SEC v. Faraz Dar; and Horizon Platinum LLC, No. 1:25-cv-12387, District of Massachusetts (Aug. 29, 2025) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE
COMMISSION,

   Plaintiff,
 v.

FARAZ DAR (also known as OSMAN
DAR) and HORIZON PLATINUM LLC,

   Defendants.

      Civil Action No. 25-CV-

COMPLAINT
 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the
following against defendants Faraz Dar, also known as Osman Dar (“Dar”) and Horizon
Platinum LLC (“Horizon” and collectively with Dar, “Defendants”  ):
SUMMARY
1. This case involves a fraudulent securities offering by Faraz Dar and his
Massachusetts-based company Horizon.  Between July 2019 and May 2023 (the “Relevant
Period”), Dar and Horizon raised money from investors who collectively invested in Horizon and
related entities.  Based on currently available information, those investments may total as high as
$30 million from over 30 investors worldwide.  Defendants falsely claimed that investors’ funds
would be used to operate Horizon, which was purportedly in the business of exporting luxury
cars from the United States to the United Arab Emirates and then further exporting those cars on
to other countries, including China and Russia.
2. Dar and Horizon engaged in a fraudulent scheme and made and used false and
misleading statements in connection with the sale of Horizon securities to investors.  Horizon’s
purported business of exporting luxury vehicles out of the United States did not exist.

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Automobile exporters are required to file export disclosures before transporting vehicles outside
of the United States.  No such filings were made by Horizon or Dar.
3. As part of their scheme to defraud, Defendants issued Horizon securities to
investors in the form of “Investment Certificates.”  These certificates included the investor’s
name, the date of the investment, the contract number, the amount of the investment, the
investment’s end date, and the projected value of the investment when it matured.  Some
Investment Certificates promised that investors would earn a return of 100% or more over an
investment period of three or four months.  These Investment Certificates were signed by Dar
and by the investor and stamped with Horizon’s seal – a raised circular stamp that said “Horizon
Platinum LLC, Company Seal, 2018, Massachusetts.”
4. Rather than using the bulk of investors’ investment funds to operate Horizon, as
Dar had promised investors, Dar spent the majority of those funds to pay for his lifestyle and
living expenses.  Those personal expenses included luxury clothing, jewelry, travel, hospital
payments, and golf supplies.
5.    In the course of soliciting investments, and lulling investors who were inquiring
about why they had not been repaid when their investments matured, Defendants made numerous
false and/or misleading statements to investors.  Defendants misrepresented: the uses to which
investors’ money would be or had been put, the purported reasons why Defendants could not
repay the investments when they were due, and the nature and success of Defendants’ business.
6. Defendants were able to keep the scheme going longer than it may otherwise have
lasted because they were able to convince some investors to roll over the principal and promised
interest from maturing investment certificates into new investment certificates with a higher
balance.  Defendants were thus able to avoid the need to make payments on some investment

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certificates when they were originally due.
7. In approximately May 2023, Defendants stopped making payments to investors
when their investment certificates matured.  As of the date of this Complaint, Defendants have
failed to repay at least $2.5 million in investment principal to investors with matured investment
certificates.  This sum does not account for the investment returns that Defendants promised to
these investors.
8. As a result of the conduct alleged herein, Defendants violated, and unless
restrained and enjoined will continue to violate, Section 10(b) of the Securities Exchange Act of
1934 (“Exchange Act”) and Rule 10b-5 thereunder [15 U.S.C. §78j(b); 17 C.F.R. §240.10b-5]
and Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §77q(a)].
9. Based on these violations, the Commission seeks from Defendants: (1) permanent
injunctions enjoining them from engaging in the transactions, acts, practices, and courses of
business of the type alleged in this Complaint in violation of the federal securities laws; (2)
disgorgement of ill-gotten gains from the unlawful conduct set forth in this Complaint, together
with prejudgment interest; ( 3)   civil penalties pursuant to Section 20(d) of the Securities Act [15
U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act [15 U.S.C. §78u(d)(3)], and such other
relief as the Court may deem appropriate.  In addition, the Commission seeks from Dar alone: (1)
a permanent injunction that would restrain Dar from directly or indirectly, including, but not
limited to, through any entity owned or controlled by Dar, participating in the issuance, purchase,
offer, or sale of any security, provided, however, that such injunction shall not prevent Dar from
purchasing or selling securities for his own personal account; and (2) an officer and director bar
pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. §78u(d)(2)].

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JURISDICTION AND VENUE
10. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and
22(a) of the Securities Act [15 U.S.C. §§77t(d)(1), 77v(a)] and Sections 21(d), 21(e), and 27 of
the Exchange Act [15 U.S.C §§78u(d), 78u(e) and 78aa].
11. Venue is proper in this Court pursuant to Section 22 of the Securities Act [15
U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 U.S.C §78aa].  Certain of the acts,
practices, transactions and courses of business constituting the violations alleged in this
Complaint occurred within the District of Massachusetts, and were effected, directly, or
indirectly, by making use of the means or instrumentalities of transportation or communication in
interstate commerce, or the mails, including the internet and the telephone.  Further, Defendant
Horizon is a Massachusetts corporation that claims its principal place of business is Boston,
Massachusetts.
12. Defendants’ conduct involved fraud, deceit, or deliberate or reckless disregard of
regulatory requirements, and resulted in substantial loss, or significant risk of substantial loss, to
other persons.
DEFENDANTS
13. Faraz Dar, also now known as Osman Dar, age 44, currently resides in Istanbul,
Turkey.  Before moving to Turkey in 2022, Dar resided in Dubai, United Arab Emirates
(“UAE”).  Dar is the owner of both Horizon and another Massachusetts corporation named
Marmara Trading LLC.
14. Horizon is a Massachusetts corporation.   It was incorporated on October 29,
2018, and filed its most recent annual report with the Massachusetts Secretary of State on
September 7, 2023.  In that, and previous reports, Horizon identified Boston, Massachusetts as

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its principal place of business.  At all relevant times, Dar has exercised control over Horizon and
has run all aspects of its business.
RELATED ENTITIES
15. Horizon Platinum Motors FZE (“HP Motors”) is a purported corporation owned
by Dar with a purported principal place of business in the UAE.  Dar often solicited investors to
invest in this entity as well as in Massachusetts-based Horizon.  Dar told investors that this entity
conducted the same type of business as Horizon.
16. Limitless Motors (“Limitless”) is a purported corporation controlled by Dar with
a purported principal place of business in the UAE.  Dar often solicited investors to invest in this
entity as well as in Horizon.  Dar told investors that this entity conducted the same type of
business as Horizon and the Limitless website claimed to be “an exclusive agent of Horizon
Platinum, LLC USA.”
17. Marmara Trading LLC (“Marmara”) is a Massachusetts corporation that identifies
its principal place of business as Winchester, Massachusetts.  It was incorporated on August 1,
2022, and filed its most recent annual report with the Massachusetts Secretary of State on July 1,
2024.  That filing identifies the general character of its business as “import export.”  At all
relevant times, Dar has exercised control over Marmara and has run all aspects of its business.
FACTUAL ALLEGATIONS
Dar’s and Horizon’s Purported Business
18. In its corporate annual reports filed with the Massachusetts Secretary of State
between 2019 and 2023, Horizon described the general character of its business as “buying and
selling cars online and exporting cars.”  Dar submitted and signed those reports.

