SEC v. ANTON SENDEROV; LIOR BABAZARA; and LIOR BAR, No. 4:19-cv-05242, Eastern District of Washington (Oct. 10, 2019) — Complaint

COMPLAINT 1

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Christian D. H. Schultz
Assistant Chief Litigation Counsel
David A. Nasse
Trial Counsel
Division of Enforcement
SECURITIES AND EXCHANGE COMMISSION
100 F. Street N.E.
Washington, D.C. 20549
Telephone: (202) 551-4740 (Schultz)
Email:  [email protected]

Attorneys for Plaintiff
Securities and Exchange Commission
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON
SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
ANTON SENDEROV and LIOR
BABAZARA a/k/a/ LIOR BAR,

Defendants,

  Case No. 19-cv-5242

COMPLAINT

JURY TRIAL REQUESTED

    Plaintiff Securities and Exchange Commission (the “SEC”) alleges:
SUMMARY OF THE ACTION
1. This case concerns a fraudulent scheme in which investors in the United
States deposited millions of dollars into online trading accounts in connection with
the illegal offer and sale of high risk securities called “binary options”

from at least
January 2014 through August 2017 (the “Relevant Period”).

COMPLAINT 2

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2. Anton Senderov and Lior Babazara a/k/a Lior Bar (collectively, the
“Defendants”) controlled and operated two internet-based binary options brokers
called LBinary/Live Binary at www.Lbinary.com (“LBinary”) and Ivory Option at
www.ivoryoption.com (“Ivory Option”).  The LBinary and Ivory Option websites
each contained a binary options trading platform where investors could open and fund
trading accounts and trade binary options, including binary options referencing
securities.
3. The Defendants also owned, controlled, and operated LianTech Finance
Marketing, Ltd a/k/a LianTech Ltd. (“LianTech”), which operated a call center in
Israel and maintained and operated the LBinary and/or Ivory Option websites.
Employees at the LianTech call center solicited investors in the United States to open
and fund binary options trading accounts with the websites, and some of them
purported to advise investors on binary option trading after they opened such
accounts.
4. LianTech used LBinary and Ivory Option to fraudulently make
unregistered offers and sales of binary options that referenced well-known securities
to investors in the United States.  The Defendants, operating from Israel, controlled
these activities and thereby directly or indirectly offered and sold binary options to
United States investors through these entities.
5. The LBinary and Ivory Option websites, and employees at the LianTech
call center, described the binary options offered through those websites as a profitable

COMPLAINT 3

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investment even for retail investors with little to no experience in trading securities.
In reality, the binary option offerings deceived many investors into depositing large
sums of money into trading accounts at LBinary and Ivory Option, which were
operated or controlled by the Defendants. Many investors then lost all or nearly all of
their investment through unprofitable binary option trades and other deceptive or
manipulative devices.
6. To persuade retail investors in the United States to invest in the binary
options offered on the LBinary and Ivory Option trading platforms, the LianTech call
center employees and the websites made numerous false and misleading statements
and engaged in deceptive business practices to defraud investors.  For example, the
LBinary and Ivory Option websites and the call center employees claimed that
investors could make large profits trading binary options while working with
LianTech’s supposedly experienced investment professionals.  In fact, the LianTech
call center employees were trained to lie about their backgrounds and investment
experience.  Further, they failed to disclose that the interests of LianTech, LBinary,
and Ivory Option were actually opposed to the interests of the investors because
LianTech, LBinary, and Ivory Option made money only when investors made
unprofitable “losing” binary option trades on the online trading platforms.  This is
material information that reasonable investors would want to know before they
deposited money with LBinary or Ivory Option and made binary option trading
decisions with advice and assistance from LianTech.

COMPLAINT 4

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7. LianTech, LBinary, and Ivory Option did not register with the SEC as a
broker or dealer, were never associated with an SEC-registered broker or dealer, and
never registered with the SEC any of their offers or sales of binary options made
through the LBinary and Ivory Option websites.
8. LianTech solicited thousands of investors in the United States who
opened binary options trading accounts with LBinary or Ivory Option.  As a result of
the fraudulent representations on the LBinary and Ivory Option websites, and the
deceptive conduct of LianTech call center employees, Defendants procured millions
of dollars in deposits from investors in the United States in connection with the offer
and sale of binary options.  Many investors lost significant portions of their invested
deposits.
9. Defendants’ offers and sales of binary options through LianTech,
LBinary, and Ivory Option violated the registration provisions of Sections 5(a) and
5(c) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a) and
77e(c)].  Because Defendants controlled LianTech, LBinary, and Ivory Option, they
also are liable as control persons under Section 20(a) of the Securities Exchange Act
of 1934 (“Exchange Act”) [15 U.S.C. § 78t(a)] for those entities’ violations of the
antifraud provisions of Section 10(b) of the Exchange Act [15 U.S.C. §§ 78j(b)], and
Rule 10b-5(a) and (c) thereunder [17 C.F.R. § 240.10b‒5], as well as the broker
registration provision of Section 15(a)(1) of the Exchange Act [15 U.S.C. §
78o(a)(1)].

COMPLAINT 5

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10. The SEC seeks disgorgement of Defendants’ ill-gotten gains,
prejudgment interest, civil monetary penalties, an injunction against further violations
of the federal securities laws, and other appropriate relief.  Unless restrained and
enjoined by this Court, Defendants are likely to continue to engage in the acts and
practices alleged herein.
JURISDICTION AND VENUE
11. The SEC brings this action pursuant to Sections 20(b), 20(d)(1), and
22(a) of the Securities Act [15 U.S.C. §§ 77t(b), 77t(d)(1) & 77v(a)] and Sections
21(d)(1), 21(d)(3)(A), 21(e), and 27(a) of the Exchange Act [15 U.S.C. §§ 78u(d)(1),
78u(d)(3)(A), 78u(e) & 78aa(a)].  Defendants, directly or indirectly, made use of the
means or instrumentalities of interstate commerce, of the mails, or of the facilities of
a national securities exchange in connection with the transactions, acts, practices and
courses of business alleged in this Complaint, including by making use of the Internet
to offer and sell securities and sending or receiving interstate and/or international
emails or audio/video communications.  This Court has subject matter jurisdiction
under Section 22 of the Securities Act [15 U.S.C. § 77v], Sections 21(d) and 27 of the
Exchange Act [15 U.S.C. §§ 78u(d) and 78aa], and 28 U.S.C. § 1331.
12. Venue is proper in this district under Section 22(a) of the Securities Act
[15 U.S.C. § 77v(a)] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa(a)]
because certain of the transactions, acts, practices, and courses of conduct
constituting violations of the federal securities laws occurred within this district,

COMPLAINT 6

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including at least one investor who was defrauded out of approximately $500,000.
Venue also is proper under 28 U.S.C. § 1391(c)(3), as each of the Defendants resides
outside of the United States.
DEFENDANTS

13. Anton Senderov, age 34, is a citizen of Israel and is believed to reside
in Israel.  Senderov, along with Lior Babazara, owned, controlled, and operated
LianTech, which derives its name from the first two letters of the Defendants’ first
names (i.e., LIor and ANton).  Senderov also controlled the LBinary and Ivory
Options websites.
14. Lior Babazara (also known as Lior Bar), age 37, is a citizen of Israel
and is believed to reside in Israel.  Babazara, along with Senderov, owned, controlled,
and operated LianTech, through which Senderov controlled the LBinary and Ivory
Options websites.
FACTS
I. THE DEFENDANTS’ BINARY OPTIONS OFFERINGS
15. A “binary option” is a financial instrument that expires at a
predetermined time where the payout is contingent on the future value of an
underlying asset, such as a security or securities index.  Binary options like those sold
though the LBinary and Ivory Option online trading platforms are “binary” because
they carry only two possible outcomes.  Upon expiration, its holder will receive a

