SEC v. JONATHAN WEBB, No. 1:25-cv-10604, District of Massachusetts (Mar. 14, 2025) — Complaint

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SECURITIES AND EXCHANGE COMMISSION,

  Plaintiff,

 v.

JONATHAN WEBB,

  Defendant,

     Civil Action No.

COMPLAINT

 Plaintiff, United States Securities and Exchange Commission (“SEC” or “Commission”)
alleges as follows against Defendant Jonathan Webb (“Defendant” or “Webb”).
SUMMARY
1. Massachusetts resident Jonathan Webb conducted a securities offering fraud that
included Ponzi-like payments to some investors and use of investor money for personal
purposes.  From at least January 2021 to August 2023, Webb solicited and accepted
approximately $1.7 million dollars from at least 34 people for “investment purposes.”  Many of
the investors lacked financial and/or investment experience.  Many also worked for Webb at a
Massachusetts cemetery.  Several investors did not speak English and many were low-income
workers who could not afford to invest and risk losing the money they entrusted to Webb.
2. Webb falsely told investors he could double their money within a year by pooling
it and investing in the foreign currency exchange market (Forex), and guaranteed the return of
the capital and any interest earned.  For prospective investors who did not have tens of thousands
of dollars to invest, Webb helped them to secure personal loans that enabled them to invest with

2
him.  He even promised to make the monthly loan payments on their behalf.  Webb then
converted investor funds to crypto assets and transferred the converted funds to overseas
brokerage firms.  That permitted Webb to invest in the Forex market using up to 500:1 leverage
and an algorithmic trading program Webb had purchased on the internet.
3. Webb lost hundreds of thousands of dollars in investor funds using the trading
program.  Despite these losses, he continued to solicit and accept investor funds, falsely
guaranteeing the return of capital and promising exorbitant potential returns.
4. Webb lost most of the investor funds investing in Forex.  In addition, despite
promising to use the investor funds for investment purposes, used some investor funds to pay
back some earlier investors.  He also misappropriated investor funds for personal expenses.
VIOLATIONS
5. By virtue of the conduct alleged herein, Webb violated Sections 17(a)(1),
17(a)(2), and 17(a)(3) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77q(a)(1),
(2), and (3)], and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15
U.S.C. §78j(b)] and Rules 10b-5(a), (b), and (c) thereunder [17 C.F.R. §§240.10b-5(a), (b), and
(c)].
NATURE OF THE PROCEEDING AND RELIEF SOUGHT
6. The Commission brings this action pursuant to the authority conferred upon it by
Section 20(b) of the Securities Act [15 U.S.C. §77t(b)] and Section 21(d)(1) of the Exchange Act
[15 U.S.C. §78u(d)(1)].
7. The Commission seeks a final judgment: (a) permanently enjoining Webb from
violating the federal securities laws by engaging in transactions, acts, practices, and courses of
business of the type alleged in this Complaint; (b) permanently enjoining Webb from, directly or
indirectly, including but not limited to, through any entity owned or controlled by him,

3
participating in the purchase, offer, or sale of any security to investors or potential investors,
provided, however, that such injunction shall not prevent him from purchasing or selling
securities for his own personal accounts; (c) ordering Webb to disgorge any ill-gotten gains with
prejudgment interest thereon, pursuant to Sections 21(d)(5) and 21(d)(7) of the Exchange Act [15
U.S.C. §78u(d)(5) and (7)]; (d) ordering Webb to pay a civil money penalty pursuant to Section
20(d) of the Securities Act [15 U.S.C. §77t(d)] and Section 21(d)(3) of the Exchange Act [15
U.S.C. §78u(d)(3)]; and (e) ordering such other and further relief the Court may deem just and
proper.
DEFENDANT
8. Jonathan Webb (“Webb”),  age 49, is a resident of Tewksbury, Massachusetts.
Webb was employed at a cemetery in Massachusetts in various horticultural and arboricultural
positions from 1994 through 2024.  Webb is currently employed at a different cemetery in
Massachusetts.
JURISDICTION AND VENUE
9. This Court has jurisdiction over this action pursuant to Sections 20(d)(1) and
22(a) of the Securities Act [15 U.S.C. §§77t(d)(1) and 77v(a)] and Sections 21(d), 21(e), and 27
of the Exchange Act [15 U.S.C. §§78u(d), 78u(e), 78aa].  Venue lies in this district pursuant to
Section 22(a) of the Securities Act [15 U.S.C. §77v(a)] and Section 27 of the Exchange Act [15
U.S.C. §78aa].  A substantial portion of the acts, practices, transactions and courses of business
alleged in this Complaint occurred within the District of Massachusetts.  Webb also resides in the
district.
10. In connection with the transactions, acts, practices, and courses of business
alleged in this Complaint, Defendant, directly or indirectly, singly or in concert with others,

