SEC v. Mina Tadrus; and Tadrus Capital LLC, No. 1:23-cv-05708, Eastern District of New York (Dec. 17, 2025) — Judgment

[OCR_UNRECOVERABLE method=recover reason=missing_pdf ts=2026-08-11T14:53:34.535Z]                                                           

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UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff,

v.           No. 23 Civ. 5708 (FB) 

MINA TADRUS and 
TADRUS CAPITAL LLC, 

Defendants.

 FINAL JUDGMENT AS TO DEFENDANT MINA TADRUS

The Securities and Exchange Commission having filed a Complaint and Defendant Mina 

Tadrus having entered a general appearance; consented to the Court’s jurisdiction over him and 

the subject matter of this action; consented to entry of this Final Judgment; waived findings of 

fact and conclusions of law; and waived any right to appeal from this Final Judgment: 

I. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is 

permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the 

Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 

promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of 

interstate commerce, or of the mails, or of any facility of any national securities exchange, in 

connection with the purchase or sale of any security: 

(a) to employ any device, scheme, or artifice to defraud;

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(b) to make any untrue statement of a material fact or to omit to state a material fact 

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

 under which they were made, not misleading; or 

(c) to engage in any act, practice, or course of business which operates or would 

 operate as a fraud or deceit upon any person. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

II. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating Section 17(a) of the Securities Act of 1933 

(the “Securities Act”) [15 U.S.C. § 77q(a)] in the offer or sale of any security by the use of any 

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

mails, directly or indirectly: 

(a) to employ any device, scheme, or artifice to defraud; 

(b) to obtain money or property by means of any untrue statement of a material fact 

 or any omission of a material fact necessary in order to make the statements 

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

 or 

 (c) to engage in any transaction, practice, or course of business which operates or  

  would operate as a fraud or deceit upon the purchaser. 

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 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

III. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating Sections 206(1) and (2) of the Investment 

Advisers Act of 1940 (the “Advisers Act”) [15 U.S.C. §§ 80b-6(1) and 6(2)] by, while acting as 

an investment adviser, using any means or instrumentalities of interstate commerce, or any 

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

or any facility of any national securities exchange: 

(a) to employ any device, scheme, or artifice to defraud any client or prospective 

client; 

(b) to engage in any transaction, practice, or course of business which operates as a 

fraud or deceit upon any client or  prospective client; or 

(c) to engage in any acts, practices, or courses of business which are fraudulent, 

deceptive, or manipulative. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

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IV. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is permanently restrained and enjoined from violating Section 206(4) of the Advisers Act [15 

U.S.C. § 80b-6(4)] and Rule 206(4)-8 promulgated thereunder [17 C.F.R. § 275.206(4)-8] by, 

while acting as an investment adviser, using any means or instrumentalities of interstate 

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

commerce, or by the mails or any facility of any national securities exchange: 

(a). to make any untrue statement of a material fact or to omit to state a material fact 

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

which they were made, not misleading, to any investor or prospective investor in 

a pooled investment vehicle; and  

(b). to engage in any act, practice, or course of business which is fraudulent, deceptive 

or manipulative, with respect to any investor or prospective investor in a pooled 

investment vehicle. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in 

Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who 

receive actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s 

officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or 

participation with Defendant or with anyone described in (a). 

V. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to Section 

21(d)(5) of the Exchange Act [15 U.S.C. § 78u(d)(5)], Defendant is permanently restrained and 

enjoined from directly or indirectly, including, but not limited to, through any entity owned or 

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controlled by Defendant, participating in the issuance, purchase, offer, or sale of any security, 

provided however, that such injunction shall not prevent Defendant from purchasing or selling 

securities for his own personal account. 

VI. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that pursuant to Section 

21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)], Defendant is prohibited from acting as an 

officer or director of any issuer that has a class of securities registered pursuant to Section 12 of 

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

the Exchange Act [15 U.S.C. § 78o(d)]. 

VII. 

 IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant 

is liable for disgorgement of $4,070,350, representing his ill-gotten gains as a result of the 

conduct alleged in the Complaint, and prejudgment interest thereon of $72,100, for a total of 

$4,142,450 which shall be deemed satisfied by the order of restitution entered against him in 

United States v. Tadrus, 23 Cr. 393 (E.D.N.Y) (Dkt. No. 65), as well as the transfer of frozen 

assets ordered to take place in ParagraphsVIII, IX, X, and XI below to be used toward the 

restitution obligation in the criminal action. 

VIII. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, pursuant to the 

directions set forth in Paragraph XI below, within 3 days after being served with a copy of this 

Final Judgment, Brex Inc. (“Brex”) shall transfer to the Clerk of Court the entire balance of the 

Brex accounts held in the name of Tadrus Capital LLC (ending in -3190 and -0148), over which 

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Defendant had signatory authority, and which were frozen pursuant to the August 22, 2023 Order 

of this Court (Dkt. No. 11; the “Freeze Order”). 

IX. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, pursuant to the 

directions in Paragraph XI below, within 3 days after being served with a copy of this Final 

Judgment, First Internet Bank of Indiana (“FIBI”) shall transfer to the Clerk of Court the entire 

balance of the FIBI account held in the name of Tadrus Capital LLC (ending in -0826), over 

which Defendant had signatory authority, and which was frozen pursuant to the Freeze Order. 

X. 

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that, pursuant to the 

directions in Paragraph XI below, within 3 days after being served with a copy of this Final 

Judgment, Court Registry Investment System (“CRIS”) shall transfer to the Clerk of Court the 

entire balance of the CRIS account held in the name of Mina Tadrus which was frozen pursuant 

to the Freeze Order. 

XI. 

 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Brex, FIBI, and CRIS 

shall each transmit payment to the Clerk of the Court, United States District Court, Eastern 

District of New York, 225 Cadman Plaza East, Brooklyn, NY 11021 to be applied to Tadrus’s 

obligations under and pursuant to the Judgment and Order of Restitution entered in the parallel 

criminal case, United States v. Tadrus, 23 Cr. 393 (E.D.N.Y.) (Dkt. No. 65). The Commission 

will provide detailed ACH transfer/Fedwire instructions upon request. Payment shall be 

accompanied by a letter identifying (1) this case title, civil action number, and name of this Court 

and specifying that payment is made pursuant to this Final Judgment; and (2) that the payment is 

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to be applied to Tadrus’s obligations pursuant to the Judgment and Order of Restitution entered 

in the parallel criminal case, United States v. Tadrus, 23 Cr. 393 (E.D.N.Y.). A copy of the letter 

will be sent to Commission counsel in this action. Defendant relinquishes all legal and equitable 

right, title, and interest in such funds and no part of the funds shall be returned to Defendant. 

XII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, for purposes of 

exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. § 523, the 

allegations in the Complaint are true and admitted by Defendant, and further, any debt for 

disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under this 

Final Judgment or any other judgment, order, consent order, decree or settlement agreement 

entered in connection with this proceeding, is a debt for the violation by Defendant of the federal 

securities laws or any regulation or order issued under such laws, as set forth in Section 

523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). 

XIII. 

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is 

incorporated herein with the same force and effect as if fully set forth herein, and that Defendant 

shall comply with all of the undertakings and agreements set forth therein. 

 

 

 

 

 

 

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XIV. 

 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain 

jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment. 

 

 

 
Dated:  ______________, _____ 

____________________________________ 
UNITED STATES DISTRICT JUDGE 
/S/ Frederic Block

December 12 2025

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