COMPLAINT 7

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predetermined amount of money, or nothing or nearly nothing, depending on whether
the underlying asset increases or decreases in value.
16. For example, if the current market price of a reference stock, “ABC,
Inc.,” is $100 per share, an investor could use the LBinary or Ivory Option trading
platform to trade a binary option on whether the price of that stock would be above or
below $100 at a certain time in the future (e.g. ABC, Inc., stock will be above $100 at
1 p.m.).  If, at the expiration of the binary option, the investor’s trade proved correct –
i.e., the price of ABC, Inc., stock was above $100 at 1 p.m. – the investor might
receive 175% of his original investment.  If the stock price at expiration of the binary
option was less than $100, the investor would forfeit all or nearly all of his original
investment.
17. Binary options in which the underlying financial asset is a security or
securities within the meaning of Section 2(a)(1) of the Exchange Act [15 U.S.C. §
77b(a)(1)] and Section 3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)] are
themselves “securities” within the meaning of those provisions.
18. During the Relevant Period and through LianTech, Defendants
controlled two internet-based, binary options brokers called LBinary/Live Binary and
Ivory Option using www.Lbinary.com and www.ivoryoption.com websites.  These
online brokers offered and sold security-based binary options over the internet to
investors in the United States and around the world.

COMPLAINT 8

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19. Through the trading platforms on the LBinary and Ivory Option
websites, LianTech call center employees offered and sold to investors binary options
with payouts that were contingent on the value of common stocks, including Google,
Nike, Coca Cola, Citi Group, Apple, IBM, Microsoft, and numerous other domestic
and international companies.  The referenced securities also included numerous
domestic and international securities indices, including the Nasdaq Composite and
Dow Jones Industrial Average.
20. The LBinary and Ivory Option websites included statements that
described themselves as binary options trading brokers and characterized the
purchase of binary options through their trading platforms as trading and investing.
21. The Defendants owned, controlled, and operated LianTech Finance
Marketing, Ltd, a/k/a LianTech, Ltd., which operated a call center in Israel.
Employees at the LianTech call center solicited investors in the United States to open
and fund binary options trading accounts with LBinary or Ivory Option. In some
cases, LianTech employees represented themselves to investors as financial advisors
who recommended particular binary option trades and  executed trades on investors’
behalf.
II. DEFENDANTS’ BINARY OPTION SCHEME
22. The LBinary and Ivory Option websites were made to appear like
legitimate online broker’ websites and advertised binary options as profitable and

COMPLAINT 9

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simple investments, even for retail investors with little to no experience in trading
securities.
23. Entities controlled by the Defendants were the counterparty on every
single binary option trade that investors made through the online trading platforms, or
that call center employees made through those platforms on behalf of the investors
whose accounts they handled.
24. LianTech and entities controlled by Defendants did not charge Investors
any fees to trade binary options through the online trading platforms.  Rather, because
they sat on the opposite side of the investors on every trade, the entities controlled by
the Defendants retained the amounts investors placed on losing trades as revenue and
profits.  This fact was not explained to investors by LianTech call center employees
or otherwise clearly disclosed to investors.
25.  Accordingly, the interests of the Defendants, LianTech, and entities they
controlled were in direct conflict with the interests of their investors.  The investors
sought to profitably trade binary options, while Defendants, LianTech, and entities
they controlled depended on investors losing trades for revenue so that they could
fund their operations and earn a profit.
26. Consistent with this conflict of interest, the LianTech business model
and compensation structure incentivized call center employees to deceive investors
into depositing significant sums of money into trading accounts, and, through a
variety of deceptive acts, to cause those investors to lose their deposits.

COMPLAINT 10

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A. Finding Investor Victims
27. The LianTech call center employees identified potential victims for their
scam through contracts with third-party affiliate marketers.  These affiliate marketers
identified potential investors, and made an initial solicitation to them, by creating
false and misleading online advertising materials, including elaborate infomercial-
like videos, and by sending thousands of fraudulent spam emails to potential
investors.  These materials were designed to persuade prospective investors to visit
the LBinary and Ivory Option websites and open a binary option trading account with
a small minimum deposit, typically around $250.  For every investor that did so, after
viewing an affiliate’s marketing materials, LianTech paid that affiliate marketer a
commission.
28. After a prospective investor opened and funded a trading account
through the LBinary or Ivory Option websites, or otherwise registered or expressed
an interest with one of the websites, an employee from the LianTech call center
contacted them to encourage them to make large deposits and start trading binary
options.
B. Fraudulent Call Center Operations
29. The LianTech call center operated like a boiler room where sales persons
used deceptive, high-pressure tactics to offer and sell binary options that LBinary and
Ivory Option offered through their trading platforms.  Call center employees were
trained to build rapport with investors, convince investors to deposit as much money

COMPLAINT 11

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as possible into their trading accounts, and induce investors to trade binary options,
resulting in those investors typically losing all or nearly all of the funds they had
deposited.
30. Sales employees at the LianTech call center were expected to make a
minimum of 300 telephone calls each day and obtain a minimum of 8 deposits a
week.  From 2014 to 2017, the LianTech call center employed, over time, more than
one hundred people.
31. LianTech call center sales employees were paid a base salary and a
commission.  Each employee’s commission was calculated, not as a percentage of the
investors’ profits or trading activity, but rather as a percentage of the deposits made
by investors whose accounts that employee handled.  As a result, LianTech call
center sales employees were incentivized to fraudulently induce investors to deposit
significant funds to trade binary options, and to deter investors from withdrawing
those funds.
32. Investors typically deposited money with LBinary or Ivory Option by
credit card or bank wire at the direction of LianTech call center employees.  These
payments went to accounts held by third-party entities, which may have been directly
or indirectly owned or controlled by the Defendants or otherwise tied to LianTech’s
operations, and investor deposits were then transferred to LianTech and other
individuals and entities.

COMPLAINT 12

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33. LianTech call center sales employees were trained to make false
statements to investors concerning their professional background, experience and
location to gain investors’ trust and mislead them into believing that they had
significant experience as investment professionals and the necessary qualifications to
advise investors on how to trade binary options profitably.
34. LianTech call center sales employees were trained to create fake
biographies and use aliases instead of their real names.  They were trained to claim to
be older than they actually were, to have numerous years of experience working in
financial markets and trading securities, to have earned significant sums trading
binary options, and to be located in Europe rather than Israel.
35. In reality, call center employees were located in the LianTech call center
in Israel, were typically younger than they claimed, had significantly less experience
working in the financial sector or advising investors on trading securities than they
claimed to investors, and had not earned large sums trading binary options.  The
LianTech call center sales employees also fabricated professional sounding titles
normally associated with legitimate trading and the provision of financial advice,
such as “Financial Advisor,” “Head of Managed Accounts,” and “Chief Trading
Officer.”
36. LianTech training materials instructed call center sales employees on
how to conduct their first solicitation call with potential investors.  These materials
also instructed employees to describe their fake personas and inform investors about

COMPLAINT 13

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potential profits they could earn.  Tellingly, these materials did not instruct the
employees to inform investors that the entities controlled by the Defendants were the
counterparties on every investor trade and that they earned money whenever investors
lost money on those trades.
37. Reasonable investors would have considered it important to their
investment decisions to know that the interests of LBinary, Ivory Option, and
LianTech were not aligned with their own, and that call center employees were
fabricating their financial experience as well as their experience advising other
investors on how to profitably trade securities.
38. Once investors made initial deposits, LianTech call center sales
employees transferred investors to other sales employees in what was referred to as
the “retention department.”  Sales employees in the retention department made
additional false and misleading statements for the purpose of persuading investors to
deposit as much money as possible into their trading accounts.
39. Alignment of Interest.  Retention department employees informed
investors that the entities controlled by the Defendants earned money by taking a
percentage of the profits that investors earned from winning binary option trades.  In
addition, promotional materials provided to certain investors stated that commissions
would be taken as percentage of “monthly profit.”  In reality,  LianTech, LBinary,
and Ivory Option earned money only when investors had losing binary option trades.