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19. On its website, at least on or about July 16, 2024, Horizon advertised itself as
“one of the leading global auto dealers with experience in the import/import business.  With its
market leading digitized portal Horizon Platinum Portal makes the task of buying your perfect
automobile from any place in the world a flawless activity.  We take pride in having developed a
selected network of trusted and dependable dealers all over the world who have enabled us to
gain the confidence of numerous clients across the world.”  Horizon’s website also claimed to
have sold 1500 vehicles to 500 “happy customers.”
20. As of July 16, 2024, Horizon’s website advertised an inventory of 18 vehicles,
including ones manufactured by Audi, Ferrari, Bentley, Mercedes-Benz, and Lamborghini.  It
also listed its address in Boston, Massachusetts and provided a map to its office in Back Bay.
21. Between at least February 2019 and July 2024 (when the account was closed),
Horizon maintained bank accounts at Bank of America, and used an address in Tyngsboro,
Massachusetts, where one of his relatives resided, as the official address on that account.
22. Beginning in 2018, Dar solicited investors in Horizon by describing his business
as purchasing used luxury cars in the United States, for which he claimed buyers in other
countries, like Russia and China, would pay a premium, and then selling those cars to buyers in
other countries.  Dar’s solicitations commonly took place during social gatherings in his home in
the UAE, and he also asked people who invested in Horizon to solicit investments from their
own networks of friends.
23. As part of his solicitation, Dar explained to at least one investor, who then
explained to others, that Horizon would receive 50% downpayments from customers who
ordered vehicles, but his companies needed investments so that they could purchase the cars in
full, and pay for shipping, insurance and other costs.  Horizon’s investors would then be repaid,

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with a profit, when the customers paid the remaining 50% of the price on delivery to them of the
vehicles they ordered.
24. To memorialize investors’ investments, Dar typically provided investors with a
contract.  These contracts, titled “Investment Certificates,” had generally similar terms and were
typically signed both by Dar and by the investor and stamped with the corporate seal of Horizon,
which was a raised circular stamp reading “Horizon Platinum LLC, Company Seal, 2018,
Massachusetts.”
25. Horizon’s investment contracts offered investors rates of return that varied widely
for investments lasting generally between about three months and four months.  The contracts
specified the “investment start date,” the “projected investment end date,” the original
“investment amount” and the “projected maturation value.”  For example, an investment with a
“projected investment end date” of January 15, 2022 offered a return of 75% on an investment
lasting 100 to 120 days, and another with a “projected investment end date” of April 28, 2020
offered a return of 150% on an investment lasting 100 days.
26. The investment contracts typically stated that “At maturation, the investment sum
may be fully reinvested, partially reinvested and partially withdrawn, or fully withdrawn at
Investors preference.  Investor is to notify Horizon Platinum of his/her intentions a minimum of
two weeks before the conclusion of the investment term.  If no communication is received, the
entire sum will be reinvested for another term.”
27. The investment contracts each matured on a specified date (usually between three
and four months in the future) and typically provided that investors would be repaid their
principal plus their investment return when the investment matured.  Many of the investment
contracts noted, however, that Horizon was not responsible for a delay in investment payout that

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was caused by delays in shipping its vehicles caused by “any force majeure (including- extreme
weather conditions, piracy, terrorism, port issues, political or security instabilities or any other
factors outside of our control.) ”
28. Along with the Investment Certificates, Dar gave at least one investor guarantee
checks, which were checks made out to the investor in the amount of his original investments.
Dar told this investor that he could cash these checks if Horizon defaulted in repaying.  When the
investor tried to cash one of the guarantee checks, which was written on a Limitless account in a
UAE bank, he found that the account was closed.
29. Investors typically transferred their investment funds to Horizon’s account in
Massachusetts by wire transfer, but some also made their payments by check, by credit card
payment, or by giving cash to someone working for Dar.
30. When the investments matured, Dar often succeeded in delaying his repayment
obligations by convincing investors to roll over their investments into new Investment
Certificates.
31. Though Dar made some periodic or partial payments to some investors, he
eventually stopped repaying investors.  As excuses for nonpayment, Dar variously claimed that:
he owed taxes to the shipping companies so the cars were stuck in customs, COVID-19
restrictions in China prevented him from being paid, and Russia’s war with Ukraine prevented
some customers from paying for the cars.
32. At the same time that he was soliciting investments in Horizon, Dar also solicited
investments in two UAE based businesses – HP Motors and Limitless.  At least two investors
invested in Horizon, HP Motors and Limitless at around the same time.  One investor reported
that Dar asked for an investment in one of the three companies, but gave the investor an

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investment contract from a different company.  Dar told the investor that the three companies
were sister companies engaging in overlapping business activities so that it did not matter which
company signed a contract.  The other investor made at least two investments in Horizon by
wiring funds to its U.S . bank account, and, in exchange, received Investment Certificates issued
both by Limitless and by HP Motors, and also received “guarantee” checks written on a
Limitless account in the UAE that could purportedly be cashed if Horizon did not repay the
investments.
33. Horizon’s U.S . bank account records confirm this comingling of funds.  Between
December 2019 and January 2021, Dar wired $126,324.98 from Horizon to Limitless and
$54,454.40 from Limitless to Horizon.
34. Defendants were making some repayments to some investors between 2019 and
2021, but by early 2022, nearly all repayments to investors stopped.  This stoppage happened at
about the same time Dar relocated from the UAE to Turkey, changed his name, and became a
Turkish citizen.
35. To date, the Commission has identified at least six investors who invested with
Horizon during the Relevant Period and transmitted their investment payments in whole or in
part to Horizon’s Massachusetts bank account.  Combined, those six investors invested over $4.1
million with Horizon.  The Commission estimates that Defendants have failed to repay at least
$2.5 million in investment principal to those six investors with matured investment contracts.
This sum does not account for the investment returns that Defendants promised to these
investors.

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36. In addition, based on its review of available bank records and investor interviews,
the Commission estimates that other investments in some combination of Horizon, HP Motors
and Limitless may total as high as $30 million and may involve over 30 investors.
Examples of Specific Investments
37. Investor 1 entered into numerous Investment Certificates with Dar between July
2019 and August 2021.  Some of these Investment Certificates bore the logo and corporate stamp
of Horizon and some bore the logo and corporate stamp of HP Motors.  The only difference in
the two companies’ logos was the addition of  “Motors” after “Horizon Platinum” on the HP
Motors Investment Certificates.  A chart of Investor 1’s Investment Certificates appears below:
Investment
Start Date
Projected
Investment
End Date
Company
Issuing the
Investment
Certificate
Currency
(AED or
USD)
Investment
Amount
Projected
Maturation
Value
7/15/2019 10/30/2019 HP Motors AED 100,000 125,000
8/15/2019 11/30/2019 HP Motors AED 192,000 274,560
8/27/2019 12/7/2019 HP Motors AED 120,000 194,400
9/25/2019 12/24/2019 HP Motors AED 190,000 304,000
11/2/2019 2/7/2020 HP Motors  AED 367,000 594,540
11/2/2019 2/7/2020 HP Motors AED 210,000 382,200
11/30/2019 3/28/2020 HP Motors AED 1,455,570 2,980,359
11/30/2019 3/28/2020 HP Motors AED 55,000 110,000
11/30/2019 3/28/2020 HP Motors AED 135,000 270,000
12/29/2019 4/20/2020 HP Motors AED 304,000 532,000
12/29/2019 4/20/2020 HP Motors USD 55,000 121,000
1/9/2020 4/28/2020 HP Motors AED 110,000 220,000
1/9/2020 4/28/2020 Horizon USD 28,000 70,000
2/5/2020 5/28/2020 HP Motors AED 552,000 1,104,000
2/5/2020 5/28/2020 HP Motors AED 100,000 200,000
2/11/2020 5/28/2020 Horizon USD 30,000 60,000
2/11/2020 5/28/2020 Horizon USD 50,000 125,000
2/27/2020 6/15/2020 Horizon Does not
specify
15,000 26,250
3/5/2020 7/9/2020 HP Motors AED 150,000 285,000
4/1/2020 8/20/2020 HP Motors AED 2,205,000 4,410,000
4/17/2020 9/10/2020 HP Motors AED 920,000 1,748,000
4/17/2020 9/10/2020 HP Motors AED 160,000 336,000
4/17/2020 9/10/2020 HP Motors AED 200,000 400,000

