SEC v. SHAHIN AHMED, No. 1:25-cv-06730, Eastern District of New York (Dec. 5, 2025) — Complaint

[OCR_UNRECOVERABLE method=recover reason=missing_pdf ts=2026-08-11T14:53:34.799Z]                                                           

Thomas P. Smith, Jr. 
Adam S. Grace 
Brenda Chang 
Ben Kuruvilla  
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street, Suite 20-100 
New York, NY 10004-2616 
(212) 336-5599 (Kuruvilla) 
[email protected]  
 
UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF NEW YORK 
 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
                                             Plaintiff, 
 
                        -against- 
 
SHAHIN AHMED,   
  
                                             Defendant.  
 
 

 
 
COMPLAINT 

   
25 Civ. 6730 

 
   

JURY TRIAL DEMANDED 
  

           
          

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

against Defendant Shahin Ahmed (“Ahmed”), alleges as follows: 

SUMMARY 

1. Between at least March 2020 and February 2022 (the “Relevant Period”), 

Defendant Ahmed defrauded investors by posing as a professional money manager. In fact, 

Ahmed was employed as a driver at Investment Adviser A, a registered investment adviser that 

managed a hedge fund. Ahmed had no investment experience at Investment Adviser A or any 

other financial firm, lacked formal education beyond high school, and possessed no license that 

would qualify him to work as a securities professional.   

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2. Yet, by lying to investors about his background and employment, Ahmed 

fraudulently induced at least one individual to deposit money into Honest Partners LLC (“Honest 

Partners”), an entity that Ahmed organized with a name deceptively similar to Investment 

Adviser A’s name, and he fraudulently induced both that individual and two others (a husband 

and wife) to grant him control over their online brokerage accounts.   

3. Ahmed also falsely promised at least one of these victims that he would fully 

guarantee that victim’s principal investment against any trading losses and further falsely 

promised other victims that he would repay at least some of their trading losses.  Ahmed further 

perpetuated his fraud by providing his three victims with fake written statements regarding the 

value of their invested assets; lying to one of the victims about an alleged opportunity to 

purchase investments at a steep discount; and lying to a broker to conceal that Ahmed was 

trading assets on behalf of others in the Honest Partners investment account.   

4. Ahmed’s trading in the Honest Partners account, and in his victims’ own 

brokerage accounts, resulted in hundreds of thousands of dollars in trading losses for each of his 

victims. In total, Ahmed’s victims sustained over $1 million in combined losses due to Ahmed’s 

fraud. 

VIOLATIONS 

5. By virtue of the foregoing conduct and as alleged further herein, Ahmed has 

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

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

Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and 206(2) of the 

Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. §§ 80b-6(1) and (2)]. 

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

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

and courses of business of similar type and object.   

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

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

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

21(d) [15 U.S.C. § 78u(d)], and Advisers Act Sections 209(d) and 209(e) [15 U.S.C. §§ 80b-9(d) 

and 80b-9(e)].  

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

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

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

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

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

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

Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], and Advisers Act Section 209(e) [15 U.S.C. § 80b-

9(e)]; (d) permanently enjoining Ahmed from, directly or indirectly, including, but not limited to, 

through any entity owned or controlled by him, participating in the issuance, purchase, offer, or 

sale of any security, provided, however, that such injunction shall not prevent him from 

purchasing or selling securities for his own personal accounts, pursuant to Securities Act Section 

20(b) [15 U.S.C. § 77t(b)] Exchange Act Sections 21(d)(1) and 21(d)(5) [15 U.S.C. §§ 78u(d)(1) 

and 78u(d)(5)], and Advisers Act Section 209(d) [15 U.S.C. § 80b-9(d)]; (e) permanently 

enjoining Ahmed from, directly or indirectly, acting as or being associated with any investment 

adviser, pursuant to Securities Act Section 20(b) [15 U.S.C. § 77t(b)], Exchange Act Sections 

21(d)(1) and 21(d)(5) [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)], and Advisers Act Section 209(d) 

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[15 U.S.C. § 80b-9(d)]; for purposes of this paragraph, a person is “associated with an 

investment adviser” if such person is a partner, officer, or director of such investment adviser (or 

performs similar functions), or directly or indirectly controls or is controlled by such investment 

adviser, including any employee of such investment adviser; and (f) ordering any other and 

further relief the Court may deem just and proper. 