COMPLAINT 14

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40. Promises of profitable trades.  Retention department employees made it
a business practice to promise investors that trading in binary options would be
highly profitable.  For example, in a Skype Chat with one investor, a LianTech call
center employee wrote, “We will watch your money double in the next 30 days with
no further investments[.]”  Another investor was told if he deposited $30,000 to
$40,000, he could expect to withdraw profits of $3,000 to $4,000 per month.  Still
another investor was told that the goal was for his investments to earn 7 percent a
month.  This practice was misleading and deceptive because the retention department
employees knew (or recklessly failed to know) that many if not most investors were
extremely unlikely to make any money trading binary options.
41. Elevation to “VIP” Status.  The retention department employees
routinely told investors that if they increased their total deposits to a particular
level—usually in the five- and six- figure range—they would achieve “VIP,” “gold,”
“platinum,” or some similarly-named elevated status that provided access to more
experienced brokers, larger payouts, and access to special VIP-only trading
opportunities.  In fact, these elevated status benefits were largely illusory and these
pitches were nothing more than lures to induce investors to deposit additional funds.
42. Insured Trades.  For investors with LBinary and Ivory Option who
deposited sufficient funds to meet the requirements to enter into a VIP group,
retention department employees offered purported “insured trades.”  VIP marketing
materials regarding the VIP program that were sent to investors, claim to provide

COMPLAINT 15

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“insured trading events” where all trades were “100% insured” to “give a ‘sure
profit.’”  In reality, there was no “insurance” on any investors’ trades.
43. Withdrawals.  LianTech call center employees told investors they could
withdraw funds whenever they wanted with no restrictions.  When investors
submitted withdrawal requests to either LBinary or Ivory Option, however, these
requests were typically ignored, not processed, or denied due to withdrawal
restrictions in certain purported terms and conditions.
44. In some cases, investors were told that the withdrawals were processed
and they should await payment to their accounts, only for days and weeks to pass
without the withdrawal appearing in the customers’ bank or credit card accounts.
45. In other instances, after investors had stopped making additional
deposits and had submitted withdrawal requests, retention department employees
made unauthorized binary option trades in the investors’ accounts.  In one such case,
an employee lost more than $400,000 in an investor’s account in a matter of days. In
another instance, a LianTech employee traded away nearly $107,000 in an investor’s
account.
46. After investors submitted withdrawal requests, the retention department
employees who had served as their account representatives often ceased all
communications with them and “disappeared.”  Investors who were able to reach
someone at the LianTech call center were often told that their account representatives
were sick, on vacation, in meetings, or otherwise busy with other investors.

COMPLAINT 16

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47. Reasonable investors would have considered it important to their
investment decisions to know that that the LianTech call center employees’ in the
retention department were falsely representing (1) the alleged alignment of interests;
(2) the likelihood of profitable trades; (3) the alleged benefits under the “VIP
Program”; (4) that the trades were insured; and (5) that investors could easily
withdraw their funds.
C. Deceptive Websites
48. Ivory Option and LBinary licensed the technology and infrastructure
necessary to run their binary options websites from SpotOption, Ltd., a binary options
platform provider that has helped numerous entities defraud investors with binary
options trading scams.  Under these license agreements, SpotOption provided Ivory
Option and LBinary with Internet software infrastructure, a website interface, a
binary option trading platform, and customer relationship management software
(“CRM”).  Defendants and LianTech simply put the Ivory Option and LBinary
“branding” on the SpotOption trading platform and embedded it on their websites.
49. The trading platform embedded on the Ivory Option and LBinary
websites created the appearance of actual market-oriented options trading that looked
similar to what an investor might see on a legitimate broker’s website.  The trading
platform allowed investors to place “trades,” see “live” market quotations, make
deposits, and track their trades and balances.  The trading platform referred to binary

COMPLAINT 17

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options positions as “investments” or “trades” and showed the assets the positions
referenced, including the names of relevant securities.
50. Similar to the way a legitimate broker would operate, LBinary’s and
Ivory Option’s websites and other promotional materials stated, respectively, in 2015
and 2016 that, “Investors’ funds are held in a segregated account.  These funds are
used only for trading options on our website.”  These statements were false and
misleading because investor deposits were actually placed in aggregated accounts
from which expenses associated with running the business were regularly paid,
including salary payments to call center employees, commissions to affiliate
marketers, and purported “licensing” payments to SpotOption, Ltd.
51. Reasonable investors would have considered it important to their
investment decisions to know that their funds were not segregated as represented on
the LBinary and Ivory Option websites and were instead being used to pay the
expenses of LianTech, LBinary, Ivory Option and other entities controlled and/or
operated by the Defendants.
52. The LBinary and Ivory Option websites contained additional false
and misleading statements.  For example, LBinary’s website stated in 2015 that,
“Trading is conducted only upon the client’s instructions, and are not to be used for
any other cause. Our liabilities and exposures are professionally handled and we
guarantee pay-outs of your profits based on our terms.”  These statements were false
and misleading because at times LianTech call center employees placed trades

COMPLAINT 18

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directly in investor accounts without the investor’s knowledge or consent and
LianTech frequently did not honor investors’ legitimate withdrawal requests.
53. Reasonable investors would have considered it important to their
investment decisions to know that the entities controlled by the Defendants would
engage in unauthorized trading and refuse their legitimate withdrawal requests.
54. In addition, LBinary’s website contained the following additional
statements in 2015:
“Our account managers are experienced professionals that
provide guided material, one-on-one coaching, and scheduled
webinars.”

“The coalition of a user–friendly and flexible platform along
with guided expertise allows our investors to maximize earnings
with minimal effort from the comfort of their own home.”

“LBinary’s brokers are the best in the business. The company
hires experienced brokers, which have led the company to
become the leading brokerage in Europe. The reason that our
company and our investors have had so much success is because
of the level of expertise our brokers possess and project onto our
traders. Each of our brokers bring with them their own skill set
that they have developed and modeled over years of experience
trading in financial markets.”

“A One-on-One session can be helpful for all types of Binary
Option traders, no matter how experienced you may be. For
those who have no background in the business, a One-on-One
session is a great opportunity to consult with a professional
while going through the full process of making a Binary Option
trade.”

55. These statements were false and misleading because the employees at
the LianTech call center were trained to use fake names, titles, and credentials and

COMPLAINT 19

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were either not experienced professionals capable of providing expert guidance to
investors to help them make profitable binary options trades, or were not nearly as
experienced as they claimed to be.  These statements are also false and misleading
because the so-called “brokers” had no incentive to help investors “succeed.”  Rather,
these employees were incentivized to obtain the largest possible deposit from
investors and to deter withdrawals.  Moreover, LBinary was not a leading brokerage
in Europe, but rather a boiler room call center operated from Israel.
   These
misrepresentations would have been important to a reasonable investor’s investment
decisions
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56. Ivory Option’s website contained similar false and misleading
statements, concerning segregated accounts and the value of a one on one session
with a LianTech account representative, and it also contained additional false and
misleading statements.  For example, the website stated:

Learn about binary options and discover new possibilities when
you start trading with our best brokers. We will provide you the
tools and education so that you can succeed. You can have
access to all the investment plans we offer by taking a few
minutes to open your account, then you can use our platform to
make a profit.

This investment plan provides personal trading strategies based
on the funds available on the account. If you are interested in
learning about a specific asset on our website, we will provide
an individual training program based on the asset of your
choice. You will frequently receive e-mails with market updates
as well as personal sessions with your broker. You can receive
up to a 25% bonus based on your initial investment. You will

COMPLAINT 20

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receive trading signals through e-mail and Skype and constant
support from your broker and customer service representatives.