4
made use of the means or instrumentalities of transportation or communication in interstate
commerce, or the mails.
DEFENDANT’S ACTS IN VIOLATION OF THE FEDERAL SECURITIES LAWS
11. Webb began working as an arborist at a Massachusetts cemetery in 1994 and by
2019 had become a supervisor of tree maintenance.  Webb had no investment experience or
training beyond his workplace retirement account and his trading of securities in a personal
trading account.
12. In approximately 2019, Webb attended a two-week course for the purpose of
learning about on-line trading in his personal accounts.  The second week of the on-line trading
course focused on trading in the Forex market.  After taking the on-line trading course, Webb
proceeded to use his own money to trade Forex, achieving both gains and losses over time.
13. After attending the on-line trading course, Webb learned from on-line sources that
if he used certain overseas brokerage firms he could trade Forex with leverage of up to 500:1.
The term “leverage” at the overseas brokerage firms did not involve the customer borrowing
funds to trade.  Rather, the firm allowed the customer to trade a larger position.  One overseas
brokerage firm’s website stated, “For example, with $1,000 in your trading account and leverage
of 200:1, you can have trading capacity of $200,000.”  Webb understood that this allowed for the
potential of greater gains, but also increased the risk of loss.  The firms limited any losses to the
initial investment.
14. After attending the on-line trading course, Webb also read on-line information
about “Forex Expert Advisors,” software trading programs which claim to execute automatic
Forex trading strategies according to a computer programmed algorithm.
15. Webb particularly focused on the software trading program called “Barclays
Expert Advisor,” as it advertised gains of 15% per month over many years with very small

5
losses.  Webb’s due diligence on the Barclays Expert Advisor software was limited to reviewing
publicly available websites and the Barclays Expert Advisor website.  The only contact
information listed on the Barclays Expert Advisor website was a WhatsApp Online Chat number.
The website was hosted in Indonesia and the registrant’s contact information is in Indonesia.  A
well-known international financial institution known as Barclays plc or Barclays Bank has no
connection with the website or with the Barclays Expert Advisor software.
16. Webb discussed his Forex investments with employees of the cemetery and also
with his church community where he was the president and a board member.  He told people that
he could earn extravagant returns doing Forex trading and that they could as well.  He told the
employees and church members that if they invested their money with him, he would return the
money they invested plus any interest earned in one year.
17. Beginning in at least January 2021, Webb began soliciting and accepting money
from employees, church members and friends for purposes of investing in Forex.  Webb had
known many of the investors as employees, church members or friends for decades.  Many of the
employees were low-wage workers who reported to Webb at the cemetery.   Individuals invested
tens of thousands of dollars with Webb.  When potential investors did not have the savings to
invest, Webb helped individuals take out personal loans of as much as $50,000 and even
promised to make the monthly payments owed on the loans.
18. At least 34 individuals invested approximately $1.7 million with Webb from at
from at least January 1, 2021 to August 2023.  Several of the investments were provided to
Webb cash in-hand.  Webb had virtually no system for recording the names of investors,
amounts invested, dates of investment, investment returns or amounts paid back to investors.
Webb also did not keep track of nor did he record the amount of investor funds actually invested
in Forex.

