SEC v. Safeguard Metals LLC; and Jeffrey Ikahn, No. 2:22-cv-00693, Central District of California (May 9, 2025) — Judgment

FINAL JUDGMENT AS TO DEFENDANT
SAFEGUARD METALS LLC

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UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

SECURITIES AND EXCHANGE
COMMISSION,
Plaintiff,

vs.
SAFEGUARD METALS LLC AND
JEFFREY IKAHN (f/k/a/ JEFFREY S.
SANTULAN),

Defendants.

    Case No. 2:22-CV-00693 JFW (SKx)
Hon. John F. Walter, Crtrm 7A

FINAL JUDGMENT AS TO
DEFENDANT SAFEGUARD
METALS LLC

Complaint Filed:    Feb. 1, 2022

The Securities and Exchange Commission having filed a Complaint and Defendant
Safeguard Metals LLC (“Defendant”) having entered a general appearance; consented to the
Court’s jurisdiction over Defendant and the subject matter of this action; consented to entry of this
Final Judgment without admitting or denying the allegations of the Complaint (except as to
jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from
this Final Judgment:
I.
 IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is permanently
restrained and enjoined from violating, directly or indirectly, Section 10(b) of the Securities

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FINAL JUDGMENT AS TO DEFENDANT
SAFEGUARD METALS LLC

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Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated
thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of interstate commerce,
or of the mails, or of any facility of any national securities exchange, in connection with the
purchase or sale of any security:
(a) to employ any device, scheme, or artifice to defraud;
(b) to make any untrue statement of a material fact or to omit to state a material fact
 necessary in order to make the statements made, in the light of the circumstances
 under which they were made, not misleading; or
(c) to engage in any act, practice, or course of business which operates or would
 operate as a fraud or deceit upon any person.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal
Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive
actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s officers,
agents, servants, employees, and attorneys; and (b) other persons in active concert or participation
with Defendant or with anyone described in (a).
II.
  IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is permanently
restrained and enjoined from violating, directly or indirectly, Section 206(1) and Section 206(2) of
the Advisers Act [15 U.S.C. §§ 80b-6(1) and 80b-6(2)] (“Advisers Act”), by making use of the
mails or any means or instrumentality of interstate commerce, in connection with the conduct of
business as an investment adviser, directly or indirectly:
(i) to employ any device, scheme or artifice to defraud any investment advisory clients or
prospective clients; or
(ii) to engage in any transaction, practice or course of business which operates as a fraud or
deceit upon any such investment advisory clients or prospective clients.
 IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal
Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive
actual notice of this Final Judgment by personal service or otherwise:  (a) Defendant’s officers,

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FINAL JUDGMENT AS TO DEFENDANT
SAFEGUARD METALS LLC

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agents, servants, employees, and attorneys; and (b) other persons in active concert or participation
with Defendant or with anyone described in (a).
III.
  IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is liable,
jointly and severally with Defendant Jeffrey Ikahn, for disgorgement of $25,569,303, representing
net profits gained as a result of the conduct alleged in the Complaint, to be offset against any
amounts paid in restitution to the Commodity Futures Trading Commission (“CFTC”) in its parallel
action, CFTC, et al. v. Safeguard Metals LLC and Jeffrey Santulan, 2:22-cv-00691-JFW (SKx),
together with prejudgment interest thereon in the amount of $4,821,263. The Court finds that
sending the disgorged funds to the United States Treasury, as ordered below, is consistent with
equitable principles. The Court further imposes, jointly and severally with Defendant Jeffrey Ikahn,
a civil penalty in the amount of $25,569,303, pursuant to Section 21(d)(3) of the Exchange Act [15
U.S.C. § 78u(d)(3)], and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)], to be offset
against any amounts paid as a penalty to the CFTC in its parallel action. Defendant shall satisfy
these obligations by paying $55,959,869 to the Securities and Exchange Commission within 30
days after entry of this Final Judgment.
   Defendant may transmit payment electronically to the Commission, which will provide
detailed ACH transfer/Fedwire instructions upon request.   Payment may also be made directly from
a bank account via Pay.gov through the SEC website at http://www.sec.gov/about/offices/ofm.htm.
Defendant may also pay by certified check, bank cashier’s check, or United States postal money
order payable to the Securities and Exchange Commission, which shall be delivered or mailed to
Enterprise Services Center
Accounts Receivable Branch
6500 South MacArthur Boulevard
Oklahoma City, OK 73169
and shall be accompanied by a letter identifying the case title, civil action number, and name of this
Court; Safeguard Metals LLC as a defendant in this action; and specifying that payment is made
pursuant to this Final Judgment.