57. These statements are false and misleading because the LianTech call
center employees were either not experienced investment professionals or not as
experienced as they claimed to be, and they had little to no substantive experience
with the Ivory Option platform.  In addition, like the statements above on the LBinary
website, these statements are also false and misleading because the so-called
“brokers” were incentivized to cause investors to lose money trading binary options.
58. These misrepresentations would have been important to a reasonable
investors’ investment decisions
.
D.  The Defendants Controlled and Operated LianTech, LBinary, and
Ivory Option
59. Israeli corporate records show that the Defendants owned, controlled,
and operated LianTech, which operated the LianTech call center.  Former LianTech
call center employees confirmed that the Defendants owned, controlled, and
supervised the call center and that they had offices at the call center and were
regularly present. One former LianTech employee noted that Babazara occasionally
gave “Wolf of Wall Street like” speeches at the LianTech call center to motivate the
sales staff.
60. When new affiliate marketing campaigns were used to generate new
investor leads, desk supervisors at the LianTech call center told the sales staff to work

COMPLAINT 21

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hard in attracting investors because the Defendants had invested a lot of money to
obtain the leads.
61. Senderov’s internet domain registration account with GoDaddy (and its
affiliate Domains by Proxy) registered the internet domains for LBinary and Ivory
Option, giving Senderov the rights to and control over the websites www.lbinary.com
and www.ivoryoption.com.  Updates and maintenance to the LBinary and Ivory
Option websites took place from the LianTech call center, which Senderov and
Babazara owned.  Defendants exercised authority over the content and operations of
the trading platforms on the websites as demonstrated through their email
communications with SpotOption, which the Defendants typically sent through an
“admin” email address that the Defendants jointly operated.
E.   Defendants Fraud Harmed United States Investors
62. The Ivory Option and LBinary websites were available to investors in
the United States and thousands of United States investors made deposits to trade
binary options and purchased binary options through those sites.
63. For example, data from LBinary’s internal database shows that from
October 2014 through December 2014, LBinary accepted deposits from more than
1,800 United States residents totaling more than $3.155 million.  After December
2014, other investors in the United States deposited at least $680,000 into binary
option trading accounts with LBinary.

COMPLAINT 22

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64. For example, data from Ivory Option’s internal database shows that from
October 2014 through December 2014, Ivory Option accepted deposits from at least
980 United States investors totaling $1.62 million. After December 2014, other
United States investors deposited at least $266,500 into binary option trading
accounts with Ivory Option.
VIOLATIONS OF THE FEDERAL SECURITIES LAWS
FIRST CLAIM
Unregistered Offer or Sale of Securities in
Violation of Section 5 of the Securities Act
65. Paragraphs 1-64 are realleged and incorporated by reference herein.
66. No registration statement had been filed or was in effect for any of the
security-based binary options offered or sold through or by the LBinary and Ivory
Option websites, LianTech, and the Defendants.
67. Defendants, by engaging in the conduct described above, directly or
indirectly, made use of means or instruments of transportation or communication in
interstate commerce or of the mails to offer to sell or to sell such securities.
68. By reason of the foregoing, Defendants violated, and unless enjoined
will again violate, Section 5 of the Securities Act [15 U.S.C. §§ 77e].

COMPLAINT 23

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SECOND CLAIM
Control Person Liability Under Section 20(a) of the Exchange Act for Violations
of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder
69. Paragraphs 1-64 are realleged and incorporated by reference herein.
70. As alleged above, Defendants were controlling persons of LBinary, and
Ivory Option, and LianTech for the purposes of Section 20(a) of the Exchange Act
[15 U.S.C. § 78t(a)].
71. As alleged above, LBinary, Ivory Option, and LianTech directly or
indirectly, by use of the means or instruments of interstate commerce, or of the mails,
or the facility of a national securities exchange, in connection with the purchase or
sale of securities, and with knowledge or recklessness: (a) employed devices,
schemes, or artifices to defraud; (b) made untrue statements of material fact or
omitted to state material facts necessary to make the statements made, in light of the
circumstances under which they were made, not misleading; and/or (c) engaged in
acts, practices, or courses of business which operated or would operate as a fraud or
deceit upon any person.  Thus, LBinary, Ivory Option, and LianTech violated 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].
72. Accordingly, Defendants are liable as a controlling persons pursuant to
Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)] for the violations of 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] committed by LBinary, Ivory Option, and LianTech.

COMPLAINT 24

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THIRD CLAIM
Control Person Liability Under Section 20(a) of the Exchange Act for Violations
of Section 15(a) of the Exchange Act
73. Paragraphs 1-64 are realleged and incorporated by reference herein.
74. As alleged above, Defendants were controlling persons of LBinary, and
Ivory Option, and LianTech for the purposes of Section 20(a) of the Exchange Act
[15 U.S.C. § 78t(a)].
75. Through the conduct described above, LBinary, Ivory Option, and
LianTech:
(a) engaged in the business of effecting transactions in securities for the
account of others; and
(b) directly or indirectly, made use of the mails or the means or
instrumentalities of interstate commerce to effect transactions in, or to
induce or attempt to induce the purchase or sale of, securities without
being registered as a broker or dealer with the Commission or associated
with a broker or dealer registered with the Commission.
Thus, LBinary, Ivory Option, and LianTech violated Section 15(a) of the Exchange
Act [15 U.S.C. § 78j(b)].
76.  Accordingly, Defendants are liable as a controlling persons pursuant to
Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)] for the violations of Section
15(a) of the Exchange Act [15 U.S.C. § 78j(b)] committed by LBinary, Ivory Option,
and LianTech.

COMPLAINT 25

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RELIEF REQUESTED
WHEREFORE, the Commission respectfully requests that this Court:
a) Find that Defendants committed the alleged violations;
b) Order Defendants to disgorge, with prejudgment interest, all ill-gotten
gains they received or derived from the activities set forth in this Complaint, and to
repatriate any ill-gotten funds or assets they caused to be sent overseas;
c) Order Defendants to pay civil penalties under 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];
d) Permanently enjoin Defendants from directly or indirectly violating
Sections 5 of the Securities Act [15 U.S.C. §§ 77e] and Sections 10(b) and 15(a)
of the Exchange Act [15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §
240.10b-5];
e) Retain jurisdiction over this action in order to implement and carry out
the terms of all orders and decrees that it may enter, or to entertain any suitable
application or motion for additional relief within the jurisdiction of this Court; and
f) Grant such other relief as may be necessary or appropriate.

COMPLAINT 26

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Dated:  October 9, 2019 Respectfully submitted,

     /s/
Christian D. H. Schultz
Assistant Chief Litigation Counsel

David Nasse
Trial Counsel

Deborah Maisel
Senior Counsel

Jason Anthony
Senior Counsel

Division of Enforcement
SECURITIES AND EXCHANGE
COMMISSION
100 F. Street, N.E.
Washington, D.C. 20549

COMPLAINT 1  

 

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Christian D. H. Schultz               
Assistant Chief Litigation Counsel 
David A. Nasse 
Trial Counsel 
Division of Enforcement 
SECURITIES AND EXCHANGE COMMISSION 
100 F. Street N.E. 
Washington, D.C. 20549 
Telephone: (202) 551-4740 (Schultz) 
Email:  [email protected] 
 
Attorneys for Plaintiff 
Securities and Exchange Commission 

UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF WASHINGTON 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 

ANTON SENDEROV and LIOR 
BABAZARA a/k/a/ LIOR BAR,  
   

Defendants, 
 

 

 Case No. 19-cv-5242 
 
 
 
COMPLAINT 
 
JURY TRIAL REQUESTED 

 
 Plaintiff Securities and Exchange Commission (the “SEC”) alleges:  

SUMMARY OF THE ACTION 

1. This case concerns a fraudulent scheme in which investors in the United 

States deposited millions of dollars into online trading accounts in connection with 

the illegal offer and sale of high risk securities called “binary options” from at least 

January 2014 through August 2017 (the “Relevant Period”).  