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4/17/2020 9/10/2020 Horizon
1
 USD 200,000 460,000
4/17/2020 9/10/2020 Horizon Does not
specify
27,500 87,500
5/29/2020 9/20/2020 HP Motors AED 450,000 900,000
5/29/2020 9/20/2020 HP Motors AED 100,000 210,000
5/29/2020 9/20/2020 HP Motors AED 160,000 336,000
5/29/2020 9/20/2020 Horizon USD 240,000 504,000
6/29/2020 10/25/2020 HP Motors AED 200,000 420,000
6/29/2020 10/25/2020 HP Motors AED 188,000 488,800
9/5/2020 12/29/2020 HP Motors AED 2,000,000 3,600,000
9/5/2020 12/29/2020 HP Motors AED 1,000,000 2,400,000
9/5/2020 12/29/2020 HP Motors AED 1,200,000 2,400,000
9/5/2020 1/10/2021 HP Motors AED 1,330,000 2,660,000
9/29/2020 1/10/2021 HP Motors AED 140,000 357,000
9/29/2020 1/10/2021 Horizon USD 500,000 1,235,000
11/15/2020 2/26/2021 HP Motors AED 175,000 402,500
12/7/2020 4/26/2021 HP Motors AED 200,000 460,000
1/15/2021 5/29/2021 HP Motors AED 5,703,350 11,406,700
1/15/2021 5/29/2021 Horizon USD 2,700,000 5,400,000
6/2/2021 11/3/2020 Horizon Does not
specify
5,300,000 8,109,000
6/2/2021 11/3/20221 Horizon Does not
specify
3,046,114 4,660,555
8/3/2021 12/31/2021 HP Motors AED 1,680,000 2,436,000
8/3/2021 12/31/2021 HP Motors AED 92,000 149,960

38. The language of each of these Investment Certificates (other than the dates and
amounts) was substantially the same.  Each of these Investment Certificates was signed by Dar.
39. On some of these Investment Certificates, Investor 1 is the sole investor.  On
several others, Investor 1 is part of a group of investors whose names are listed.  In those
instances where Investor 1 is part of a group of investors, Investor 1 only made a portion of the
investment payment, with the balance coming from other investors in the group.
40. Some of these Investment Certificates do not represent contributions of new
money by Investor 1.  Rather, Dar encouraged Investor 1 to roll over some of his maturing

1
 Investment Contract issued by Horizon but the corporate stamp is that of HP Motors.

12

investments into new contracts, so the “investment amount” shown on some of these Investment
Certificates represents the rolled over investment principal contributed by Investor 1 plus some
amount of profits that Defendants had promised to pay Investor 1 on earlier Investment
Certificates.
41. Investor 1 received some payments on his Investment Certificates over time.
Many of those payments were made to him from bank accounts in the name of Limitless, rather
than from Horizon or HP Motors.
42. Investor 1 estimates that Defendants owe him approximately $438,000 USD in
investment principal that they have not repaid to him.  Based solely on transactions flowing
through Horizon’s Massachusetts bank account, Defendants have not repaid $35,108 USD
contributed by Investor 1.
43. Investor 1 understood that Dar and his related businesses were using his
investment funds to facilitate the export of cars from the United States to the UAE and other
countries.
44. Several of Investor 1’s investments were made by wire transfer to Horizon’s
Massachusetts bank account.  Dar was the sole authorized signatory on Horizon’s bank account
at the time of these transfers.
45. Based on Horizon’s bank records, it appears that Investor 1’s funds were not used
to make investments that facilitated an automobile exporting business, contrary to the
representations made by Dar and in the Investment Certificates.  Rather, a portion of Investor 1’s
funds appear to have been transferred to Dar’s personal account.  For example, Investor 1 sent a
wire transfer of $50,000 to Horizon’s Massachusetts account on February 18, 2020.  Between
March 2, 2020 and March 20, 2020, Dar transferred $31,755 from Horizon’s account to his

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personal account. Similarly, Investor 1 sent a wire transfer of $14,640 to Horizon’s
Massachusetts account on September 2, 2020.  On September 8, 2020, Dar transferred $5,000 to
his personal account.
46. Investor 2 entered into four Investment Certificates with Dar and Horizon
between June 2020 and September 2021.  Investor 2, who is a United States resident, was
introduced to the investment opportunity through a relative who lived in the UAE and had met
Dar.  Investor 2 then met Dar personally when he traveled to Dubai in 2020.
47. Dar’s sales pitch to Investor 2 was that people would spend a lot of money on
exotic cars and it was a lucrative business.  Dar told Investor 2 that he was providing vehicles to
Russia, China, and the UAE and made his business sound like a big operation that even provided
vehicles to the royal family of the UAE.  Investor 2 thought the contracts he saw looked official
and genuine.
48. Each of Investor 2’s Investment Certificates bore the logo and corporate stamp of
Horizon, and was signed by Dar.  The language of each of these Investment Certificates (other
than the dates and amounts) was substantially the same.  A chart of Investor 2’s investments
appears below:
Investment
Start Date
Projected
Investment
End Date
Company
Issuing the
Investment
Certificate
Currency
(AED or
USD)
Investment
Amount
Projected
Maturation
Value
6/10/2020 10/25/2020 Horizon USD $20,000 $44,000
6/15/2020 10/15/2020 Horizon USD $20,000 $34,000
1/15/2021 5/29/2021 Horizon USD $30,000 $50,400
9/7/2021 1/15/2022 Horizon USD $50,000 $87,500
   Total $120,000

49. Unlike other investors, Investor 2 did not receive payments on his Investment
Certificates over time.  Instead, he was told that his investments would be rolled over into future

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investments.
50. When Investor 2’s Investment Certificates all matured, he, and his relative who
had also invested, requested payment from Dar.  Dar provided a series of excuses for why he
could not repay Investor 2, including delays due to COVID, China lockdowns and the Russia-
Ukraine war.
51. All of Investor 2’s investments were made by wire transfer to Horizon’s
Massachusetts bank account.  Dar was the sole authorized signatory on Horizon’s bank account
at the time of these transfers.
52. Based on Horizon’s bank records, it appears that Investor 2’s funds were not used
to make investments that facilitated an automobile exporting business, contrary to the
representations made by Dar and in the Investment Certificates.  Rather, a portion of Investor 2’s
funds appear to have been transferred to Dar’s personal account.  For example, Investor 2 sent
two wire transfers of $20,000 each to Horizon’s Massachusetts account on June 9, 2020 and July
1, 2020.  Those two wires, combined with other funds, resulted in an account balance of $59,979.
Over the next several weeks, between July 6 and July 29, 2020, Dar transferred $42,850 from
Horizon’s account to his personal accounts.
53. To date, Defendants have not repaid any of Investor 2’s $120,000 in investment
principal or any promised investment income.
Dar and Horizon Misrepresented the Uses of Investors’ Funds and their Conduct is
Characteristic of a Ponzi Scheme

54. Defendants’ representations that investors’ funds would be used to operate and
finance an automobile exporting business were false and misleading.  At the time they made
these representations, Dar and Horizon knew, or had reason to know, or were reckless in not
knowing, that the money invested by their investors was not being, and would not be, used to