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FINAL JUDGMENT AS TO DEFENDANT
SAFEGUARD METALS LLC
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Defendant shall simultaneously transmit photocopies of evidence of payment and case
identifying information to the Commission’s counsel in this action.  By making this payment,
Defendant relinquishes all legal and equitable right, title, and interest in such funds and no part of
the funds shall be returned to Defendant.  The Commission shall send the funds paid pursuant to
this Final Judgment to the United States Treasury.
The Commission may enforce the Court’s judgment for disgorgement and prejudgment
interest by using all collection procedures authorized by law, including, but not limited to, moving
for civil contempt at any time after 30 days following entry of this Final Judgment.  The
Commission may enforce the Court’s judgment for penalties by the use of all collection procedures
authorized by law, including the Federal Debt Collection Procedures Act, 28 U.S.C. § 3001 et seq.,
and moving for civil contempt for the violation of any Court orders issued in this action.
Defendant shall pay post judgment interest on any amounts due after 30 days of the entry of this
Final Judgment pursuant to 28 U.S.C. § 1961.
IV.
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that this Court shall retain
jurisdiction of this matter for the purposes of enforcing the terms of this Final Judgment.
Dated:  May 2, 2025
____________________________________
John F. Walter
UNITED STATES DISTR    T JUDGE
_________________________________________
JoJoJoJoJJoJoJJJoJJJJJJJJJJJJJJJJJJJJJJJhn F. Walter
UNUUUUUUUUITED STATES DISTRICT JUDG

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FINAL JUDGMENT AS TO DEFENDANT  
SAFEGUARD METALS LLC   

 

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UNITED STATES DISTRICT COURT 
 

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 
 

SECURITIES AND EXCHANGE 
COMMISSION, 

Plaintiff, 
 

vs. 
SAFEGUARD METALS LLC AND 
JEFFREY IKAHN (f/k/a/ JEFFREY S. 
SANTULAN), 
 

Defendants. 
 

 Case No. 2:22-CV-00693 JFW (SKx) 
Hon. John F. Walter, Crtrm 7A 
 
FINAL JUDGMENT AS TO 
DEFENDANT SAFEGUARD  
METALS LLC 
 
Complaint Filed:    Feb. 1, 2022 
 

 
The Securities and Exchange Commission having filed a Complaint and Defendant 

Safeguard Metals LLC (“Defendant”) having entered a general appearance; consented to the 

Court’s jurisdiction over Defendant and the subject matter of this action; consented to entry of this 

Final Judgment without admitting or denying the allegations of the Complaint (except as to 

jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from 

this Final Judgment: 

I. 

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

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

Case 2:22-cv-00693-JFW-SK     Document 70     Filed 05/02/25     Page 1 of 4   Page ID
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FINAL JUDGMENT AS TO DEFENDANT  
SAFEGUARD METALS LLC 
 

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

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

or of the mails, or of any facility of any national securities exchange, in connection with the 

purchase or sale of any security: 

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

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

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

 under which they were made, not misleading; or 

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

 operate as a fraud or deceit upon any person. 

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

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

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

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

with Defendant or with anyone described in (a). 

II. 