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.1   Page 1 of 26



 

COMPLAINT 2  

 

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2. Anton Senderov and Lior Babazara a/k/a Lior Bar (collectively, the 

“Defendants”) controlled and operated two internet-based binary options brokers 

called LBinary/Live Binary at www.Lbinary.com (“LBinary”) and Ivory Option at 

www.ivoryoption.com (“Ivory Option”).  The LBinary and Ivory Option websites 

each contained a binary options trading platform where investors could open and fund 

trading accounts and trade binary options, including binary options referencing 

securities.   

3. The Defendants also owned, controlled, and operated LianTech Finance 

Marketing, Ltd a/k/a LianTech Ltd. (“LianTech”), which operated a call center in 

Israel and maintained and operated the LBinary and/or Ivory Option websites.  

Employees at the LianTech call center solicited investors in the United States to open 

and fund binary options trading accounts with the websites, and some of them 

purported to advise investors on binary option trading after they opened such 

accounts. 

4. LianTech used LBinary and Ivory Option to fraudulently make 

unregistered offers and sales of binary options that referenced well-known securities 

to investors in the United States.  The Defendants, operating from Israel, controlled 

these activities and thereby directly or indirectly offered and sold binary options to 

United States investors through these entities.      

5. The LBinary and Ivory Option websites, and employees at the LianTech 

call center, described the binary options offered through those websites as a profitable 

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COMPLAINT 3  

 

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investment even for retail investors with little to no experience in trading securities.  

In reality, the binary option offerings deceived many investors into depositing large 

sums of money into trading accounts at LBinary and Ivory Option, which were 

operated or controlled by the Defendants. Many investors then lost all or nearly all of 

their investment through unprofitable binary option trades and other deceptive or 

manipulative devices. 

6. To persuade retail investors in the United States to invest in the binary 

options offered on the LBinary and Ivory Option trading platforms, the LianTech call 

center employees and the websites made numerous false and misleading statements 

and engaged in deceptive business practices to defraud investors.  For example, the 

LBinary and Ivory Option websites and the call center employees claimed that 

investors could make large profits trading binary options while working with 

LianTech’s supposedly experienced investment professionals.  In fact, the LianTech 

call center employees were trained to lie about their backgrounds and investment 

experience.  Further, they failed to disclose that the interests of LianTech, LBinary, 

and Ivory Option were actually opposed to the interests of the investors because 

LianTech, LBinary, and Ivory Option made money only when investors made 

unprofitable “losing” binary option trades on the online trading platforms.  This is 

material information that reasonable investors would want to know before they 

deposited money with LBinary or Ivory Option and made binary option trading 

decisions with advice and assistance from LianTech.   

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COMPLAINT 4  

 

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7. LianTech, LBinary, and Ivory Option did not register with the SEC as a 

broker or dealer, were never associated with an SEC-registered broker or dealer, and 

never registered with the SEC any of their offers or sales of binary options made 

through the LBinary and Ivory Option websites.   

8. LianTech solicited thousands of investors in the United States who 

opened binary options trading accounts with LBinary or Ivory Option.  As a result of 

the fraudulent representations on the LBinary and Ivory Option websites, and the 

deceptive conduct of LianTech call center employees, Defendants procured millions 

of dollars in deposits from investors in the United States in connection with the offer 

and sale of binary options.  Many investors lost significant portions of their invested 

deposits.  

9. Defendants’ offers and sales of binary options through LianTech, 

LBinary, and Ivory Option violated the registration provisions of Sections 5(a) and 

5(c) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77e(a) and 

77e(c)].  Because Defendants controlled LianTech, LBinary, and Ivory Option, they 

also are liable as control persons under Section 20(a) of the Securities Exchange Act 

of 1934 (“Exchange Act”) [15 U.S.C. § 78t(a)] for those entities’ violations of the 

antifraud provisions of Section 10(b) of the Exchange Act [15 U.S.C. §§ 78j(b)], and 

Rule 10b-5(a) and (c) thereunder [17 C.F.R. § 240.10b‒5], as well as the broker 

registration provision of Section 15(a)(1) of the Exchange Act [15 U.S.C. § 

78o(a)(1)]. 

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.4   Page 4 of 26



 

COMPLAINT 5  

 

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10. The SEC seeks disgorgement of Defendants’ ill-gotten gains, 

prejudgment interest, civil monetary penalties, an injunction against further violations 

of the federal securities laws, and other appropriate relief.  Unless restrained and 

enjoined by this Court, Defendants are likely to continue to engage in the acts and 

practices alleged herein. 

JURISDICTION AND VENUE 

11. The SEC brings this action pursuant to Sections 20(b), 20(d)(1), and 

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

21(d)(1), 21(d)(3)(A), 21(e), and 27(a) of the Exchange Act [15 U.S.C. §§ 78u(d)(1), 

78u(d)(3)(A), 78u(e) & 78aa(a)].  Defendants, directly or indirectly, made use of the 

means or instrumentalities of interstate commerce, of the mails, or of the facilities of 

a national securities exchange in connection with the transactions, acts, practices and 

courses of business alleged in this Complaint, including by making use of the Internet 

to offer and sell securities and sending or receiving interstate and/or international 

emails or audio/video communications.  This Court has subject matter jurisdiction 

under Section 22 of the Securities Act [15 U.S.C. § 77v], Sections 21(d) and 27 of the 

Exchange Act [15 U.S.C. §§ 78u(d) and 78aa], and 28 U.S.C. § 1331. 

12. Venue is proper in this district under Section 22(a) of the Securities Act 

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

because certain of the transactions, acts, practices, and courses of conduct 

constituting violations of the federal securities laws occurred within this district, 

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COMPLAINT 6  

 

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including at least one investor who was defrauded out of approximately $500,000.  

Venue also is proper under 28 U.S.C. § 1391(c)(3), as each of the Defendants resides 

outside of the United States.    

DEFENDANTS 
 

13. Anton Senderov, age 34, is a citizen of Israel and is believed to reside 

in Israel.  Senderov, along with Lior Babazara, owned, controlled, and operated 

LianTech, which derives its name from the first two letters of the Defendants’ first 

names (i.e., LIor and ANton).  Senderov also controlled the LBinary and Ivory 

Options websites. 

14. Lior Babazara (also known as Lior Bar), age 37, is a citizen of Israel 

and is believed to reside in Israel.  Babazara, along with Senderov, owned, controlled, 

and operated LianTech, through which Senderov controlled the LBinary and Ivory 

Options websites.   

FACTS 

I. THE DEFENDANTS’ BINARY OPTIONS OFFERINGS 

15. A “binary option” is a financial instrument that expires at a 

predetermined time where the payout is contingent on the future value of an 

underlying asset, such as a security or securities index.  Binary options like those sold 

though the LBinary and Ivory Option online trading platforms are “binary” because 

they carry only two possible outcomes.  Upon expiration, its holder will receive a 

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COMPLAINT 7  

 

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predetermined amount of money, or nothing or nearly nothing, depending on whether 

the underlying asset increases or decreases in value.    

16. For example, if the current market price of a reference stock, “ABC, 

Inc.,” is $100 per share, an investor could use the LBinary or Ivory Option trading 

platform to trade a binary option on whether the price of that stock would be above or 

below $100 at a certain time in the future (e.g. ABC, Inc., stock will be above $100 at 

1 p.m.).  If, at the expiration of the binary option, the investor’s trade proved correct – 

i.e., the price of ABC, Inc., stock was above $100 at 1 p.m. – the investor might 

receive 175% of his original investment.  If the stock price at expiration of the binary 

option was less than $100, the investor would forfeit all or nearly all of his original 

investment.     