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fund the automobile exporting business described in the investors’ investment contracts.
Horizon’s bank records show few, if any, disbursements of funds for car purchases, for shipping
expenses, for insurance expenses, or for any other expenses that would appear necessary for such
a business.  Further, Horizon’s bank records do not show repayments from vehicle purchasers to
Horizon.
55. In addition, in order to export a vehicle valued at more than $2,500 from the
United States, federal law requires certain disclosures to be made and filed with the U.S.
Customs and Border Protection (“CBP”) agency at least 72 hours before the vehicle departs the
United States.  See Federal Trade Regulations, 15 C.F.R. Subtit. B, Ch. 1, pt. 30.  Required
disclosures include the title transaction number, the vehicle identification number and the title.
These disclosures must be made through CBP’s Automated Export System.  There are no records
of vehicles being exported from the United States during the Relevant Period by Dar, Horizon,
HP Motors, or Limitless.
56. Instead, Horizon’s bank records show a pattern of investors’ funds being
disbursed shortly after they were deposited to fund, among other things:  1) payments to other
investors, 2) payments to personal bank accounts belonging to Dar, 3) payments for Dar’s credit
card bills, and 4) payments to other businesses owned or controlled by Dar.
57. The use of later investors’ funds to repay earlier investors whose investments had
matured is characteristic of a Ponzi scheme.  Dar explicitly told at least one investor that he
would not be able to pay out that investor’s return unless that investor brought in a new investor
to Horizon and/or HP Motors.
58. In addition, Dar solicited certain investors to “roll over” their principal and return
into a subsequent investment, i.e. decline to take the payout and instead directly reinvest the

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proceeds in the scheme.  Such an approach is characteristic of a Ponzi scheme because it allows
the operator of the Ponzi scheme to avoid needing to make a payout, thereby keeping investor
funds under his or her control.
59. Many investors in Horizon and HP Motors whose investment contracts have
matured have not been repaid either their principal or promised investment return.  Based on the
bank account information currently available about Horizon’s Massachusetts accounts,
Defendants took in at least $2.5 million more in investor deposits than they have repaid to
investors.  It is likely that Horizon owes far more to investors through its use of foreign bank
accounts and the foreign bank accounts of its affiliated companies, HP Motors and Limitless.
FIRST CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES

Defendants’ Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder

60. Paragraphs 1 through 59 above are re-alleged and incorporated by reference as if
fully set forth herein.
61. By reason of the conduct described above, Defendants, directly or indirectly, in
connection with the purchase or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, or of any facility of any national securities exchange,
intentionally, knowingly, or recklessly, (i) employed devices, schemes, or artifices to defraud;
(ii) made untrue statements of material facts or omitted to state material facts necessary to make
the statements made, in the light of the circumstances under which they were made, not
misleading; and/or (iii) engaged in acts, practices, or courses of business which operated or
would operate as a fraud or deceit upon any persons, including purchasers or sellers of the
securities.
62. Defendants’ conduct involved fraud, deceit, manipulation or deliberate or reckless

17

disregard of regulatory requirements and directly or indirectly resulted in substantial losses to
other persons.
63. By reason of the conduct described above, Defendants violated Exchange Act
Section 10(b) [15 U.S.C. §78j(b)] and Rule 10b-5 [17 C.F.R §240.10b-5] thereunder.
SECOND CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES

Defendants’ Violations of Sections 17(a) of the Securities Act

64. Paragraphs 1 through 59 above are re-alleged and incorporated by reference as if
fully set forth herein.
65. By reason of the conduct described above, Defendants, directly or indirectly, in
connection with the offer or sale of securities, by the use of the means or instrumentalities of
interstate commerce or of the mails, directly or indirectly, acting intentionally, knowingly,
recklessly, or negligently: (i) employed devices, schemes, or artifices to defraud; (ii) obtained
money or property by means of untrue statements of material fact or by omitting to state material
facts necessary in order to make statements made, in the light of the circumstances under which
they were made, not misleading; or (iii) engaged in transactions, practices, or courses of business
which operated or would operate as a fraud or deceit upon any persons, including purchasers or
sellers of the securities.
66. By reason of the conduct described above, Defendants violated Securities Act
Sections 17(a) [15 U.S.C. §77q(a)] and will continue to violate that section unless enjoined.
PRAYER FOR RELIEF
 WHEREFORE, the Commission respectfully requests that this Court:
 A. Permanently restrain Defendants, their agents, servants, employees and attorneys,
and those persons in active concert or participation with them who receive actual notice of the

18

injunction by personal services or otherwise, and each of them, from violating Section 10(b) of
the Exchange Act [15 U.S.C. §78j(b)], and Rule 10b-5 thereunder [17 C.F.R §240.10b-5]   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;
 (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 by, directly or indirectly, (i) creating a false appearance or otherwise deceiving any
person, or (ii) disseminating false or misleading documents, materials, or information or making,
either orally or in writing, any false or misleading statement in any communication with any
investor or prospective investor, about: (A) any investment strategy or investment in securities,
(B) the prospects for success of any product or company,
 (C) the use of investor funds, (D)
compensation to any person, (E) Defendants’ qualifications to advise investors; or (F) the
misappropriation of investor funds or investment proceeds.
 B. Permanently restrain Defendants, their agents, servants, employees and attorneys,
and those persons in active concert or participation with them who receive actual notice of the
injunction by personal services or otherwise, and each of them, from violating Section 17(  a) of
the Securities Act [15 U.S.C. §77q(a)], by using any means or instrumentality of interstate
commerce, or of the mails, or of any facility of any national securities exchange, in the offer or
sale of any security:
 (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 the light of the circumstances under

19

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 by, directly or
indirectly, (i) creating a false appearance or otherwise deceiving any person, or (ii) disseminating
false or misleading documents, materials, or information or making, either orally or in writing,
any false or misleading statement in any communication with any investor or prospective
investor, about: (A) any investment strategy or investment in securities, (B) the prospects for
success of any product or company,
 (C) the use of investor funds, (D) compensation to any
person, (E) Defendants’ qualifications to advise investors; or (F) the misappropriation of investor
funds or investment proceeds.
C. Permanently restrain Dar from directly or indirectly, including, but not limited to,
through any entity owned or controlled by Dar, participating in the issuance, purchase, offer, or
sale of any security, provided, however, that such injunction shall not prevent Dar from
purchasing or selling securities for his own personal account.
D. Enter an order barring Dar from serving as an officer or director of certain public
companies, pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. §78u(d)(2)].
E. Order Defendants, jointly and severally, to disgorge, with prejudgment interest,
their i ll-  gotten gains obtained by reason of the unlawful conduct alleged in this Complaint;
F. Order Defendants each to pay an appropriate civil monetary penalty pursuant to
Section 20(d) of the Securities Act [15 U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act
[15 U.S.C. §78u(d)(3)];
G. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered; and
H. Grant such other further relief as the Court may deem just and proper.

20

JURY DEMAND
 The Commission demands a jury in this matter for all claims so triable.
DATED: August 28, 2025
      Respectfully submitted,
      /s/ Kathleen Burdette Shields
      Kathleen Burdette Shields (BBO #637438)
      Sarah Joanne McAteer (BBO #706403)
      SECURITIES AND EXCHANGE COMMISSION
      Boston Regional Office
      33 Arch Street, 24
th
 Floor
      Boston, MA 02110
      Phone: (617) 573-8904 (Shields direct)
      (617) 573-8906 (McAteer direct)
(617) 573-4590 (fax)
      [email protected]
 (Shields email)
      [email protected] (McAteer email)

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
SECURITIES AND EXCHANGE 
COMMISSION, 
 
   Plaintiff, 
 v. 
 
FARAZ DAR (also known as OSMAN 
DAR) and HORIZON PLATINUM LLC, 
 
   Defendants. 

