' material representations about the safety of investors' fund s to be held 

and remain in the escrow account were fal se and misleading. 

70. Wo rld w ide Funding, Geivelis, Butts, A11isky, Express Commerc ial, Banner, and Baggs 

made fal se and mislead ing statements ofm aterial fact in conversations with inves tors and in the 

offering materials that investor 's fund s were to be used to acquire a SBLC. 

7 1. Con trary to their representations, Gei velis, Worldwide Funding, Butts Anisky, Express 

Co mmercial, Banner, and Baggs did not use investors' fund s to pay bank charges to acquire a 

SBLC. 

72. Geivelis and Butts knew their statements about the use of inves tors ' fund s were m aterial, 

false and misleading. Geivelis' knowledge is attributed to Wofld w ide Funding. T hey fail ed to 

disclose that they misappropriated all of an investor's fun ds to pay them selves and the sales 

I 1 


http:60,000.00


agents, and that no funds were used to pay bank charges to acquire SBLCs. 

73. After an investor depos ited funds into Butts ' trust accoun t, Bu tts immediately disbursed 

the fund s as compensation to the defendants. He d istributed approximately 45% to the 

Worldwide Chase account for the benefi t of Geivelis, I 0% to the broker, and 45% to Butts' 

personal accounts. Butts knew that he used at leas t 45% of investors' funds for his own persona l 

benefit and that none of the fund s he received were used to pay bank charges to acquire a SBLC 

as represented to investors. 

74. As the sole manager and owner of Worldw ide Funding and signatory on the Worldwide 

Chase account, Geivelis knew that he used at least 45% of investors' funds for his personal 

benefit and that none of the funds were used to pay bank charges to acquire a SBLC as 

represented to investors. Geivelis used investor funds for numerous personal expenses, including 

gambling and travel. 

75. . Butts and Geivelis knew that the app rox imately I 0% of investors' fu nds paid to the 

brokers was not for payment of bank charges to acquire SB LCs as represented to investors. 

76. Anisky, Express Commercial, Banner and Baggs knew the ir statements about the use of 

an investor's funds were fa lse becau se they received approximately I 0% of the investor's funds, 

contrary to their representation that the f·unds wou ld be used to acquire a SBLC. Their 

representations that as intermediaries they received a commission after the transaction and 

trading was completed were also false because they were compensated out of investors' funds 

before an y SBLC was ever purchased. 

77. During at least one of the conference ca lls with investors, Geivelis and Butts represented 

that Geivelis had completed thirty SBLC transactions. Geivelis knew that statement was false as 

he had completed no transactio ns. Butts knew, or was reckless in not know ing, the statement 

was false because the agreements with inves tors provid ed that any earnings from the trading 

program were to be paid into his attorney trus t account for distribution to the investors, and that 

never happened. 

78. Anisky is engaged in the business of induci ng investors or attempting to induce investors 

to purchase securities, including the investment contracts offered by Worldwide Funding. 

79. From at least June 20 12 .through October 20 12, Anisky offered investm ents in the 

Worldw ide Funding trading program through emails sent over the Internet and telephone calls. 

80. Anisky offered an inves tment of $60,000 to obtain a $ 10,000,000 non-recourse loan 

12 




through Wo rldwide Funding trading progra m. Among other things, he represented the $60,000 

was used to cover the costs to acquire the banking instrument and tha t the $60,000 deposit was 

held under an Escrow Agreem ent with Butts PA, which was full y insured and ref1mdable. He 

represented the escrowed funds are released after confim1ation of the acqui sition of the 

instrument from the issuing bank. He represented the process took 15 intem ational banking days 

until the investor received the fund s. While the documents he sent investors disclosed that as 
' 

the intermediary in the tran sactio n, he would receive 10% of proj ect net funding and 10% of net 

trading profit s for one year, he fai led to di sclose the material fact that he received approximately 

10% of the investor 's funds immediately from the escrow account. 