6
19. For many investors, Webb drafted a one paragraph “Investment Agreement,”
which he and the investor signed electronically.  The agreements varied in specifics, but in
general they provided that the investor was giving Webb an amount of money “for investment
purposes.”  The agreements further stated that at the end of one year, Webb would return the
money they invested, or capital, plus any interest.  Most of the agreements falsely promised that
the capital was “guaranteed,” and provided an exorbitant “intended targeted interest.”  For
example, many agreements provided for a targeted annual return of 100% or 200%, and others
provided for targeted monthly returns as high as 15% or 25%.  In a few instances, Webb
promised to return the capital and a specified percentage return.  For example, some agreements
promised that the capital plus an additional 35% would be guaranteed after one year.
20. For investors who did not sign a written agreement, Webb falsely promised to
double or triple their money within a year by investing in Forex.
21. Webb knew or was reckless in not knowing that his guarantees to return
investors’ capital within a year with promises of exorbitant returns based on Forex trading were
false.  Webb had never generated consistent annual returns in his own trading, and certainly not
annual returns of 100%.  Webb’s own trading record was far more mixed, with some gains and
some losses.
22. Webb’s purported basis for guaranteeing a return of capital and projecting and
promising extravagant returns was the on-line advertised returns he had seen for the Barclays
Expert Advisor software, which he had purchased using crypto assets.  Webb did not know
anyone personally who had actually used the software to trade in a real account.
23. In order to execute his Forex trading plan, Webb opened accounts at overseas
brokerage firms located in Dubai and St. Vincent and the Grenadines.  The overseas brokerage

7
firms provided Webb access to a platform for trading Forex, to which he was able to connect the
Barclays Expert Advisor software.
24. The overseas brokerage firms also allowed Webb to trade with up to 500:1
leverage.  Webb understood that there is always a risk of loss when investing and that the risk
was greatly increased by using leverage.
25. In order to make deposits at the overseas brokerage firms, Webb sent investor
money to a U.S. based crypto asset trading platform, converted the U.S. dollars to crypto assets,
and then transferred the crypto assets to the overseas brokerage firms.
26. By at least the end of 2022, Webb’s trading resulted in the loss of significant
investor funds.  For example, the records from one overseas brokerage firm show that Webb lost
approximately $100,000 during the first two days of November 2022.  Records from another
overseas brokerage firm show that by March 2023, Webb had lost over $700,000.
27. Even after losing significant investor funds in November 2022, Webb continued
to solicit investments from employees, church members, and friends, and continued to falsely
promise exorbitant returns of 100% or 200% per year and a guaranteed return of capital after one
year.  Webb knew, based on his recent loss of investor funds, that his guarantee to return capital
and promises of exorbitant returns were false.  As with previous investors, when some of those
individuals did not have the funds to invest, Webb helped them apply for personal loans and
promised to make monthly payments on the loans.  At least 14 different individuals made a total
of more than $500,000 in investments with Webb after he had suffered large investment losses in
November 2022.
28. After losing significant investor funds, Webb tried different Forex trading
strategies.  One of those strategies was using retail proprietary trading firms to trade Forex.
These firms charge retail customers a fee to take a trading challenge.  If the customer passes the

8
trading challenge, which typically consists of trading Forex using simulated funds in a simulated
market, he or she is given access to firm capital to trade in a “funded account.”  At some
proprietary trading firms customers with access to a funded account are able to trade in actual
Forex markets, while at other firms customers with access to a funded account are only able to
trade simulated funds in simulated Forex markets.  The customer then splits any profits
generated from their trading with the firm.  However, if at any point the customer loses more
than a pre-determined percentage of the funded account’s value, the customer loses access to the
funded account.  Webb sent investor funds to both types of proprietary trading firms.
29. By August 2023, Webb had lost most of the investor money that had actually
been invested in Forex.  These losses totaled more than one million dollars.
30. However, Webb did not use all of the investor funds for “investment purposes.”
Despite promising to use the funds for investment purposes, Webb used some incoming investor
funds from later investors to make payments to earlier investors.  He also misappropriated
investor funds and used funds to pay for personal expenses.  Many of the payments to earlier
investors were not for the repayment of their capital investment or investment returns, but rather
to make monthly payments on  personal loans investors had taken out to invest with Webb.
FIRST CLAIM FOR RELIEF
FRAUD IN THE OFFER OR SALE OF SECURITIES
Violations of Section 17(a) of the Securities Act [15 U.S.C. 77q(a)]
31. The Commission realleges and incorporates by reference paragraphs 1 through 30
above, as if fully set forth herein.
32. By engaging in the acts and conduct alleged above, Webb directly or indirectly, in
the offer or sale of securities, by use of the means or instruments of transportation or
communication in interstate commerce or by use of the mails: (1) employed devices, schemes, or
artifices to defraud; (2) obtained money or property by means of untrue statements of material