 
 
      Civil Action No. 25-CV- 
 
 
 

 
COMPLAINT 

 Plaintiff, Securities and Exchange Commission (the “Commission”), alleges the 

following against defendants Faraz Dar, also known as Osman Dar (“Dar”) and Horizon 

Platinum LLC (“Horizon” and collectively with Dar, “Defendants”): 

SUMMARY 

1. This case involves a fraudulent securities offering by Faraz Dar and his 

Massachusetts-based company Horizon.  Between July 2019 and May 2023 (the “Relevant 

Period”), Dar and Horizon raised money from investors who collectively invested in Horizon and 

related entities.  Based on currently available information, those investments may total as high as 

$30 million from over 30 investors worldwide.  Defendants falsely claimed that investors’ funds 

would be used to operate Horizon, which was purportedly in the business of exporting luxury 

cars from the United States to the United Arab Emirates and then further exporting those cars on 

to other countries, including China and Russia.   

2. Dar and Horizon engaged in a fraudulent scheme and made and used false and 

misleading statements in connection with the sale of Horizon securities to investors.  Horizon’s 

purported business of exporting luxury vehicles out of the United States did not exist.  

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Automobile exporters are required to file export disclosures before transporting vehicles outside 

of the United States.  No such filings were made by Horizon or Dar. 

3. As part of their scheme to defraud, Defendants issued Horizon securities to 

investors in the form of “Investment Certificates.”  These certificates included the investor’s 

name, the date of the investment, the contract number, the amount of the investment, the 

investment’s end date, and the projected value of the investment when it matured.  Some 

Investment Certificates promised that investors would earn a return of 100% or more over an 

investment period of three or four months.  These Investment Certificates were signed by Dar 

and by the investor and stamped with Horizon’s seal – a raised circular stamp that said “Horizon 

Platinum LLC, Company Seal, 2018, Massachusetts.”  

4. Rather than using the bulk of investors’ investment funds to operate Horizon, as 

Dar had promised investors, Dar spent the majority of those funds to pay for his lifestyle and 

living expenses.  Those personal expenses included luxury clothing, jewelry, travel, hospital 

payments, and golf supplies.  

5.    In the course of soliciting investments, and lulling investors who were inquiring 

about why they had not been repaid when their investments matured, Defendants made numerous 

false and/or misleading statements to investors.  Defendants misrepresented: the uses to which 

investors’ money would be or had been put, the purported reasons why Defendants could not 

repay the investments when they were due, and the nature and success of Defendants’ business. 

6. Defendants were able to keep the scheme going longer than it may otherwise have 

lasted because they were able to convince some investors to roll over the principal and promised 

interest from maturing investment certificates into new investment certificates with a higher 

balance.  Defendants were thus able to avoid the need to make payments on some investment 

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3 
 

certificates when they were originally due. 

7. In approximately May 2023, Defendants stopped making payments to investors 

when their investment certificates matured.  As of the date of this Complaint, Defendants have 

failed to repay at least $2.5 million in investment principal to investors with matured investment 

certificates.  This sum does not account for the investment returns that Defendants promised to 

these investors. 

8. As a result of the conduct alleged herein, Defendants violated, and unless 

restrained and enjoined will continue to violate, Section 10(b) of the Securities Exchange Act of 

1934 (“Exchange Act”) and Rule 10b-5 thereunder [15 U.S.C. §78j(b); 17 C.F.R. §240.10b-5] 

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

9. Based on these violations, the Commission seeks from Defendants: (1) permanent 

injunctions enjoining them from engaging in the transactions, acts, practices, and courses of 

business of the type alleged in this Complaint in violation of the federal securities laws; (2) 

disgorgement of ill-gotten gains from the unlawful conduct set forth in this Complaint, together 

with prejudgment interest; (3) civil penalties pursuant to Section 20(d) of the Securities Act [15 

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

relief as the Court may deem appropriate.  In addition, the Commission seeks from Dar alone: (1) 

a permanent injunction that would restrain Dar from directly or indirectly, including, but not 

limited to, through any entity owned or controlled by Dar, participating in the issuance, purchase, 

offer, or sale of any security, provided, however, that such injunction shall not prevent Dar from 

purchasing or selling securities for his own personal account; and (2) an officer and director bar 

pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. §78u(d)(2)]. 

 

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4 
 

JURISDICTION AND VENUE 

10. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and 

22(a) of the Securities Act [15 U.S.C. §§77t(d)(1), 77v(a)] and Sections 21(d), 21(e), and 27 of 

the Exchange Act [15 U.S.C §§78u(d), 78u(e) and 78aa].   

11. Venue is proper in this Court pursuant to Section 22 of the Securities Act [15 

U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 U.S.C §78aa].  Certain of the acts, 

practices, transactions and courses of business constituting the violations alleged in this 

Complaint occurred within the District of Massachusetts, and were effected, directly, or 

indirectly, by making use of the means or instrumentalities of transportation or communication in 

interstate commerce, or the mails, including the internet and the telephone.  Further, Defendant 

Horizon is a Massachusetts corporation that claims its principal place of business is Boston, 

Massachusetts. 

12. Defendants’ conduct involved fraud, deceit, or deliberate or reckless disregard of 

regulatory requirements, and resulted in substantial loss, or significant risk of substantial loss, to 

other persons. 

DEFENDANTS 

13. Faraz Dar, also now known as Osman Dar, age 44, currently resides in Istanbul, 

Turkey.  Before moving to Turkey in 2022, Dar resided in Dubai, United Arab Emirates 

(“UAE”).  Dar is the owner of both Horizon and another Massachusetts corporation named 

Marmara Trading LLC.   

14. Horizon is a Massachusetts corporation.   It was incorporated on October 29, 

2018, and filed its most recent annual report with the Massachusetts Secretary of State on 

September 7, 2023.  In that, and previous reports, Horizon identified Boston, Massachusetts as 

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5 
 

its principal place of business.  At all relevant times, Dar has exercised control over Horizon and 

has run all aspects of its business. 

RELATED ENTITIES 

15. Horizon Platinum Motors FZE (“HP Motors”) is a purported corporation owned 

by Dar with a purported principal place of business in the UAE.  Dar often solicited investors to 

invest in this entity as well as in Massachusetts-based Horizon.  Dar told investors that this entity 

conducted the same type of business as Horizon. 

16. Limitless Motors (“Limitless”) is a purported corporation controlled by Dar with 

a purported principal place of business in the UAE.  Dar often solicited investors to invest in this 

entity as well as in Horizon.  Dar told investors that this entity conducted the same type of 

business as Horizon and the Limitless website claimed to be “an exclusive agent of Horizon 

Platinum, LLC USA.” 

17. Marmara Trading LLC (“Marmara”) is a Massachusetts corporation that identifies 

its principal place of business as Winchester, Massachusetts.  It was incorporated on August 1, 

2022, and filed its most recent annual report with the Massachusetts Secretary of State on July 1, 

2024.  That filing identifies the general character of its business as “import export.”  At all 

relevant times, Dar has exercised control over Marmara and has run all aspects of its business.  

FACTUAL ALLEGATIONS 

Dar’s and Horizon’s Purported Business 

18. In its corporate annual reports filed with the Massachusetts Secretary of State 

between 2019 and 2023, Horizon described the general character of its business as “buying and 

selling cars online and exporting cars.”  Dar submitted and signed those reports. 

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6 
 

19. On its website, at least on or about July 16, 2024, Horizon advertised itself as 

“one of the leading global auto dealers with experience in the import/import business.  With its 

market leading digitized portal Horizon Platinum Portal makes the task of buying your perfect 

automobile from any place in the world a flawless activity.  We take pride in having developed a 

selected network of trusted and dependable dealers all over the world who have enabled us to 

gain the confidence of numerous clients across the world.”  Horizon’s website also claimed to 

have sold 1500 vehicles to 500 “happy customers.”   

20. As of July 16, 2024, Horizon’s website advertised an inventory of 18 vehicles, 

including ones manufactured by Audi, Ferrari, Bentley, Mercedes-Benz, and Lamborghini.  It 

also listed its address in Boston, Massachusetts and provided a map to its office in Back Bay. 