81. If an inves tor was interes ted in the Worldwide Funding trading program, Anisky arranged 

for a telephone conference call among Geivelis, Butts, Ani sky and the investor. 

82. Anisky offered the investment to at least ten inves tors who invested approximately 

$960,000. 

83. Butts paid Ani sky approximately 9% of the inves tor's funds received into the Butts PA 

bust account. In to tal, Butts pa id approximately $86,768 to PW Consulting for the benefit of 

Anisky. 

84 . A nisky obtained investo rs' funds by mean s of fal se and misleading statements or 

omissio ns ofmaterial fact made about the investment in the Worldwide Funding trading 

program. 

85. Banner and Express Conunercial are engaged in the business of inducing investors or 

attempting to induce inves tors to purchase securities, including the invesllnent contracts offered 

by Worldwide Funding. 

86. From at least January 20 13 tlu-ough August 20 13, Banner an d Express Commercial 

offered invesllnent con tracts in W orldwide Funding's trading program which he named the 

"F A27" program. 

87. Banner, as the managing m emb er of Express Commercial, sent emails, newsletters, 

posted information on the Express Commercial 's website at www.expcomcap.com and spoke 

with investors by telephone about an invesllnent in the Worldwide Funding's FA27 Proj ect 

Funding, Infras tructure Humanitarian & Environmental Program. 

88. B anner and Express Commercial made false and misleading statements of material fact in 

their em ails and newsle tters sent to investors since January 20 13, amo ng other tl1ings, that in the 

13 




F A27 program: 

" The provider group [World wide Funding and Geivelis] purchases the ten (1OM) SBLCs 

fro m top major banks for cash in the nam e of the cli ent. For one yea r the client controls 

thi s SBLC for the monetization & trade po1tion of thi s infrastruc ture Humanitarian & 

Enviro1m1ental Program (IHEP). The escrow agent for the FA27 IHEP program is a 

practicing attorney in Miami, Florida for over 40 years. The attorney is a partner and 

managing director of the trading organization & the FA27 IHEP funding entity. The 

trad er has 23+ years of experience & is licensed with 27 banks worldwide to do the lines 

of credit for the trade." The SBLC is monet ization at 80% providing net proceeds to the 

client of$6,660,000 Euros . The SB LC is " leveraged up 3 to 5 tim es which max imi zes 

the trading amount to a minimum of 30M to 50M trad e because the I OM SBLC is cash 

backed. The trad e is normally 40 weeks. T he trader's contract states a 50% I 50 % split 

with the client. The Trader Co ntract will sta te the historical returns . Each cash-backed 

1OM SBLC has a hard cost of 90K deposited into the Florida atto rney's insured Escrow 

Account. All other client's costs are charged to the monetization & trade funding returns . 

'rhe 90K is p aid after your proj ect is approved & contracts are offered to the client. " 

Banner outlined the procedures to get started included to sign and return to the sender an Express 

Commercial NCND; ca ll or email the sender to answer questions a bout the IH EP program; 

request a F A27 client infom1ation fom1 and executive summ ary and; set up a co nference call 

with the Escrow attom ey, Funder and the send er. Bam1er disclosed he received co-bro ker's fees 

of "2. 5% of client's 6 .6M euros" after the SBLC was mon etized and "2.5% of clients ne t 40 

week PPP trade paid to broker." But he did not disclose h e immediately received approximately 

10% of investor's fund s before the SBLC was acquired. 

89. Banner identified the provider of the FA27 program as Wo rldw ide Funding and Frank 

Anastasio; the attomey and escrow agent as Bem a rd H. Butts Jr. ; and tha t Butts is the pmtner of 

Anas tasio the managing director o f the trading organization. 

90. When an inves tor contacted Banner about the FA27 program , Banner arranged for a 

conference call an1ong the investor, Geivelis, Butts, and Banner. Banner and Express 

Conunercial offered the investment to at least ten investors who invested approx imately 

$9 19,955 . 

9 1. Butts immediately paid Banner approximately 10% the investor's fund s received into the 

Butts PA trust account. In total, Butts paid approx imately $9 1,25 0 to Express Comme rcia l for 

the benefit of Ba nner. 