17. Binary options in which the underlying financial asset is a security or 

securities within the meaning of Section 2(a)(1) of the Exchange Act [15 U.S.C. § 

77b(a)(1)] and Section 3(a)(10) of the Exchange Act [15 U.S.C. § 78c(a)(10)] are 

themselves “securities” within the meaning of those provisions. 

18. During the Relevant Period and through LianTech, Defendants 

controlled two internet-based, binary options brokers called LBinary/Live Binary and 

Ivory Option using www.Lbinary.com and www.ivoryoption.com websites.  These 

online brokers offered and sold security-based binary options over the internet to 

investors in the United States and around the world.   

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COMPLAINT 8  

 

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19. Through the trading platforms on the LBinary and Ivory Option 

websites, LianTech call center employees offered and sold to investors binary options 

with payouts that were contingent on the value of common stocks, including Google, 

Nike, Coca Cola, Citi Group, Apple, IBM, Microsoft, and numerous other domestic 

and international companies.  The referenced securities also included numerous 

domestic and international securities indices, including the Nasdaq Composite and 

Dow Jones Industrial Average.  

20. The LBinary and Ivory Option websites included statements that 

described themselves as binary options trading brokers and characterized the 

purchase of binary options through their trading platforms as trading and investing. 

21. The Defendants owned, controlled, and operated LianTech Finance 

Marketing, Ltd, a/k/a LianTech, Ltd., which operated a call center in Israel.  

Employees at the LianTech call center solicited investors in the United States to open 

and fund binary options trading accounts with LBinary or Ivory Option. In some 

cases, LianTech employees represented themselves to investors as financial advisors 

who recommended particular binary option trades and  executed trades on investors’ 

behalf. 

II. DEFENDANTS’ BINARY OPTION SCHEME 

22. The LBinary and Ivory Option websites were made to appear like 

legitimate online broker’ websites and advertised binary options as profitable and 

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COMPLAINT 9  

 

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simple investments, even for retail investors with little to no experience in trading 

securities.    

23. Entities controlled by the Defendants were the counterparty on every 

single binary option trade that investors made through the online trading platforms, or 

that call center employees made through those platforms on behalf of the investors 

whose accounts they handled.   

24. LianTech and entities controlled by Defendants did not charge Investors 

any fees to trade binary options through the online trading platforms.  Rather, because 

they sat on the opposite side of the investors on every trade, the entities controlled by 

the Defendants retained the amounts investors placed on losing trades as revenue and 

profits.  This fact was not explained to investors by LianTech call center employees 

or otherwise clearly disclosed to investors.   

25.  Accordingly, the interests of the Defendants, LianTech, and entities they 

controlled were in direct conflict with the interests of their investors.  The investors 

sought to profitably trade binary options, while Defendants, LianTech, and entities 

they controlled depended on investors losing trades for revenue so that they could 

fund their operations and earn a profit.    

26. Consistent with this conflict of interest, the LianTech business model 

and compensation structure incentivized call center employees to deceive investors 

into depositing significant sums of money into trading accounts, and, through a 

variety of deceptive acts, to cause those investors to lose their deposits.         

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COMPLAINT 10  

 

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A. Finding Investor Victims  

27. The LianTech call center employees identified potential victims for their 

scam through contracts with third-party affiliate marketers.  These affiliate marketers 

identified potential investors, and made an initial solicitation to them, by creating 

false and misleading online advertising materials, including elaborate infomercial-

like videos, and by sending thousands of fraudulent spam emails to potential 

investors.  These materials were designed to persuade prospective investors to visit 

the LBinary and Ivory Option websites and open a binary option trading account with 

a small minimum deposit, typically around $250.  For every investor that did so, after 

viewing an affiliate’s marketing materials, LianTech paid that affiliate marketer a 

commission.   

28. After a prospective investor opened and funded a trading account 

through the LBinary or Ivory Option websites, or otherwise registered or expressed 

an interest with one of the websites, an employee from the LianTech call center 

contacted them to encourage them to make large deposits and start trading binary 

options.  

B. Fraudulent Call Center Operations   

29. The LianTech call center operated like a boiler room where sales persons 

used deceptive, high-pressure tactics to offer and sell binary options that LBinary and 

Ivory Option offered through their trading platforms.  Call center employees were 

trained to build rapport with investors, convince investors to deposit as much money 

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COMPLAINT 11  

 

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as possible into their trading accounts, and induce investors to trade binary options, 

resulting in those investors typically losing all or nearly all of the funds they had 

deposited.      

30. Sales employees at the LianTech call center were expected to make a 

minimum of 300 telephone calls each day and obtain a minimum of 8 deposits a 

week.  From 2014 to 2017, the LianTech call center employed, over time, more than 

one hundred people. 

31. LianTech call center sales employees were paid a base salary and a 

commission.  Each employee’s commission was calculated, not as a percentage of the 

investors’ profits or trading activity, but rather as a percentage of the deposits made 

by investors whose accounts that employee handled.  As a result, LianTech call 

center sales employees were incentivized to fraudulently induce investors to deposit 

significant funds to trade binary options, and to deter investors from withdrawing 

those funds.  

32. Investors typically deposited money with LBinary or Ivory Option by 

credit card or bank wire at the direction of LianTech call center employees.  These 

payments went to accounts held by third-party entities, which may have been directly 

or indirectly owned or controlled by the Defendants or otherwise tied to LianTech’s 

operations, and investor deposits were then transferred to LianTech and other 

individuals and entities. 

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.11   Page 11 of 26



 

COMPLAINT 12  

 

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33. LianTech call center sales employees were trained to make false 

statements to investors concerning their professional background, experience and 

location to gain investors’ trust and mislead them into believing that they had 

significant experience as investment professionals and the necessary qualifications to 

advise investors on how to trade binary options profitably.  

34. LianTech call center sales employees were trained to create fake 

biographies and use aliases instead of their real names.  They were trained to claim to 

be older than they actually were, to have numerous years of experience working in 

financial markets and trading securities, to have earned significant sums trading 

binary options, and to be located in Europe rather than Israel.  

35. In reality, call center employees were located in the LianTech call center 

in Israel, were typically younger than they claimed, had significantly less experience 

working in the financial sector or advising investors on trading securities than they 

claimed to investors, and had not earned large sums trading binary options.  The 

LianTech call center sales employees also fabricated professional sounding titles 

normally associated with legitimate trading and the provision of financial advice, 

such as “Financial Advisor,” “Head of Managed Accounts,” and “Chief Trading 

Officer.” 

36. LianTech training materials instructed call center sales employees on 

how to conduct their first solicitation call with potential investors.  These materials 

also instructed employees to describe their fake personas and inform investors about 

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COMPLAINT 13  

 

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potential profits they could earn.  Tellingly, these materials did not instruct the 

employees to inform investors that the entities controlled by the Defendants were the 

counterparties on every investor trade and that they earned money whenever investors 

lost money on those trades.     

37. Reasonable investors would have considered it important to their 

investment decisions to know that the interests of LBinary, Ivory Option, and 

LianTech were not aligned with their own, and that call center employees were 

fabricating their financial experience as well as their experience advising other 

investors on how to profitably trade securities. 

38. Once investors made initial deposits, LianTech call center sales 

employees transferred investors to other sales employees in what was referred to as 

the “retention department.”  Sales employees in the retention department made 

additional false and misleading statements for the purpose of persuading investors to 

deposit as much money as possible into their trading accounts. 

39. Alignment of Interest.  Retention department employees informed 

investors that the entities controlled by the Defendants earned money by taking a 

percentage of the profits that investors earned from winning binary option trades.  In 

addition, promotional materials provided to certain investors stated that commissions 

would be taken as percentage of “monthly profit.”  In reality,  LianTech, LBinary, 

and Ivory Option earned money only when investors had losing binary option trades.   