JURISDICTION AND VENUE 

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

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

Section 214 [15 U.S.C. § 80b-14].  

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

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

courses of business alleged herein. 

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

Exchange Act Section 27 [15 U.S.C. §78aa], and Advisers Act Section 214 [15 U.S.C. § 80b-14]. 

Certain of the acts, practices, transactions, and courses of business constituting the violations of 

the federal securities law alleged in this Complaint occurred within this District including that 

during the Relevant Period Ahmed resided in this District, and at least one victim resided in this 

District. 

DEFENDANT 

12. Shahin Ahmed, age 53, is currently a resident of Orchard Park, New York.  At 

all relevant times, Ahmed was employed as a driver at Investment Adviser A, with the title 

“administrative assistant,” until his employment was terminated in or around March 17, 2022. 

Ahmed has never held any securities licenses, has never been an associated person with a 

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registered adviser or broker-dealer, and has never registered with any state as an investment 

adviser.   

OTHER RELEVANT INDIVIDUALS AND ENTITIES 

13. Honest Partners is a New York limited liability company, which Ahmed formed 

in 2018, with its principal place of business in Valley Stream, New York.  Other than its 2018 

Articles of Organization, Honest Partners has made no corporate filings with the State of New 

York.  While it lists its corporate status as “Active,” Honest Partners has no current business 

operations or assets and is defunct. 

14. Investment Adviser A is a Delaware limited liability company whose principal 

place of business is in New York, NY.  Investment Adviser A is registered with the 

Commission as an investment adviser.   

FACTS 

I. AHMED’S SCHEME AGAINST INVESTOR 1 

15. During the Relevant Period, Investment Adviser A employed Ahmed as a driver 

for Investment Adviser A’s founder and portfolio manager.  

16. Although Investment Adviser A managed a hedge fund, Ahmed was not involved 

in the management or operations of the hedge fund; rather, his principal duties were as a driver. 

A. Ahmed Fraudulently Induced Investor 1 to Invest in Honest Partners 
 

17. In or about 2012, Ahmed met Investor 1 through a mutual friend.  At that time, 

Ahmed falsely introduced himself to Investor 1 as a senior investment professional managing 

investments at Investment Adviser A.   

18. In subsequent years, Ahmed continued to falsely represent to Investor 1 that 

Ahmed was an investment professional. 

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19. In or around April 2020, at Ahmed’s request, Ahmed and Investor 1 met in the 

lobby of Investment Adviser A’s offices (the “Lobby Meeting”), which were closed at the time 

due to the global COVID-19 pandemic, giving Investor 1 the false impression that Ahmed 

worked as a securities professional at Investment Adviser A. 

20. During the Lobby Meeting, Ahmed provided Investor 1 with Investment Adviser 

A’s marketing materials and touted Investment Adviser A’s portfolio of securities holdings, 

emphasizing Investment Adviser A’s activist role and board memberships with the companies 

that Investment Adviser A was invested in.  

21. During the Lobby Meeting, Ahmed also falsely claimed that, as a securities 

professional with Investment Advisor A, he had conducted due diligence regarding the 

companies in Investment Adviser A’s securities portfolio. 

22. Also at the Lobby Meeting, Ahmed falsely led Investor 1 to believe that he would 

leverage his alleged experience and knowledge trading Investment Adviser A’s portfolio of 

assets to invest on Investor 1’s behalf. 

23. In or around May 2020, Ahmed asked Investor 1 to invest with Ahmed through 

Investment Adviser A, and, based on Ahmed’s misrepresentations, Investor 1 gave Ahmed 

$50,000 to invest for Investor 1.  

24. Specifically, in or around May 2020, Ahmed directed Investor 1 to write a check 

for $50,000 in the name of “Honest Partners LLC,” an entity that Ahmed had organized 

purportedly to invest assets, with a name deceptively similar to Investment Adviser A’s name. 

25. Based on Ahmed’s misrepresentations, Investor 1 believed that Investment 

Advisor A would manage the investments that Ahmed claimed he would make for Investor 1. 

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26. Months later, Ahmed represented to Investor 1 that Ahmed could purchase stock 

options in one of Investment Adviser A’s major holdings, at a steep discount to its market price.    

27. As a result of Ahmed’s representation, on or around July 27, 2020, Investor 1 

gave Ahmed an additional $41,000 to invest in the purportedly discounted stock options.   