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92. Banner obtained investors' fund s by means of false and mis leading statements or 

omiss ions of material fact made about the investment in the Worldwide Funding trad ing 

program. 

93. Baggs is engaged in the bus iness of inducing in vestors or attempting to induce inves tors 

to purchase securities, including th e investment contracts offered by Worldwide Funding. 

94. In or about January 2013, Baggs learned of the Worldwide Funding' s investment 

program from Barmer. Banner told Baggs tha t an inv estment cost $80,000 a nd was completely 

safe because the fund s were paid into Butt's attorney tTUst account in Miami, Florida. Banner 

told Baggs the initial payout was approximately $6,600,000 to the investor a nd thereafter weekly 

payments of between $2 million and $4 milli on wo uld accm e for approximately 40 weeks. 

Banner said tha t Anastasio (Geivelis) and Bu tts were paitners; Anastasio (Geivelis) started the 

program and made it work. 

95. Baggs had several telephone ca lls and emails w ith Butts, Geiveli s and Banner who each 

confirmed the details of the program. Geivelis, Butts and Barmer to ld Baggs that the initial 

monies from the customer wo uld be u sed to procure a € I0 millio n SBLC from a major world 

class bank. That that letter ofcredit would be leveraged up to €30 million to € 50 million and 

those funds would be used to go into a trading program. Investors' returns were to be generated 

from trading profits. A ll three assured Baggs that the investors' money was safe in the attorney's 

trust account and there would be no losses. 

96. Banner and Baggs agreed to split any comm iss ions from Baggs introducing investors to 

the program. 

97. In or about February 5, 20 13, Baggs began offering the Worldwide Funding investment 

program to investors tlu·ough emails and te lephone ca lls with investors repeating the 

mi srepresentations made to him by Geivelis, Butts and Banner. 

98. Baggs did not have any reasonab le basis on which to believe that the Worldw ide Funding 

trading program describ ed by Geivelis, Butts, and Banner existed. 

99. Baggs offered the Worldwide Funding investment to at leas t one investor who invested 

$80,000, which was w ired to Butts PA on or about February 19, 20 13. 

100 . Butts paid Baggs and Banner approximately 10% of the investor's funds received into the 

Butts PA trust account. Butts wired $4,970 to Baggs' entity Capital Express Corporation and 

$4,970 to Banner's entity Express Commerc ial. 

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10 I. Geivelis, Butts, An isky, Ba1mer, Express Conu11ercia l and Baggs told most inves tors that 

they wo uld receive the initial proceeds from the € I 0,000,000 Euro loan within fifteen to forty­

five wo rking days. 

102. After the Oiiginal investmen ts were made and continuing through at least August 9; 20 13, 

Worldwide Funding, Geivelis and Butts made fa lse s tatements to investors to lull them into 

remaining in the investmen t program because payment of the clain1ed extraordinary returns on 

their investments were inuninent, but that issues w ith the various financial institutions were 

causing delays. 

103. For example, on October 30, 20 12, Worldwide Funding and Geivelis sent a Jetter to "all 

participants in the project funding humanitarian p rogram" providing an update falsely 

representing "the new ex it buyer is con tracted . .. and they have provided the necessary bank 

confirm ations ... . At this tim e .. . the 2 parties are completi ng the final paperwork and are 

preparing the trade to the fina l banking stage prior to di sbursing to the first 3 waives of project 

owners. We will ha ve ano ther upda te tomorrow as to where the payouts stand . ... We 

understand time is of the essence and it is unfortuna te that after all this time our exit buyer 

backed out last minute.... [F]unding for waive 1, 2, and 3 then waive 4 and 5 will go into 

disbursement state. The a nticipated time frame wou ld be 7-10 days fro m the day waive 3 is 

funded." 