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.13   Page 13 of 26



 

COMPLAINT 14  

 

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40. Promises of profitable trades.  Retention department employees made it 

a business practice to promise investors that trading in binary options would be 

highly profitable.  For example, in a Skype Chat with one investor, a LianTech call 

center employee wrote, “We will watch your money double in the next 30 days with 

no further investments[.]”  Another investor was told if he deposited $30,000 to 

$40,000, he could expect to withdraw profits of $3,000 to $4,000 per month.  Still 

another investor was told that the goal was for his investments to earn 7 percent a 

month.  This practice was misleading and deceptive because the retention department 

employees knew (or recklessly failed to know) that many if not most investors were 

extremely unlikely to make any money trading binary options.   

41. Elevation to “VIP” Status.  The retention department employees 

routinely told investors that if they increased their total deposits to a particular 

level—usually in the five- and six- figure range—they would achieve “VIP,” “gold,” 

“platinum,” or some similarly-named elevated status that provided access to more 

experienced brokers, larger payouts, and access to special VIP-only trading 

opportunities.  In fact, these elevated status benefits were largely illusory and these 

pitches were nothing more than lures to induce investors to deposit additional funds.   

42. Insured Trades.  For investors with LBinary and Ivory Option who 

deposited sufficient funds to meet the requirements to enter into a VIP group, 

retention department employees offered purported “insured trades.”  VIP marketing 

materials regarding the VIP program that were sent to investors, claim to provide 

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.14   Page 14 of 26



 

COMPLAINT 15  

 

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“insured trading events” where all trades were “100% insured” to “give a ‘sure 

profit.’”  In reality, there was no “insurance” on any investors’ trades.     

43. Withdrawals.  LianTech call center employees told investors they could 

withdraw funds whenever they wanted with no restrictions.  When investors 

submitted withdrawal requests to either LBinary or Ivory Option, however, these 

requests were typically ignored, not processed, or denied due to withdrawal 

restrictions in certain purported terms and conditions.   

44. In some cases, investors were told that the withdrawals were processed 

and they should await payment to their accounts, only for days and weeks to pass 

without the withdrawal appearing in the customers’ bank or credit card accounts. 

45. In other instances, after investors had stopped making additional 

deposits and had submitted withdrawal requests, retention department employees 

made unauthorized binary option trades in the investors’ accounts.  In one such case, 

an employee lost more than $400,000 in an investor’s account in a matter of days. In 

another instance, a LianTech employee traded away nearly $107,000 in an investor’s 

account. 

46. After investors submitted withdrawal requests, the retention department 

employees who had served as their account representatives often ceased all 

communications with them and “disappeared.”  Investors who were able to reach 

someone at the LianTech call center were often told that their account representatives 

were sick, on vacation, in meetings, or otherwise busy with other investors.   

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.15   Page 15 of 26



 

COMPLAINT 16  

 

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47. Reasonable investors would have considered it important to their 

investment decisions to know that that the LianTech call center employees’ in the 

retention department were falsely representing (1) the alleged alignment of interests; 

(2) the likelihood of profitable trades; (3) the alleged benefits under the “VIP 

Program”; (4) that the trades were insured; and (5) that investors could easily 

withdraw their funds. 

C. Deceptive Websites 

48. Ivory Option and LBinary licensed the technology and infrastructure 

necessary to run their binary options websites from SpotOption, Ltd., a binary options 

platform provider that has helped numerous entities defraud investors with binary 

options trading scams.  Under these license agreements, SpotOption provided Ivory 

Option and LBinary with Internet software infrastructure, a website interface, a 

binary option trading platform, and customer relationship management software 

(“CRM”).  Defendants and LianTech simply put the Ivory Option and LBinary 

“branding” on the SpotOption trading platform and embedded it on their websites.   

49. The trading platform embedded on the Ivory Option and LBinary 

websites created the appearance of actual market-oriented options trading that looked 

similar to what an investor might see on a legitimate broker’s website.  The trading 

platform allowed investors to place “trades,” see “live” market quotations, make 

deposits, and track their trades and balances.  The trading platform referred to binary 

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.16   Page 16 of 26



 

COMPLAINT 17  

 

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options positions as “investments” or “trades” and showed the assets the positions 

referenced, including the names of relevant securities. 

50. Similar to the way a legitimate broker would operate, LBinary’s and 

Ivory Option’s websites and other promotional materials stated, respectively, in 2015 

and 2016 that, “Investors’ funds are held in a segregated account.  These funds are 

used only for trading options on our website.”  These statements were false and 

misleading because investor deposits were actually placed in aggregated accounts 

from which expenses associated with running the business were regularly paid, 

including salary payments to call center employees, commissions to affiliate 

marketers, and purported “licensing” payments to SpotOption, Ltd.   

51. Reasonable investors would have considered it important to their 

investment decisions to know that their funds were not segregated as represented on 

the LBinary and Ivory Option websites and were instead being used to pay the 

expenses of LianTech, LBinary, Ivory Option and other entities controlled and/or 

operated by the Defendants. 

52. The LBinary and Ivory Option websites contained additional false 

and misleading statements.  For example, LBinary’s website stated in 2015 that, 

“Trading is conducted only upon the client’s instructions, and are not to be used for 

any other cause. Our liabilities and exposures are professionally handled and we 

guarantee pay-outs of your profits based on our terms.”  These statements were false 

and misleading because at times LianTech call center employees placed trades 

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.17   Page 17 of 26



 

COMPLAINT 18  

 

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directly in investor accounts without the investor’s knowledge or consent and 

LianTech frequently did not honor investors’ legitimate withdrawal requests.  

53. Reasonable investors would have considered it important to their 

investment decisions to know that the entities controlled by the Defendants would 

engage in unauthorized trading and refuse their legitimate withdrawal requests. 

54. In addition, LBinary’s website contained the following additional 

statements in 2015: 

“Our account managers are experienced professionals that 
provide guided material, one-on-one coaching, and scheduled 
webinars.”   
 
“The coalition of a user–friendly and flexible platform along 
with guided expertise allows our investors to maximize earnings 
with minimal effort from the comfort of their own home.” 
   
“LBinary’s brokers are the best in the business. The company 
hires experienced brokers, which have led the company to 
become the leading brokerage in Europe. The reason that our 
company and our investors have had so much success is because 
of the level of expertise our brokers possess and project onto our 
traders. Each of our brokers bring with them their own skill set 
that they have developed and modeled over years of experience 
trading in financial markets.” 
 
“A One-on-One session can be helpful for all types of Binary 
Option traders, no matter how experienced you may be. For 
those who have no background in the business, a One-on-One 
session is a great opportunity to consult with a professional 
while going through the full process of making a Binary Option 
trade.” 
 

55. These statements were false and misleading because the employees at 

the LianTech call center were trained to use fake names, titles, and credentials and 

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COMPLAINT 19  

 

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were either not experienced professionals capable of providing expert guidance to 

investors to help them make profitable binary options trades, or were not nearly as 

experienced as they claimed to be.  These statements are also false and misleading 

because the so-called “brokers” had no incentive to help investors “succeed.”  Rather, 

these employees were incentivized to obtain the largest possible deposit from 

investors and to deter withdrawals.  Moreover, LBinary was not a leading brokerage 

in Europe, but rather a boiler room call center operated from Israel.   These 

misrepresentations would have been important to a reasonable investor’s investment 

decisions. 

56. Ivory Option’s website contained similar false and misleading 

statements, concerning segregated accounts and the value of a one on one session 

with a LianTech account representative, and it also contained additional false and 

misleading statements.  For example, the website stated:   

Learn about binary options and discover new possibilities when 
you start trading with our best brokers. We will provide you the 
tools and education so that you can succeed. You can have 
access to all the investment plans we offer by taking a few 
minutes to open your account, then you can use our platform to 
make a profit. 
 