9
fact or by omitting to state material facts necessary in order to make statements made, in the light
of the circumstances under which they were made, not misleading; and (3) engaged in
transactions, practices or courses of business which operated or would operate as a fraud or
deceit upon the purchasers, in violation of Sections 17(a)(1), (2), and (3) of the Securities Act
[15 U.S.C. § 77q(a)(1), (2), and (3)].
SECOND CLAIM FOR RELIEF
FRAUD IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES
Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder
[15 U.S.C. § 78j(b), 17 C.F.R. § 240.10b-5]
33. The Commission realleges and incorporates by reference paragraphs 1 through 30
above, as if fully set forth herein.
34. By engaging in the acts and conduct alleged above, Webb, directly or indirectly,
in connection with the purchase or sale of securities, by the use of means or instrumentalities of
interstate commerce, or of the mails, or of a facility of a national securities exchange:
(1) employed devices, schemes, or artifices to defraud; (2) made untrue statements of material
fact or omitted to state material facts necessary in order to make the statements made, in light of
the circumstances under which they were made, not misleading; and (3) engaged in acts,
practices, or courses of business which operated or would operate as a fraud or deceit upon other
persons, including purchases and sellers of securities, in violation of Section 10(b) of the
Exchange Act [15 U.S.C. § 78j(b)] and subsections (a), (b), and (c) of Rule 10b-5 thereunder [17
C.F.R. § 240.10b-5(a), (b), and (c)].
PRAYER FOR RELIEF
WHEREFORE, the Commission respectfully requests that the Court find Defendant
committed the violations alleged, and:

10
A. Enter a Final Judgment permanently restraining and enjoining Webb, as well as
his agents, servants, employees, attorneys, and other persons in active concert or participation
with them, from directly or indirectly engaging in the conduct described above, or in conduct of
similar purpose and effect, in violation of:
1. Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; and
2. 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].
B. Enter a Final Judgment permanently restraining and enjoining Webb from,
directly or indirectly, including but not limited to, through any entity owned or controlled by
him, participating in the issuance, purchase, offer, or sale of any security, provided, however,
that such injunction shall not prevent him from purchasing or selling securities for his own
personal accounts.
C. Enter a Final Judgment ordering Webb to disgorge his ill-gotten gains or unjust
enrichment, with prejudgment interest thereon, to effect the remedial purposes of the federal
securities laws.
D. Enter a Final Judgment ordering Webb to pay civil penalties pursuant to Section
20(d) of the Securities Act [15 U.S.C. § 77t(d)] and Section 21(d) of the Exchange Act [15
U.S.C. § 78u(d)].
E. Retain jurisdiction over this action to implement and carry out the terms of all
orders and decrees that may be entered.
F. Grant such other and further relief as this Court may deem just and proper.

11
DEMAND FOR JURY TRIAL
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands a
jury trial in this action for all claims so triable..
Dated:  March 13, 2025   Respectfully submitted,

      SECURITIES AND EXCHANGE COMMISSION

      By its attorneys,

//s//  Martin F. Healey
Martin F. Healey (BBO# 227550)
Kerry Dakin (BBO# 640826)
Jeffrey Olshan (BBO# 693337)
Boston Regional Office
33 Arch Street, 24th Floor
Boston, MA  02110
Phone:  (617) 573-8900
Facsimile: (617) 573-4590
Healey Email:  [email protected]
Healey Phone: (617) 573-8952

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 

 
 
 
SECURITIES AND EXCHANGE COMMISSION, 
 
  Plaintiff, 
 
 v. 
 
JONATHAN WEBB, 
 
 
  Defendant,  
 
 

 
 
 
 
 
 
     Civil Action No.  
 
      

 
      
 
  

COMPLAINT 
 

 Plaintiff, United States Securities and Exchange Commission (“SEC” or “Commission”) 

alleges as follows against Defendant Jonathan Webb (“Defendant” or “Webb”).   