I 04. On November 15, 20 12, Worldwide Funding and Geivelis sent another letter to all 

participants fa lsely representing, "the first 4 wires were being cleared and . .. w ill be passed on 

to Bernard Butts P.A. We cannot advise how long this process is, however from experience of 

domestic transfers usually it is a very quick tum around." 

105. On December 19,20 12, Worldwide Funding and Geivelis sent another letter to all 

participants falsely rep resenting, they had forwarded information to the bank fo r review which 

was 60% complete. "The draw request for fun ds will be completed once all fil es are app roved. 

Once the bankers are complete we will sign the draw request and the Funds will be transferred 

accordingly to JP Morgan Chase WWF III account in which I will turn the funds around same 

day ...." 

I 06. Butts also sen t various text messages to investors promising that payments were 

imminent. 

107. For example, on March 25, 2013, Butts sen t a text message falsely stating, " Fincen has 

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released Wells and they have no restrictions on lransfening f·unds to Chase and Frank It 's not if 

but when .... Raj and his time estimate is as he outlined. As soon as the fund s are transferred he 

will communicate to alL" 

I 08. On Jul y 3, 20 13, Geiveli s emailed an investor false ly s tating the investor's funding was 

scheduled for release around July 12, 2013 

I 09. On July 9, 20 13, Geivelis emailed an inves tor fal sely stating, "I was not authorized to 

release your payment yet but I was told end of last week that we w ill process it in the next couple 

days and payment w ill be made to your ... account" 

110. On August I, 2013, Geivelis emailed an investor fal sely stating, "You will be funded no 

later than August 12, 2013." 

11 1. Geivelis and Butts continued to lull investors through August 2013. ­

VII. BROKER AND DEALER 

112. From at least April 20 12, Geivelis, Butts, Ani sky, Banner, Express Commercial and 

Baggs engaged in the business of inducing or attempting to induce the purchase or sale of the 

securities. 

11 3. Geivelis, Butts, Anisky, Banner, Express Commercial and Baggs each used interstate 

commerce, send ing emails and speaking by telephone w ith investors about the Worldwide 

Funding trading program. 

114. Geivelis and Butts were parh1ers in the offer and sale of the investment contracts of 

Worldw ide Funding. Each received transaction-based compensatio n of approximately 45% of 

the money that investors' invested with Worldwide Funding. 

11 5. Anisky; Banner and Express Commercial; and Baggs offered the investment contracts of 

Worldwide Funding. Each received transaction-based compensation of approxin1ately 10% of an 

investor's funds, with Banner and Baggs sharing the 10% for the investor that Baggs introduced. 

11 6. Geivelis, Butts, Anisky, Banner, Express Commercial and Baggs were not registered as 

brokers, or associated with a broker-dealer registered with the SEC while they induced or 

attempted to induce the purchase or sale of securities. 

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FIRST CLAI M FOR RELIEF 
Fraud- Violations of Securities Act Section 17(a) 

[15 U.S.C. § 77q(a)] 

11 7. The SEC realleges paragi·aphs 1 through 11 6 above. 

118. D efendants Worldwide F unding, Geivelis , Butts, Anisky, Express Commercial, Banner, 

and Baggs directly and indirectly, w ith scienter, in the offer or sale of securities, by u se of the 

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

mai ls, employed a device, scheme, or artifice to defraud; obtained money or property by m eans 

ofuntrue statements of material fact or omissions to state material facts necessary in order to 

make the statem ents made, in light of th e circumstances under w hich they were made, not 

misleading; or engaged in transactio ns, practices, or courses of business which have been or are 

operating as a fraud or deceit upo n the purchasers of the securities. 

11 9. re 

120. D efendants Worldwide Funding, Geivelis, B utts Anisky, Express Commerc ial, Banner, 

and Baggs violated and unless restrained and enjoined will in the future violate Securities Act 

Section 17(a)(1), (2) and (3). 