This investment plan provides personal trading strategies based 
on the funds available on the account. If you are interested in 
learning about a specific asset on our website, we will provide 
an individual training program based on the asset of your 
choice. You will frequently receive e-mails with market updates 
as well as personal sessions with your broker. You can receive 
up to a 25% bonus based on your initial investment. You will 

Case 4:19-cv-05242    ECF No. 1    filed 10/09/19    PageID.19   Page 19 of 26



 

COMPLAINT 20  

 

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receive trading signals through e-mail and Skype and constant 
support from your broker and customer service representatives. 

 
57. These statements are false and misleading because the LianTech call 

center employees were either not experienced investment professionals or not as 

experienced as they claimed to be, and they had little to no substantive experience 

with the Ivory Option platform.  In addition, like the statements above on the LBinary 

website, these statements are also false and misleading because the so-called 

“brokers” were incentivized to cause investors to lose money trading binary options. 

58. These misrepresentations would have been important to a reasonable 

investors’ investment decisions. 

D. The Defendants Controlled and Operated LianTech, LBinary, and 
Ivory Option  

59. Israeli corporate records show that the Defendants owned, controlled, 

and operated LianTech, which operated the LianTech call center.  Former LianTech 

call center employees confirmed that the Defendants owned, controlled, and 

supervised the call center and that they had offices at the call center and were 

regularly present. One former LianTech employee noted that Babazara occasionally 

gave “Wolf of Wall Street like” speeches at the LianTech call center to motivate the 

sales staff.   

60. When new affiliate marketing campaigns were used to generate new 

investor leads, desk supervisors at the LianTech call center told the sales staff to work 

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hard in attracting investors because the Defendants had invested a lot of money to 

obtain the leads.  

61. Senderov’s internet domain registration account with GoDaddy (and its 

affiliate Domains by Proxy) registered the internet domains for LBinary and Ivory 

Option, giving Senderov the rights to and control over the websites www.lbinary.com 

and www.ivoryoption.com.  Updates and maintenance to the LBinary and Ivory 

Option websites took place from the LianTech call center, which Senderov and 

Babazara owned.  Defendants exercised authority over the content and operations of 

the trading platforms on the websites as demonstrated through their email 

communications with SpotOption, which the Defendants typically sent through an 

“admin” email address that the Defendants jointly operated.  

E. Defendants Fraud Harmed United States Investors 

62. The Ivory Option and LBinary websites were available to investors in 

the United States and thousands of United States investors made deposits to trade 

binary options and purchased binary options through those sites.   

63. For example, data from LBinary’s internal database shows that from 

October 2014 through December 2014, LBinary accepted deposits from more than 

1,800 United States residents totaling more than $3.155 million.  After December 

2014, other investors in the United States deposited at least $680,000 into binary 

option trading accounts with LBinary. 

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COMPLAINT 22  

 

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64. For example, data from Ivory Option’s internal database shows that from 

October 2014 through December 2014, Ivory Option accepted deposits from at least 

980 United States investors totaling $1.62 million. After December 2014, other 

United States investors deposited at least $266,500 into binary option trading 

accounts with Ivory Option.    

VIOLATIONS OF THE FEDERAL SECURITIES LAWS 

FIRST CLAIM 

Unregistered Offer or Sale of Securities in 
Violation of Section 5 of the Securities Act 

65. Paragraphs 1-64 are realleged and incorporated by reference herein. 

66. No registration statement had been filed or was in effect for any of the 

security-based binary options offered or sold through or by the LBinary and Ivory 

Option websites, LianTech, and the Defendants. 

67. Defendants, by engaging in the conduct described above, directly or 

indirectly, made use of means or instruments of transportation or communication in 

interstate commerce or of the mails to offer to sell or to sell such securities. 

68. By reason of the foregoing, Defendants violated, and unless enjoined 

will again violate, Section 5 of the Securities Act [15 U.S.C. §§ 77e]. 

 

 

 

 

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COMPLAINT 23  

 

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SECOND CLAIM 

Control Person Liability Under Section 20(a) of the Exchange Act for Violations 
of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder 

69. Paragraphs 1-64 are realleged and incorporated by reference herein. 

70. As alleged above, Defendants were controlling persons of LBinary, and 

Ivory Option, and LianTech for the purposes of Section 20(a) of the Exchange Act 

[15 U.S.C. § 78t(a)]. 

71. As alleged above, LBinary, Ivory Option, and LianTech directly or 

indirectly, by use of the means or instruments of interstate commerce, or of the mails, 

or the facility of a national securities exchange, in connection with the purchase or 

sale of securities, and with knowledge or recklessness: (a) employed devices, 

schemes, or artifices to defraud; (b) made untrue statements of material fact or 

omitted to state material facts necessary to make the statements made, in light of the 

circumstances under which they were made, not misleading; and/or (c) engaged in 

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

deceit upon any person.  Thus, LBinary, Ivory Option, and LianTech violated 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]. 

72. Accordingly, Defendants are liable as a controlling persons pursuant to 

Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)] for the violations of 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] committed by LBinary, Ivory Option, and LianTech. 

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COMPLAINT 24  

 

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THIRD CLAIM 

Control Person Liability Under Section 20(a) of the Exchange Act for Violations 
of Section 15(a) of the Exchange Act 

73. Paragraphs 1-64 are realleged and incorporated by reference herein. 

74. As alleged above, Defendants were controlling persons of LBinary, and 

Ivory Option, and LianTech for the purposes of Section 20(a) of the Exchange Act 

[15 U.S.C. § 78t(a)]. 

75. Through the conduct described above, LBinary, Ivory Option, and 

LianTech: 

(a) engaged in the business of effecting transactions in securities for the 

account of others; and  

(b) directly or indirectly, made use of the mails or the means or 

instrumentalities of interstate commerce to effect transactions in, or to 

induce or attempt to induce the purchase or sale of, securities without 

being registered as a broker or dealer with the Commission or associated 

with a broker or dealer registered with the Commission.  

Thus, LBinary, Ivory Option, and LianTech violated Section 15(a) of the Exchange 

Act [15 U.S.C. § 78j(b)]. 

76.  Accordingly, Defendants are liable as a controlling persons pursuant to 

Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)] for the violations of Section 

15(a) of the Exchange Act [15 U.S.C. § 78j(b)] committed by LBinary, Ivory Option, 

and LianTech. 

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COMPLAINT 25  

 

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RELIEF REQUESTED 

WHEREFORE, the Commission respectfully requests that this Court: 

a) Find that Defendants committed the alleged violations; 

b) Order Defendants to disgorge, with prejudgment interest, all ill-gotten 

gains they received or derived from the activities set forth in this Complaint, and to 

repatriate any ill-gotten funds or assets they caused to be sent overseas; 

c) Order Defendants to pay civil penalties under 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]; 

d) Permanently enjoin Defendants from directly or indirectly violating 

Sections 5 of the Securities Act [15 U.S.C. §§ 77e] and Sections 10(b) and 15(a) 

of the Exchange Act [15 U.S.C. §§ 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 

240.10b-5]; 

e) Retain jurisdiction over this action in order to implement and carry out 

the terms of all orders and decrees that it may enter, or to entertain any suitable 

application or motion for additional relief within the jurisdiction of this Court; and 

f) Grant such other relief as may be necessary or appropriate. 

 

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COMPLAINT 26  

 

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Dated:  October 9, 2019 Respectfully submitted,  
 

  
     /s/ 
Christian D. H. Schultz               
Assistant Chief Litigation Counsel 
 

David Nasse 
Trial Counsel 
 

Deborah Maisel 
Senior Counsel 
 

Jason Anthony 
Senior Counsel 
 

Division of Enforcement 
SECURITIES AND EXCHANGE 
COMMISSION 
100 F. Street, N.E. 
Washington, D.C. 20549 

 

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