21. Between at least February 2019 and July 2024 (when the account was closed), 

Horizon maintained bank accounts at Bank of America, and used an address in Tyngsboro, 

Massachusetts, where one of his relatives resided, as the official address on that account. 

22. Beginning in 2018, Dar solicited investors in Horizon by describing his business 

as purchasing used luxury cars in the United States, for which he claimed buyers in other 

countries, like Russia and China, would pay a premium, and then selling those cars to buyers in 

other countries.  Dar’s solicitations commonly took place during social gatherings in his home in 

the UAE, and he also asked people who invested in Horizon to solicit investments from their 

own networks of friends. 

23. As part of his solicitation, Dar explained to at least one investor, who then 

explained to others, that Horizon would receive 50% downpayments from customers who 

ordered vehicles, but his companies needed investments so that they could purchase the cars in 

full, and pay for shipping, insurance and other costs.  Horizon’s investors would then be repaid, 

Case 1:25-cv-12387     Document 1     Filed 08/28/25     Page 6 of 20



7 
 

with a profit, when the customers paid the remaining 50% of the price on delivery to them of the 

vehicles they ordered. 

24. To memorialize investors’ investments, Dar typically provided investors with a 

contract.  These contracts, titled “Investment Certificates,” had generally similar terms and were 

typically signed both by Dar and by the investor and stamped with the corporate seal of Horizon, 

which was a raised circular stamp reading “Horizon Platinum LLC, Company Seal, 2018, 

Massachusetts.”   

25. Horizon’s investment contracts offered investors rates of return that varied widely 

for investments lasting generally between about three months and four months.  The contracts 

specified the “investment start date,” the “projected investment end date,” the original 

“investment amount” and the “projected maturation value.”  For example, an investment with a 

“projected investment end date” of January 15, 2022 offered a return of 75% on an investment 

lasting 100 to 120 days, and another with a “projected investment end date” of April 28, 2020 

offered a return of 150% on an investment lasting 100 days.   

26. The investment contracts typically stated that “At maturation, the investment sum 

may be fully reinvested, partially reinvested and partially withdrawn, or fully withdrawn at 

Investors preference.  Investor is to notify Horizon Platinum of his/her intentions a minimum of 

two weeks before the conclusion of the investment term.  If no communication is received, the 

entire sum will be reinvested for another term.”   

27. The investment contracts each matured on a specified date (usually between three 

and four months in the future) and typically provided that investors would be repaid their 

principal plus their investment return when the investment matured.  Many of the investment 

contracts noted, however, that Horizon was not responsible for a delay in investment payout that 

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8 
 

was caused by delays in shipping its vehicles caused by “any force majeure (including- extreme 

weather conditions, piracy, terrorism, port issues, political or security instabilities or any other 

factors outside of our control.)”   

28. Along with the Investment Certificates, Dar gave at least one investor guarantee 

checks, which were checks made out to the investor in the amount of his original investments.  

Dar told this investor that he could cash these checks if Horizon defaulted in repaying.  When the 

investor tried to cash one of the guarantee checks, which was written on a Limitless account in a 

UAE bank, he found that the account was closed. 

29. Investors typically transferred their investment funds to Horizon’s account in 

Massachusetts by wire transfer, but some also made their payments by check, by credit card 

payment, or by giving cash to someone working for Dar. 

30. When the investments matured, Dar often succeeded in delaying his repayment 

obligations by convincing investors to roll over their investments into new Investment 

Certificates. 

31. Though Dar made some periodic or partial payments to some investors, he 

eventually stopped repaying investors.  As excuses for nonpayment, Dar variously claimed that: 

he owed taxes to the shipping companies so the cars were stuck in customs, COVID-19 

restrictions in China prevented him from being paid, and Russia’s war with Ukraine prevented 

some customers from paying for the cars. 

32. At the same time that he was soliciting investments in Horizon, Dar also solicited 

investments in two UAE based businesses – HP Motors and Limitless.  At least two investors 

invested in Horizon, HP Motors and Limitless at around the same time.  One investor reported 

that Dar asked for an investment in one of the three companies, but gave the investor an 

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9 
 

investment contract from a different company.  Dar told the investor that the three companies 

were sister companies engaging in overlapping business activities so that it did not matter which 

company signed a contract.  The other investor made at least two investments in Horizon by 

wiring funds to its U.S. bank account, and, in exchange, received Investment Certificates issued 

both by Limitless and by HP Motors, and also received “guarantee” checks written on a 

Limitless account in the UAE that could purportedly be cashed if Horizon did not repay the 

investments. 

33. Horizon’s U.S. bank account records confirm this comingling of funds.  Between 

December 2019 and January 2021, Dar wired $126,324.98 from Horizon to Limitless and 

$54,454.40 from Limitless to Horizon. 

34. Defendants were making some repayments to some investors between 2019 and 

2021, but by early 2022, nearly all repayments to investors stopped.  This stoppage happened at 

about the same time Dar relocated from the UAE to Turkey, changed his name, and became a 

Turkish citizen. 

35. To date, the Commission has identified at least six investors who invested with 

Horizon during the Relevant Period and transmitted their investment payments in whole or in 

part to Horizon’s Massachusetts bank account.  Combined, those six investors invested over $4.1 

million with Horizon.  The Commission estimates that Defendants have failed to repay at least 

$2.5 million in investment principal to those six investors with matured investment contracts.  

This sum does not account for the investment returns that Defendants promised to these 

investors. 

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10 
 

36. In addition, based on its review of available bank records and investor interviews, 

the Commission estimates that other investments in some combination of Horizon, HP Motors 

and Limitless may total as high as $30 million and may involve over 30 investors.   

Examples of Specific Investments 

37. Investor 1 entered into numerous Investment Certificates with Dar between July 

2019 and August 2021.  Some of these Investment Certificates bore the logo and corporate stamp 

of Horizon and some bore the logo and corporate stamp of HP Motors.  The only difference in 

the two companies’ logos was the addition of  “Motors” after “Horizon Platinum” on the HP 

Motors Investment Certificates.  A chart of Investor 1’s Investment Certificates appears below: 

Investment 
Start Date 

Projected 
Investment 
End Date 

Company 
Issuing the 
Investment 
Certificate 

Currency 
(AED or 

USD) 

Investment 
Amount 

Projected 
Maturation 

Value 

7/15/2019 10/30/2019 HP Motors AED 100,000 125,000 
8/15/2019 11/30/2019 HP Motors AED 192,000 274,560 
8/27/2019 12/7/2019 HP Motors AED 120,000 194,400 
9/25/2019 12/24/2019 HP Motors AED 190,000 304,000 
11/2/2019 2/7/2020 HP Motors  AED 367,000 594,540 
11/2/2019 2/7/2020 HP Motors AED 210,000 382,200 
11/30/2019 3/28/2020 HP Motors AED 1,455,570 2,980,359 
11/30/2019 3/28/2020 HP Motors AED 55,000 110,000 
11/30/2019 3/28/2020 HP Motors AED 135,000 270,000 
12/29/2019 4/20/2020 HP Motors AED 304,000 532,000 
12/29/2019 4/20/2020 HP Motors USD 55,000 121,000 
1/9/2020 4/28/2020 HP Motors AED 110,000 220,000 
1/9/2020 4/28/2020 Horizon USD 28,000 70,000 
2/5/2020 5/28/2020 HP Motors AED 552,000 1,104,000 
2/5/2020 5/28/2020 HP Motors AED 100,000 200,000 
2/11/2020 5/28/2020 Horizon USD 30,000 60,000 
2/11/2020 5/28/2020 Horizon USD 50,000 125,000 
2/27/2020 6/15/2020 Horizon Does not 

specify 
15,000 26,250 

3/5/2020 7/9/2020 HP Motors AED 150,000 285,000 
4/1/2020 8/20/2020 HP Motors AED 2,205,000 4,410,000 
4/17/2020 9/10/2020 HP Motors AED 920,000 1,748,000 
4/17/2020 9/10/2020 HP Motors AED 160,000 336,000 
4/17/2020 9/10/2020 HP Motors AED 200,000 400,000 