12 1. Altem atively, Butts know ingly aided and abetted the violations by Worldwide Funding 

and Geivelis of Securities Act Section 17(a)( I), (2) and (3). He provided substantial assistance 

in their commission of the primary violation by acting as the escrow agent to receive investors' 

funds, distributing funds to the defendants and relief defendants although no SBLCs were 

acquired, and be and the other defendants were no t to be compensated until after the trading 

program was complete. He also lulled investors into not tem1inating their investments, reassuring 

them that their returns were imm inent. 

SECOND CLAIM FOR RELIEF 

FRAUD- VIOLATIONS OF EXCHANGE ACT SECTION lO(b) AND RULE lOb-S 


[15 U.S.C. § 78j(b) and 17 C.F.R. § 240.10b-S] 


122. The SEC realleges paragraphs 1 through 11 6 above. 

123. Defendants Worldwide Funding, Geivelis, Butts, Ani sky, Express Commercial, Banner, 

and Baggs, directly or indirectly, with scienter, in connection with the purchase or sale of 

securities, by the use of means or. instrumentalities of interstate commerce, the mails, or any 

faci lity of a national securities exchange, employed devices, schemes, or artifices to defraud; 

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made un true statements of material fac t or omitted to sta te mate1ial facts necessary in order to 

make the statements m ade, in light of the circum stances under which they were made, not 

misleadi ng; o r engaged in acts, practices, or courses of business which operated or would operate 

as a fraud or deceit upon any person; in violation ofExchange Act Section IO(b) and Ru le I Ob-5. 

124. Defendants Worldw ide Funding, Geivelis, Butts Anisky, Express Commercial, Banner, 

ru1d Baggs violated and unless restrained and enjoined will in the futme v iolate Exchange Act 

Section IO(b) and Rule IOb-5. 

125. Alternative ly, Butts knowing ly aided and abetted the violations 'by Worldwide Funding 

and Geivelis ofExchange Act Section lO(b) and Ru le l Ob-5. H e provided substantial assistance 

in their commi ssion of the primary violation by acting as the escrow agent to receive investors' 

funds , distributi ng funds to the defend ants and relief defendants although no SBLCs were 

acquired, and he and th e o ther defendants were not to be compensated until after the trading 

program was complete. He also lull ed investo rs into not tem1inating their investments, reassuring 

them that their returns were imminent. 

TIDRD CLAIM FOR RELIEF 

OFFERS AND SALES OF UNREGISTERED SECUIUTIES ­

VIOLATIONS OF SECURITIES ACT SECTIONS S(a) AND S(c) 

115 U.S.C. §§ 77e(a) and 77e(c)] 


126. The SEC realleges paragraphs 1 through 11 6 above. 

127. Defendants Worldwide Funding, Geivelis, Butts Anisky, Express Commercial, Banner, 

and Baggs, directly or indirectl y, have made use of the m eans or instruments of transportation or 

communication in interstate commerce or of the mails to sell securities, when no registration 

statem ent was in effect w ith the Commission as to such securi ties, and have m ade use of the 

means or instrum ents of transportation or communication in interstate commerce or of the mails 

to offer to sell such securiti es when no registration statement had been filed with the 

Commission as to such securiti es. 

128. There were no appli cable exemptions from registration, and Defendants Worldwide 

Funding, Geivelis, Butts Anisky, Express Commercial, Banner, and Baggs therefore violated, 

and unless restrained and enjoined wi ll in the future violate Sections 5(a) and 5(c) of the 

Securities Act. 

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FOURTH CLAIM FOR RELIEF 

OFFERS AND SALES OF SECURlTIES BY AN UNREGISTERED BROKER-DEALER 

VIOLATIONS OF EXCHANGE ACT SECTION lS(a) 
115 U.S.C. § 78o(a)] 

129. The SEC realleges paragraphs 1 through 11 6 above. 

130. Defendants Geivelis, Butts Anisky, Express Commercial, Banner, and Baggs, while 

engaged in the business of effecting transactions in securities for the account of o thers, m ade use 

of the mail s or the means or instrumentalities of interstate commerce to effect transactions in, or 

to induce or attempt to induce the purchase or sale of, a security without being registered in 

accordance with Section 15(a) of the Exchange Act. 