SUMMARY 

1. Massachusetts resident Jonathan Webb conducted a securities offering fraud that 

included Ponzi-like payments to some investors and use of investor money for personal 

purposes.  From at least January 2021 to August 2023, Webb solicited and accepted 

approximately $1.7 million dollars from at least 34 people for “investment purposes.”  Many of 

the investors lacked financial and/or investment experience.  Many also worked for Webb at a 

Massachusetts cemetery.  Several investors did not speak English and many were low-income 

workers who could not afford to invest and risk losing the money they entrusted to Webb.   

2. Webb falsely told investors he could double their money within a year by pooling 

it and investing in the foreign currency exchange market (Forex), and guaranteed the return of 

the capital and any interest earned.  For prospective investors who did not have tens of thousands 

of dollars to invest, Webb helped them to secure personal loans that enabled them to invest with 

Case 1:25-cv-10604     Document 1     Filed 03/13/25     Page 1 of 11



 2 

him.  He even promised to make the monthly loan payments on their behalf.  Webb then 

converted investor funds to crypto assets and transferred the converted funds to overseas 

brokerage firms.  That permitted Webb to invest in the Forex market using up to 500:1 leverage 

and an algorithmic trading program Webb had purchased on the internet.   

3. Webb lost hundreds of thousands of dollars in investor funds using the trading 

program.  Despite these losses, he continued to solicit and accept investor funds, falsely 

guaranteeing the return of capital and promising exorbitant potential returns.   

4. Webb lost most of the investor funds investing in Forex.  In addition, despite 

promising to use the investor funds for investment purposes, used some investor funds to pay 

back some earlier investors.  He also misappropriated investor funds for personal expenses.             

VIOLATIONS 

5. By virtue of the conduct alleged herein, Webb violated Sections 17(a)(1), 

17(a)(2), and 17(a)(3) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. §§ 77q(a)(1), 

(2), and (3)], and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 

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

(c)]. 

NATURE OF THE PROCEEDING AND RELIEF SOUGHT 

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

Section 20(b) of the Securities Act [15 U.S.C. §77t(b)] and Section 21(d)(1) of the Exchange Act 

[15 U.S.C. §78u(d)(1)]. 

7. The Commission seeks a final judgment: (a) permanently enjoining Webb from 

violating the federal securities laws by engaging in transactions, acts, practices, and courses of 

business of the type alleged in this Complaint; (b) permanently enjoining Webb from, directly or 

indirectly, including but not limited to, through any entity owned or controlled by him, 

Case 1:25-cv-10604     Document 1     Filed 03/13/25     Page 2 of 11



 3 

participating in the purchase, offer, or sale of any security to investors or potential investors, 

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

securities for his own personal accounts; (c) ordering Webb to disgorge any ill-gotten gains with 

prejudgment interest thereon, pursuant to Sections 21(d)(5) and 21(d)(7) of the Exchange Act [15 

U.S.C. §78u(d)(5) and (7)]; (d) ordering Webb to pay a civil money penalty pursuant to Section 

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

U.S.C. §78u(d)(3)]; and (e) ordering such other and further relief the Court may deem just and 

proper. 

DEFENDANT 

8. Jonathan Webb (“Webb”),  age 49, is a resident of Tewksbury, Massachusetts.  

Webb was employed at a cemetery in Massachusetts in various horticultural and arboricultural 

positions from 1994 through 2024.  Webb is currently employed at a different cemetery in 

Massachusetts.   

JURISDICTION AND VENUE 

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

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

of the Exchange Act [15 U.S.C. §§78u(d), 78u(e), 78aa].  Venue lies in this district pursuant to 

Section 22(a) of the Securities Act [15 U.S.C. §77v(a)] and Section 27 of the Exchange Act [15 

U.S.C. §78aa].  A substantial portion of the acts, practices, transactions and courses of business 

alleged in this Complaint occurred within the District of Massachusetts.  Webb also resides in the 

district. 

10. In connection with the transactions, acts, practices, and courses of business 

alleged in this Complaint, Defendant, directly or indirectly, singly or in concert with others, 

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 4 

made use of the means or instrumentalities of transportation or communication in interstate 

commerce, or the mails. 