Case 1:25-cv-12387     Document 1     Filed 08/28/25     Page 10 of 20



11 
 

4/17/2020 9/10/2020 Horizon1 USD 200,000 460,000 
4/17/2020 9/10/2020 Horizon Does not 

specify 
27,500 87,500 

5/29/2020 9/20/2020 HP Motors AED 450,000 900,000 
5/29/2020 9/20/2020 HP Motors AED 100,000 210,000 
5/29/2020 9/20/2020 HP Motors AED 160,000 336,000 
5/29/2020 9/20/2020 Horizon USD 240,000 504,000 
6/29/2020 10/25/2020 HP Motors AED 200,000 420,000 
6/29/2020 10/25/2020 HP Motors AED 188,000 488,800 
9/5/2020 12/29/2020 HP Motors AED 2,000,000 3,600,000 
9/5/2020 12/29/2020 HP Motors AED 1,000,000 2,400,000 
9/5/2020 12/29/2020 HP Motors AED 1,200,000 2,400,000 
9/5/2020 1/10/2021 HP Motors AED 1,330,000 2,660,000 
9/29/2020 1/10/2021 HP Motors AED 140,000 357,000 
9/29/2020 1/10/2021 Horizon USD 500,000 1,235,000 
11/15/2020 2/26/2021 HP Motors AED 175,000 402,500 
12/7/2020 4/26/2021 HP Motors AED 200,000 460,000 
1/15/2021 5/29/2021 HP Motors AED 5,703,350 11,406,700 
1/15/2021 5/29/2021 Horizon USD 2,700,000 5,400,000 
6/2/2021 11/3/2020 Horizon Does not 

specify 
5,300,000 8,109,000 

6/2/2021 11/3/20221 Horizon Does not 
specify 

3,046,114 4,660,555 

8/3/2021 12/31/2021 HP Motors AED 1,680,000 2,436,000 
8/3/2021 12/31/2021 HP Motors AED 92,000 149,960 

 

38. The language of each of these Investment Certificates (other than the dates and 

amounts) was substantially the same.  Each of these Investment Certificates was signed by Dar. 

39. On some of these Investment Certificates, Investor 1 is the sole investor.  On 

several others, Investor 1 is part of a group of investors whose names are listed.  In those 

instances where Investor 1 is part of a group of investors, Investor 1 only made a portion of the 

investment payment, with the balance coming from other investors in the group. 

40. Some of these Investment Certificates do not represent contributions of new 

money by Investor 1.  Rather, Dar encouraged Investor 1 to roll over some of his maturing 

 
1 Investment Contract issued by Horizon but the corporate stamp is that of HP Motors. 

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12 
 

investments into new contracts, so the “investment amount” shown on some of these Investment 

Certificates represents the rolled over investment principal contributed by Investor 1 plus some 

amount of profits that Defendants had promised to pay Investor 1 on earlier Investment 

Certificates. 

41. Investor 1 received some payments on his Investment Certificates over time.  

Many of those payments were made to him from bank accounts in the name of Limitless, rather 

than from Horizon or HP Motors. 

42. Investor 1 estimates that Defendants owe him approximately $438,000 USD in 

investment principal that they have not repaid to him.  Based solely on transactions flowing 

through Horizon’s Massachusetts bank account, Defendants have not repaid $35,108 USD 

contributed by Investor 1. 

43. Investor 1 understood that Dar and his related businesses were using his 

investment funds to facilitate the export of cars from the United States to the UAE and other 

countries.   

44. Several of Investor 1’s investments were made by wire transfer to Horizon’s 

Massachusetts bank account.  Dar was the sole authorized signatory on Horizon’s bank account 

at the time of these transfers.  

45. Based on Horizon’s bank records, it appears that Investor 1’s funds were not used 

to make investments that facilitated an automobile exporting business, contrary to the 

representations made by Dar and in the Investment Certificates.  Rather, a portion of Investor 1’s 

funds appear to have been transferred to Dar’s personal account.  For example, Investor 1 sent a 

wire transfer of $50,000 to Horizon’s Massachusetts account on February 18, 2020.  Between 

March 2, 2020 and March 20, 2020, Dar transferred $31,755 from Horizon’s account to his 

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13 
 

personal account. Similarly, Investor 1 sent a wire transfer of $14,640 to Horizon’s 

Massachusetts account on September 2, 2020.  On September 8, 2020, Dar transferred $5,000 to 

his personal account. 

46. Investor 2 entered into four Investment Certificates with Dar and Horizon 

between June 2020 and September 2021.  Investor 2, who is a United States resident, was 

introduced to the investment opportunity through a relative who lived in the UAE and had met 

Dar.  Investor 2 then met Dar personally when he traveled to Dubai in 2020. 

47. Dar’s sales pitch to Investor 2 was that people would spend a lot of money on 

exotic cars and it was a lucrative business.  Dar told Investor 2 that he was providing vehicles to 

Russia, China, and the UAE and made his business sound like a big operation that even provided 

vehicles to the royal family of the UAE.  Investor 2 thought the contracts he saw looked official 

and genuine. 

48. Each of Investor 2’s Investment Certificates bore the logo and corporate stamp of 

Horizon, and was signed by Dar.  The language of each of these Investment Certificates (other 

than the dates and amounts) was substantially the same.  A chart of Investor 2’s investments 

appears below: 

Investment 
Start Date 

Projected 
Investment 
End Date 

Company 
Issuing the 
Investment 
Certificate 

Currency 
(AED or 

USD) 

Investment 
Amount 

Projected 
Maturation 

Value 

6/10/2020 10/25/2020 Horizon USD $20,000 $44,000 
6/15/2020 10/15/2020 Horizon USD $20,000 $34,000 
1/15/2021 5/29/2021 Horizon USD $30,000 $50,400 
9/7/2021 1/15/2022 Horizon USD $50,000 $87,500 
   Total $120,000  

 

49. Unlike other investors, Investor 2 did not receive payments on his Investment 

Certificates over time.  Instead, he was told that his investments would be rolled over into future 

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14 
 

investments. 

50. When Investor 2’s Investment Certificates all matured, he, and his relative who 

had also invested, requested payment from Dar.  Dar provided a series of excuses for why he 

could not repay Investor 2, including delays due to COVID, China lockdowns and the Russia-

Ukraine war.   

51. All of Investor 2’s investments were made by wire transfer to Horizon’s 

Massachusetts bank account.  Dar was the sole authorized signatory on Horizon’s bank account 

at the time of these transfers.  

52. Based on Horizon’s bank records, it appears that Investor 2’s funds were not used 

to make investments that facilitated an automobile exporting business, contrary to the 

representations made by Dar and in the Investment Certificates.  Rather, a portion of Investor 2’s 

funds appear to have been transferred to Dar’s personal account.  For example, Investor 2 sent 

two wire transfers of $20,000 each to Horizon’s Massachusetts account on June 9, 2020 and July 

1, 2020.  Those two wires, combined with other funds, resulted in an account balance of $59,979.  

Over the next several weeks, between July 6 and July 29, 2020, Dar transferred $42,850 from 

Horizon’s account to his personal accounts. 

53. To date, Defendants have not repaid any of Investor 2’s $120,000 in investment 

principal or any promised investment income. 

Dar and Horizon Misrepresented the Uses of Investors’ Funds and their Conduct is 
Characteristic of a Ponzi Scheme 
 

54. Defendants’ representations that investors’ funds would be used to operate and 

finance an automobile exporting business were false and misleading.  At the time they made 

these representations, Dar and Horizon knew, or had reason to know, or were reckless in not 

knowing, that the money invested by their investors was not being, and would not be, used to 

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fund the automobile exporting business described in the investors’ investment contracts.  