28. Ahmed, however, did not invest Investor 1’s $41,000 in the stock options that he 

represented to Investor 1. 

29. Instead, Ahmed transferred the entire $91,000 that Investor 1 had given him to a 

brokerage account that Ahmed opened in the name of Honest Partners so that Ahmed could 

conduct other trading activity on behalf of Investor 1.  On the account application Ahmed 

submitted to the brokerage firm to open the Honest Partners brokerage account, Ahmed falsely 

represented his occupation as “softwaer developer” [sic] and Honest Partners’ line of business as 

“software developement” [sic].  Ahmed did not indicate that he was using Honest Partners to 

invest money on behalf of other investors. 

30. For his purported services managing Investor 1’s funds in Honest Partners, 

Ahmed requested management fees and a share of Investor 1’s trading profits. 

31. Specifically, Ahmed presented Investor 1 with a written agreement, dated June 

30, 2020, between Honest Partners, Ahmed, and Investor 1 stating that Investor 1’s “investment 

money ($91,000.00)” would be invested for three years, and, in return, Ahmed would receive 

“2%, as management fees” and “20% as remuneration (net profits after tax)”; and that Ahmed 

would “repay a total amount of $91,000.00” in three years.  The agreement further stated that 

Investor 1 had the “right to request the re-payment of the full amount of investment money 

($91,000.00)” for any reason before the three-year period had run if he provided Ahmed advance 

notice. 

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32. Investor 1 did not ultimately sign the June 30, 2020 agreement because he did not 

want to commit to a three-year period for his investment, but he agreed orally to compensate 

Ahmed for his purported services managing and trading his funds. 

B. Ahmed Makes Misrepresentations Regarding Investor 1’s Investments 
 

33. During the Relevant Period, Ahmed falsely reassured Investor 1 that his purported 

investment was doing well and earning high returns.   

34. For example, in or around January 2021, Ahmed provided Investor 1 with an 

investor relations letter from Investment Adviser A extolling Investment Adviser A’s stellar 

2020 performance, including that Investor Adviser A had “completed its sixteenth year with a 

net return of  +[5.2%]”; had seen “progress in our portfolio”; and that, historically, the funds 

managed by Investment Adviser A had “generated a total net return of +[1,337.2%].” 

35. When Investor 1 asked Ahmed how his specific investment was doing, Ahmed 

misleadingly told Investor 1 not to worry because all of Investment Adviser A’s hedge fund 

holdings were doing very well.   

36. Ahmed never told Investor 1 that Honest Partners was a different company than 

Investment Adviser A.  Instead, based on Ahmed’s deceptive conduct and representations, 

Investor 1 believed that Honest Partners and Investment Adviser A were one and the same.  

37. Ahmed continued to further mislead Investor 1 regarding the purported success of 

Honest Partners’ management of Investor 1’s funds.   

38. For example, in or around November 2021, Ahmed sent Investor 1 a purported 

Honest Partners written statement showing that Investor 1’s account was worth $117,046.50 as 

of November 30, 2021 (the “November 2021 Statement”).  The November 2021 Statement also 

listed the number of shares that Ahmed purportedly had invested on Investor 1’s behalf in two of 

the major securities holdings of Investment Adviser A. 

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39. The November 2021 Statement also stated that Investor 1’s account had incurred 

a “Day Gain” of “+1,224.00 (+1.06%)” and a “Total Gain” of “+40,921.50 (+53.76%).”  These 

statements were false.  Ahmed’s trading for Investor 1 in the Honest Partners account did not 

generate any such gains.  In fact, as of November 30, 2021, the Honest Partners account had no 

money remaining in it. 

40. Nevertheless, in a letter titled, “Honest partners llc Promissory notes,” which 

accompanied the November 2021 Statement, Ahmed misleadingly stated that Investor 1 would 

be entitled to a “redemption amount of $117.046.50” (sic) that “will be due feb-15-2022.”   

C. Ahmed Gains On-Line Access to Investor 1’s Brokerage Account and Incurs 
Significant Losses Conducting Trading Activity in the Account 

 
41. Because Investor 1 believed that Ahmed was investing his funds through 

Investment Adviser A and was encouraged by Ahmed’s false reports of high returns on Investor 

1’s initial investments, Investor 1 was receptive when Ahmed pitched additional services.   