131. Defendants Gei velis, Butts Anisky, Express Commercial, Banner, and Baggs, have 

violated, and w1less restrained and enjoined will in the future violate Section 15(a) of the 

Exchange Act. 

FIFTH CLAIM FOR RELIEF 

UNJUST ENRICHMENT OF RELillF DEFENDANTS 


132. The SEC realleges paragraphs 1 through 11 6 above. 

133. Relief defendants B ernard H. Butts Jr. PA, Butts Holding Corporation, Globa l 

Worldwide Fw1ding Ventures, Inc. , Margaret A. Hering, and PW Consulting Group LLC, each 

obtained funds as part, and in furtherance of the securities violations alleged above without a 

legitimate claim to those funds, and und er those ci1·cum stan ces it is not j ust, equitabl e or 

conscionable for them to retain the funds. Bernard H. Butts Jr. P A, Butts Holding Corporation, 

Global Worldwide Funding Ventures, Inc., Margaret A. Hering, and PW Consulting Group Inc. 

were unjustly enriched. 

134. Bernard H. Butts Jr. PA, Butts H olding Corporation, Gl obal Worldwide Funding 

Ventures, Inc., Margaret A. Hering, and PW Consulting Group Inc. should each be ordered to 

di sgo rge the funds they received as a result of the defendants ' violations of the federal securities 

laws. 

PRAYER FOR RELIEF 


The SEC respectfull y requests that this Court: 


I. 

Enter an Order finding that D efendants Worldwide Funding, Geiveli s, Butts, A nisky, 

20Express Commercial , Banner, a nd B aggs committed the v io lations alleged in this complaint, and 

unless restrained will continue to do so. 

II. 

Enter an injunction, pursuant to Rule 65(d) of the Federal Rules of Civil Procedure, 

pem1anently restraining and enj oining Defendants W orldwide Funding, Geivelis, Butts, A nisky, 

Express Commercial, Ba nner, and Baggs from furth e r v io lati ons o f the law and ml es alleged in 

this complaint. 

III. 

Enter an Order requmng D efendants Worldwide Funding, Geivelis, Butts, Anisk y, 

Express Commercial, Banner, and Baggs to prepare accountings of all funds received from 

investors identifying the nam e of each investor, the dollar amount received, elate o f receipt, and 

how those funds were spent. 

I V. 

Enter an Order requmng Defenda nts World wide Funding, Geivelis, Butts, Anisky, 

Express Commercial, Banner, a nd Baggs to d isgorge all ill-gotten ga ins in the form of any 

benefits of any kind derived from the illegal conduc t a lleged in this complaint, together w ith 

prejudgment and post judgm ent interes t and to re patriate to the registry of the Court a ny investor 

funds being held in foreign jurisdictions. 

V. 

Enter an Order requiring D efendants Worldwide Funding, Geivelis, Butts , Anisky, 

Express Commercial , Banner, and Baggs to pay third tier civil money penalties pursuant to 

Securities A ct Section 20(d) [15 U.S.C. § 77t(d)) and Exchange Act Section 2 1(d) [15 U.S.C. § 

78u(d)) . 

VI. 

Enter an Order requiring Bernard H . Butts, Jr. PA; Butts Holding Corporation; Global 

Worldwide Funding Ventures, Inc. ; Margaret A. Hering; and PW Consulting Group LLC to 

disgorge funds that they received that were the proceeds of illegal activities of othe r defendants. 

2 1 




VII. 

Order such other rei ief as thi s Court deems necessary and appropriate. 

DATED: August 29, 2013 

Respectfu lly submitted, 

s/Leslie J. Hughes 
Lesli e J. Hughes, (Special Bar No. A5500503) 
Securities and Exchange Commission 
180 1 Ca lifornia Street, Suite 1500 
Denver, Colorado 80202 
Main number 303-844-1000 
Direct number 303-844-1086 
Fax number 303-844-1 068 
Email: HughesLJ@ sec.gov 

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