Horizon’s bank records show few, if any, disbursements of funds for car purchases, for shipping 

expenses, for insurance expenses, or for any other expenses that would appear necessary for such 

a business.  Further, Horizon’s bank records do not show repayments from vehicle purchasers to 

Horizon. 

55. In addition, in order to export a vehicle valued at more than $2,500 from the 

United States, federal law requires certain disclosures to be made and filed with the U.S. 

Customs and Border Protection (“CBP”) agency at least 72 hours before the vehicle departs the 

United States.  See Federal Trade Regulations, 15 C.F.R. Subtit. B, Ch. 1, pt. 30.  Required 

disclosures include the title transaction number, the vehicle identification number and the title.  

These disclosures must be made through CBP’s Automated Export System.  There are no records 

of vehicles being exported from the United States during the Relevant Period by Dar, Horizon, 

HP Motors, or Limitless.  

56. Instead, Horizon’s bank records show a pattern of investors’ funds being 

disbursed shortly after they were deposited to fund, among other things:  1) payments to other 

investors, 2) payments to personal bank accounts belonging to Dar, 3) payments for Dar’s credit 

card bills, and 4) payments to other businesses owned or controlled by Dar. 

57. The use of later investors’ funds to repay earlier investors whose investments had 

matured is characteristic of a Ponzi scheme.  Dar explicitly told at least one investor that he 

would not be able to pay out that investor’s return unless that investor brought in a new investor 

to Horizon and/or HP Motors. 

58. In addition, Dar solicited certain investors to “roll over” their principal and return 

into a subsequent investment, i.e. decline to take the payout and instead directly reinvest the 

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proceeds in the scheme.  Such an approach is characteristic of a Ponzi scheme because it allows 

the operator of the Ponzi scheme to avoid needing to make a payout, thereby keeping investor 

funds under his or her control. 

59. Many investors in Horizon and HP Motors whose investment contracts have 

matured have not been repaid either their principal or promised investment return.  Based on the 

bank account information currently available about Horizon’s Massachusetts accounts, 

Defendants took in at least $2.5 million more in investor deposits than they have repaid to 

investors.  It is likely that Horizon owes far more to investors through its use of foreign bank 

accounts and the foreign bank accounts of its affiliated companies, HP Motors and Limitless. 

FIRST CLAIM FOR RELIEF 
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES  

 
Defendants’ Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder 

 
60. Paragraphs 1 through 59 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

61. By reason of the conduct described above, Defendants, directly or indirectly, in 

connection with the purchase or sale of securities, by the use of the means or instrumentalities of 

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

intentionally, knowingly, or recklessly, (i) employed devices, schemes, or artifices to defraud; 

(ii) made untrue statements of material facts or omitted to state material facts necessary to make 

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

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

would operate as a fraud or deceit upon any persons, including purchasers or sellers of the 

securities. 

62. Defendants’ conduct involved fraud, deceit, manipulation or deliberate or reckless 

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disregard of regulatory requirements and directly or indirectly resulted in substantial losses to 

other persons. 

63. By reason of the conduct described above, Defendants violated Exchange Act 

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

SECOND CLAIM FOR RELIEF 
FRAUD IN THE OFFER OR SALE OF SECURITIES 

 
Defendants’ Violations of Sections 17(a) of the Securities Act  

 
64. Paragraphs 1 through 59 above are re-alleged and incorporated by reference as if 

fully set forth herein. 

65. By reason of the conduct described above, Defendants, directly or indirectly, in 

connection with the offer or sale of securities, by the use of the means or instrumentalities of 

interstate commerce or of the mails, directly or indirectly, acting intentionally, knowingly, 

recklessly, or negligently: (i) employed devices, schemes, or artifices to defraud; (ii) obtained 

money or property by means of untrue statements of material fact or by omitting to state material 

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

they were made, not misleading; or (iii) engaged in transactions, practices, or courses of business 

which operated or would operate as a fraud or deceit upon any persons, including purchasers or 

sellers of the securities. 

66. By reason of the conduct described above, Defendants violated Securities Act 

Sections 17(a) [15 U.S.C. §77q(a)] and will continue to violate that section unless enjoined. 

PRAYER FOR RELIEF 

 WHEREFORE, the Commission respectfully requests that this Court: 

 A. Permanently restrain Defendants, their agents, servants, employees and attorneys, 

and those persons in active concert or participation with them who receive actual notice of the 

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injunction by personal services or otherwise, and each of them, from violating Section 10(b) of 

the Exchange Act [15 U.S.C. §78j(b)], and Rule 10b-5 thereunder [17 C.F.R §240.10b-5] 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; (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 by, directly or indirectly, (i) creating a false appearance or otherwise deceiving any 

person, or (ii) disseminating false or misleading documents, materials, or information or making, 

either orally or in writing, any false or misleading statement in any communication with any 

investor or prospective investor, about: (A) any investment strategy or investment in securities, 

(B) the prospects for success of any product or company, (C) the use of investor funds, (D) 

compensation to any person, (E) Defendants’ qualifications to advise investors; or (F) the 

misappropriation of investor funds or investment proceeds.  

 B. Permanently restrain Defendants, their agents, servants, employees and attorneys, 

and those persons in active concert or participation with them who receive actual notice of the 

injunction by personal services or otherwise, and each of them, from violating Section 17(a) of 

the Securities Act [15 U.S.C. §77q(a)], by using any means or instrumentality of interstate 

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

sale of any security: (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 the light of the circumstances under 

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19 
 

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 by, directly or 

indirectly, (i) creating a false appearance or otherwise deceiving any person, or (ii) disseminating 

false or misleading documents, materials, or information or making, either orally or in writing, 

any false or misleading statement in any communication with any investor or prospective 

investor, about: (A) any investment strategy or investment in securities, (B) the prospects for 

success of any product or company, (C) the use of investor funds, (D) compensation to any 

person, (E) Defendants’ qualifications to advise investors; or (F) the misappropriation of investor 

funds or investment proceeds.  

C. Permanently restrain Dar from directly or indirectly, including, but not limited to, 

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

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

purchasing or selling securities for his own personal account. 

D. Enter an order barring Dar from serving as an officer or director of certain public 

companies, pursuant to Section 21(d)(2) of the Exchange Act [15 U.S.C. §78u(d)(2)]. 

E. Order Defendants, jointly and severally, to disgorge, with prejudgment interest, 

their ill-gotten gains obtained by reason of the unlawful conduct alleged in this Complaint; 

F. Order Defendants each to pay an appropriate civil monetary penalty pursuant to 

Section 20(d) of the Securities Act [15 U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act 

[15 U.S.C. §78u(d)(3)]; 

G. Retain jurisdiction over this action to implement and carry out the terms of all 

orders and decrees that may be entered; and  

H. Grant such other further relief as the Court may deem just and proper. 

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JURY DEMAND 

 The Commission demands a jury in this matter for all claims so triable. 

DATED: August 28, 2025 

      Respectfully submitted, 

      /s/ Kathleen Burdette Shields    
      Kathleen Burdette Shields (BBO #637438)  
      Sarah Joanne McAteer (BBO #706403) 
      SECURITIES AND EXCHANGE COMMISSION 
      Boston Regional Office 
      33 Arch Street, 24th Floor 
      Boston, MA 02110 
      Phone: (617) 573-8904 (Shields direct) 
      (617) 573-8906 (McAteer direct) 

(617) 573-4590 (fax) 
      [email protected] (Shields email) 
      [email protected] (McAteer email) 

Case 1:25-cv-12387     Document 1     Filed 08/28/25     Page 20 of 20

mailto:[email protected]
mailto:[email protected]