42. In or around May 2021, Ahmed asked Investor 1 to open and fund an on-line 

brokerage account for Ahmed to trade on Investor 1’s behalf.  

43. To induce Investor 1 to provide Ahmed access to Investor 1’s on-line brokerage 

account, Ahmed claimed to Investor 1 that he similarly traded the brokerage accounts of his 

other clients and would do the same for Investor 1 in return for 30% of the trading profits.   

44. Ahmed misleadingly told Investor 1 that he needed to use a brokerage account in 

Investor 1’s name to trade on Investor 1’s behalf because, due to Ahmed’s employment with 

Investment Adviser A’s hedge fund, Ahmed could not open a brokerage account in his own 

name. 

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45. Ahmed guaranteed Investor 1 that Investor 1 would not lose money through 

Ahmed’s trading in Investor 1’s brokerage account. Ahmed promised Investor 1 that, in the event 

of any loss, he would replenish 100% of Investor 1’s principal. 

46. On or about May 18, 2021, based on Ahmed’s representations, Investor 1 funded 

his brokerage account with $300,000 for Ahmed to trade, provided Ahmed with the log-in 

credentials to Investor 1’s brokerage account, and added Ahmed’s phone number as the primary 

phone number on Investor 1’s account so that Ahmed could conduct trading activity in the 

brokerage account. 

47. Ahmed received no authorization from Investor 1’s on-line brokerage firm to 

trade in Investor 1’s account; indeed, that firm’s policies prohibited investment advisory 

activities in Investor 1’s self-directed account.   

48. Shortly after Investor 1 funded his brokerage account with $300,000, Ahmed 

proceeded to trade securities in Investor 1’s account.   

49. Ahmed’s first few weeks of trading in in Investor 1’s brokerage account generated 

profits, and Investor 1 paid $15,000 to Ahmed as a “Financial Consultation Fee.” 

50. However, Ahmed’s positive early results in Investor 1’s brokerage account later 

reversed direction, and Investor 1 started suffering significant losses due to Ahmed’s speculative 

trading in that account.   

51. During the summer of 2021, Ahmed reassured Investor 1 regarding losses in his 

account by falsely claiming to have experience as an investment professional capable of 

managing dips in the market. In addition, Ahmed again promised Investor 1 that he would repay 

any loss of Investor 1’s principal investment.   

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52. In the fall of 2021, after continuing to see significant losses in his on-line 

brokerage account due to Ahmed’s risky trading, Investor 1 repeatedly asked Ahmed to return all 

his investment money. Thereafter, Ahmed gave Investor 1 three separate post-dated checks (the 

“Post-dated Checks”).  On or about October 16, 2021, Ahmed gave Investor 1 a check dated 

January 1, 2022 (in the amount of $245,000) and a check dated February 3, 2022 (in the amount 

of $100,000).  On or about December 9, 2021, Investor 1 received a third check from Ahmed 

post-dated February 15, 2022 (in the amount of $117,046.50).   

53. Ahmed asked Investor 1 not to cash the Post-dated Checks until the dates written 

on the checks.  

54. In February 2022, when Investor 1 attempted to deposit the Post-dated Checks in 

his bank account, all three checks failed to clear due to insufficient funds. 

55. Ultimately, the losses incurred in Investor 1’s brokerage account were so 

significant that he complained to the brokerage firm, and the brokerage firm removed Ahmed’s 

phone number from, and access to, Investor 1’s brokerage account.  By that time, Investor 1’s 

brokerage account had incurred over $180,000 in trading losses.   

56. Investor 1 never recouped the $91,000 that he gave to Ahmed. As for his 

brokerage account, Investor 1 was able to recoup only approximately $115,355 of the $300,000 

he had deposited, suffering losses of over $180,000.  

II.  AHMED’S SCHEME AGAINST INVESTORS 2 AND 3 

57. Investor 2 and Investor 3 are a married couple who had met Ahmed through the 

same mutual friend who had introduced Ahmed to Investor 1.  

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58. Just as he had with Investor 1, Ahmed falsely told Investor 2 and Investor 3 that 

he was a professional securities trader with years of experience managing a stock fund and that 

he could deliver substantial profits to his clients. 

59. Specifically, Ahmed told Investor 2 and Investor 3 that he was currently 

employed at Investment Adviser A, “a well-known hedge fund management company.”  