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

restrained and enjoined from violating, directly or indirectly, Section 206(1) and Section 206(2) of 

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

mails or any means or instrumentality of interstate commerce, in connection with the conduct of 

business as an investment adviser, directly or indirectly:   

(i) to employ any device, scheme or artifice to defraud any investment advisory clients or 

prospective clients; or  

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

deceit upon any such investment advisory clients or prospective clients. 

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

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

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

Case 2:22-cv-00693-JFW-SK     Document 70     Filed 05/02/25     Page 2 of 4   Page ID
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FINAL JUDGMENT AS TO DEFENDANT  
SAFEGUARD METALS LLC 
 

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

with Defendant or with anyone described in (a). 

III. 

  IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is liable, 

jointly and severally with Defendant Jeffrey Ikahn, for disgorgement of $25,569,303, representing 

net profits gained as a result of the conduct alleged in the Complaint, to be offset against any 

amounts paid in restitution to the Commodity Futures Trading Commission (“CFTC”) in its parallel 

action, CFTC, et al. v. Safeguard Metals LLC and Jeffrey Santulan, 2:22-cv-00691-JFW (SKx), 

together with prejudgment interest thereon in the amount of $4,821,263. The Court finds that 

sending the disgorged funds to the United States Treasury, as ordered below, is consistent with 

equitable principles. The Court further imposes, jointly and severally with Defendant Jeffrey Ikahn, 

a civil penalty in the amount of $25,569,303, pursuant to Section 21(d)(3) of the Exchange Act [15 

U.S.C. § 78u(d)(3)], and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)], to be offset 

against any amounts paid as a penalty to the CFTC in its parallel action. Defendant shall satisfy 

these obligations by paying $55,959,869 to the Securities and Exchange Commission within 30 

days after entry of this Final Judgment. 

   Defendant may transmit payment electronically to the Commission, which will provide 

detailed ACH transfer/Fedwire instructions upon request.   Payment may also be made directly from 

a bank account via Pay.gov through the SEC website at http://www.sec.gov/about/offices/ofm.htm.  

Defendant may also pay by certified check, bank cashier’s check, or United States postal money 

order payable to the Securities and Exchange Commission, which shall be delivered or mailed to  

Enterprise Services Center 

Accounts Receivable Branch 

6500 South MacArthur Boulevard 

Oklahoma City, OK 73169 

and shall be accompanied by a letter identifying the case title, civil action number, and name of this 

Court; Safeguard Metals LLC as a defendant in this action; and specifying that payment is made 

pursuant to this Final Judgment.   

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FINAL JUDGMENT AS TO DEFENDANT 
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Defendant shall simultaneously transmit photocopies of evidence of payment and case 

identifying information to the Commission’s counsel in this action.  By making this payment, 

Defendant relinquishes all legal and equitable right, title, and interest in such funds and no part of 

the funds shall be returned to Defendant.  The Commission shall send the funds paid pursuant to 

this Final Judgment to the United States Treasury.  

The Commission may enforce the Court’s judgment for disgorgement and prejudgment 

interest by using all collection procedures authorized by law, including, but not limited to, moving 

for civil contempt at any time after 30 days following entry of this Final Judgment.  The 

Commission may enforce the Court’s judgment for penalties by the use of all collection procedures 

authorized by law, including the Federal Debt Collection Procedures Act, 28 U.S.C. § 3001 et seq., 

and moving for civil contempt for the violation of any Court orders issued in this action. 

Defendant shall pay post judgment interest on any amounts due after 30 days of the entry of this 

Final Judgment pursuant to 28 U.S.C. § 1961.  

IV.

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

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

Dated:  May 2, 2025
____________________________________
John F. Walter
UNITED STATES DISTR T JUDGE

_________________________________________
JoJoJoJoJJoJoJJJoJJJJJJJJJJJJJJJJJJJJJJJ hn F. Walter
UNUUUUUUUU ITED STATES DISTRICT JUDG

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