60. Ahmed also promised Investor 2 and Investor 3 guaranteed, risk-free investment; 

he promised to return to them the amount of any losses that may be incurred by his trading on 

their behalf.   

A. Ahmed Gains On-Line Access to the Brokerage Accounts of Investors 2 and 3 
and Incurs Significant Losses in Those Accounts. 

 
61. In or about March 2020 and September 2021, in reliance on Ahmed’s promises of 

substantial profits and risk-free investing, Investor 2 and Investor 3 gave Ahmed their login 

credentials to access two of their on-line brokerage accounts.   

62. Investor 2 and Investor 3 agreed to pay Ahmed 30% of any net profits he 

generated from trading in their accounts and for his investment advice.   

63. Ahmed engaged in risky trading in Investor 2 and 3’s brokerage accounts, 

resulting in substantial losses, including by trading on margin.1  

64. For example, Ahmed’s bet on one position in a single stock – amplified by his 

trading on margin – incurred losses beyond the value of all the assets in one of the brokerage 

accounts to which Investor 2 and Investor 3 had provided Ahmed access (the “Loss Account”). 

 
1 Trading or buying on margin involves the trader borrowing money from a brokerage firm to purchase securities, 
thereby increasing purchasing power and potentially amplifying returns, but also potentially magnifying losses. 

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65. The broker for the Loss Account subsequently liquidated all securities positions in 

that account, after which Investor 2 and Investor 3 were left with over $60,000 in margin call 

costs, which Ahmed had incurred and which Investor 2 and Investor 3 owed the broker.   

66. Due to Ahmed’s trading, Investor 2 and 3’s brokerage accounts lost a total of over 

$637,000.   

67. Ahmed failed to return any money to Investor 2 and Investor 3. 

68.  During the time period that Ahmed traded in their brokerage accounts – in 

response to his repeated requests for compensation – Investor 2 and Investor 3 paid Ahmed a 

total of $50,000. 

III.  INVESTMENT ADVISER A TERMINATES AHMED 

69. In or around March 2022, upon learning of Ahmed’s undisclosed brokerage 

accounts and trading activity, Investment Adviser A terminated Ahmed’s employment. 

IV. TOLLING AGREEMENTS 

70. On March 11, 2025, Ahmed executed a tolling agreement with the Commission, 

which tolled the statute of limitations from March 7, 2025 through June 5, 2025. On May 29, 

2025, Ahmed executed a second amended tolling agreement with the Commission, which tolled 

the statute of limitations from June 6, 2025 through September 8, 2025.  On September 17, 2025, 

Ahmed executed a third amended tolling agreement with the Commission that tolled the statute 

of limitations from September 9, 2025 through December 10, 2025.  Each of the three tolling 

agreements specified a period of time in which “the running of any statute of limitations 

applicable to any action or proceeding against Shahin Ahmed authorized, instituted, or brought 

by or on behalf of the Commission or to which the Commission is a party arising out of the 

[Commission’s investigation of Ahmed’s conduct], including any sanctions or relief that may be 

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imposed therein, is tolled and suspended.”  The tolling agreements further provide that Ahmed 

and any of his agents or attorneys “shall not include the tolling period in the calculation of the 

running of any statute of limitations or for any other time-related defense applicable to any 

proceeding, including any sanctions or relief that may be imposed therein, in asserting or relying 

upon any such time-related defense.” 

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

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

paragraphs 1 through 70.  

72. Defendant Ahmed, directly or indirectly, singly or in concert, in the offer or sale 

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

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

schemes or artifices to defraud, (2) knowingly, recklessly, or negligently has obtained money or 

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

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

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

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

fraud or deceit upon the purchaser. 

73. By reason of the foregoing, Defendant Ahmed, directly or indirectly, has violated 

and, unless enjoined, will again violate Securities Act Section 17(a) [15 U.S.C. § 77q(a)]. 

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

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

paragraphs 1 through 70. 

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75. Defendant Ahmed directly or indirectly, singly or in concert, in connection with 

the purchase or sale of securities and by the use of means or instrumentalities of interstate 

commerce, or the mails, or the facilities of a national securities exchange, knowingly or 

recklessly has (i) employed one or more devices, schemes, or artifices to defraud, (ii) made one 

or more untrue statements of a material fact or omitted to state one or more material facts 

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

were made, not misleading, and/or (iii) engaged in one or more acts, practices, or courses of 

business which operated or would operate as a fraud or deceit upon other persons. 

76. By reason of the foregoing, Defendant Ahmed, directly or indirectly, singly or in 

concert, have violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 

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

THIRD CLAIM FOR RELIEF 
Violations of Advisers Act Sections 206(1) and (2) 

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

paragraphs 1 through 70.  

78. At all relevant times, Ahmed was an investment adviser under Advisers Act 

Section 202(11) [15 U.S.C. § 80b-2(11)]. 

79. Ahmed, by use of the mails or any means or instrumentality of interstate 

commerce, directly or indirectly, has: (i) knowingly or recklessly employed one or more devices, 

schemes, or artifices to defraud any client or prospective client, and/or (ii) knowingly, recklessly, 

or negligently engaged in one or more transactions, practices, and courses of business which 

operated or would operate as a fraud or deceit upon any client or prospective client. 

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80. By reason of the foregoing, Ahmed, directly or indirectly, singly or in concert, has 

violated and, unless enjoined, will again violate Advisers Act Sections 206(1) and (2) [15 U.S.C. 

§§ 80b-6(1) and 80b-6(2)]. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that the Court enter a Final 

Judgment: 

I. 

Permanently enjoining Ahmed and his agents, servants, employees, and attorneys and all 

persons in active concert or participation with any of them from violating, directly or indirectly, 

Securities Act Section 17(a) [15 U.S.C. § 77q(a)], Exchange Act Section 10(b) [15 U.S.C. 

§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], Advisers Act Sections 206(1) and 

206(2) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)]; 

II. 

Ordering Ahmed to disgorge all ill-gotten gains that he received directly or indirectly, 

with pre-judgment interest thereon, as a result of the alleged violations, pursuant to Exchange 

Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C. §§ 78u(d)(3), 78u(d)(5), and 78u(d)(7)]; 

III. 

Ordering Ahmed to pay civil monetary penalties under Securities Act Section 20(d) 

[15 U.S.C. § 77t(d)], Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)], and Advisers Act 

Section 209(e) [15 U.S.C. §§ 80b-9(e) [15 U.S.C. § 77t(e)];  

IV. 

Permanently prohibiting Ahmed from directly or indirectly, including, but not limited to, 

through any entity owned or controlled by him, participating in the issuance, purchase, offer, or 

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sale of any security pursuant to Securities Act Section 20(b) [15 U.S.C. § 77t(b)], Exchange Act 

Sections 21(d)(1) and 21(d)(5) [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)], and Advisers Act Section 

209(d) [15 U.S.C. § 80b-9(d)]; provided, however, that such injunction shall not prevent him 

from purchasing or selling securities for his own personal accounts;  

V. 

Permanently enjoining Ahmed from, directly or indirectly, acting as or being associated 

with any investment adviser, pursuant to Securities Act Section 20(b) [15 U.S.C. § 77t(b)], 

Exchange Act Sections 21(d)(1) and 21(d)(5) [15 U.S.C. §§ 78u(d)(1) and 78u(d)(5)], and 

Advisers Act Section 209(d) [15 U.S.C. § 80b-9(d)]. For purposes of this paragraph, a person is 

associated with an investment adviser if such person is a partner, officer, or director of such 

investment adviser (or performs similar functions), or directly or indirectly controls or is 

controlled by such investment adviser, including any employee of such investment adviser; and 

VI. 
 

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

JURY DEMAND 
 

 The Commission demands a trial by jury.  

Case 1:25-cv-06730     Document 1     Filed 12/05/25     Page 17 of 18 PageID #: 17



   

 18 

 
Dated: New York, New York 

December 5, 2025 
____/s/ Ben Kuruvilla________________  
Thomas P. Smith, Jr. 
Adam S. Grace 
Brenda Chang 
Ben Kuruvilla 
Attorneys for Plaintiff 
SECURITIES AND EXCHANGE COMMISSION 
New York Regional Office 
100 Pearl Street  
Suite 20-100 
New York, NY 10004-2616 
(212) 336-5599 (Kuruvilla) 
[email protected] 

  
  
  

Case 1:25-cv-06730     Document 1     Filed 12/05/25     Page 18 of 18 PageID #: 18