DEFENDANT’S ACTS IN VIOLATION OF THE FEDERAL SECURITIES LAWS 

11. Webb began working as an arborist at a Massachusetts cemetery in 1994 and by 

2019 had become a supervisor of tree maintenance.  Webb had no investment experience or 

training beyond his workplace retirement account and his trading of securities in a personal 

trading account.   

12. In approximately 2019, Webb attended a two-week course for the purpose of 

learning about on-line trading in his personal accounts.  The second week of the on-line trading 

course focused on trading in the Forex market.  After taking the on-line trading course, Webb 

proceeded to use his own money to trade Forex, achieving both gains and losses over time.     

13. After attending the on-line trading course, Webb learned from on-line sources that 

if he used certain overseas brokerage firms he could trade Forex with leverage of up to 500:1.  

The term “leverage” at the overseas brokerage firms did not involve the customer borrowing 

funds to trade.  Rather, the firm allowed the customer to trade a larger position.  One overseas 

brokerage firm’s website stated, “For example, with $1,000 in your trading account and leverage 

of 200:1, you can have trading capacity of $200,000.”  Webb understood that this allowed for the 

potential of greater gains, but also increased the risk of loss.  The firms limited any losses to the 

initial investment.   

14. After attending the on-line trading course, Webb also read on-line information 

about “Forex Expert Advisors,” software trading programs which claim to execute automatic 

Forex trading strategies according to a computer programmed algorithm.   

15. Webb particularly focused on the software trading program called “Barclays 

Expert Advisor,” as it advertised gains of 15% per month over many years with very small 

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 5 

losses.  Webb’s due diligence on the Barclays Expert Advisor software was limited to reviewing 

publicly available websites and the Barclays Expert Advisor website.  The only contact 

information listed on the Barclays Expert Advisor website was a WhatsApp Online Chat number.  

The website was hosted in Indonesia and the registrant’s contact information is in Indonesia.  A 

well-known international financial institution known as Barclays plc or Barclays Bank has no 

connection with the website or with the Barclays Expert Advisor software.   

16. Webb discussed his Forex investments with employees of the cemetery and also 

with his church community where he was the president and a board member.  He told people that 

he could earn extravagant returns doing Forex trading and that they could as well.  He told the 

employees and church members that if they invested their money with him, he would return the 

money they invested plus any interest earned in one year.   

17. Beginning in at least January 2021, Webb began soliciting and accepting money 

from employees, church members and friends for purposes of investing in Forex.  Webb had 

known many of the investors as employees, church members or friends for decades.  Many of the 

employees were low-wage workers who reported to Webb at the cemetery.  Individuals invested 

tens of thousands of dollars with Webb.  When potential investors did not have the savings to 

invest, Webb helped individuals take out personal loans of as much as $50,000 and even 

promised to make the monthly payments owed on the loans.   

18. At least 34 individuals invested approximately $1.7 million with Webb from at 

from at least January 1, 2021 to August 2023.  Several of the investments were provided to 

Webb cash in-hand.  Webb had virtually no system for recording the names of investors, 

amounts invested, dates of investment, investment returns or amounts paid back to investors.  

Webb also did not keep track of nor did he record the amount of investor funds actually invested 

in Forex. 

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19. For many investors, Webb drafted a one paragraph “Investment Agreement,” 

which he and the investor signed electronically.  The agreements varied in specifics, but in 

general they provided that the investor was giving Webb an amount of money “for investment 

purposes.”  The agreements further stated that at the end of one year, Webb would return the 

money they invested, or capital, plus any interest.  Most of the agreements falsely promised that 

the capital was “guaranteed,” and provided an exorbitant “intended targeted interest.”  For 

example, many agreements provided for a targeted annual return of 100% or 200%, and others 

provided for targeted monthly returns as high as 15% or 25%.  In a few instances, Webb 

promised to return the capital and a specified percentage return.  For example, some agreements 

promised that the capital plus an additional 35% would be guaranteed after one year.   

20. For investors who did not sign a written agreement, Webb falsely promised to 

double or triple their money within a year by investing in Forex.   

21. Webb knew or was reckless in not knowing that his guarantees to return 

investors’ capital within a year with promises of exorbitant returns based on Forex trading were 

false.  Webb had never generated consistent annual returns in his own trading, and certainly not 

annual returns of 100%.  Webb’s own trading record was far more mixed, with some gains and 

some losses.   

22. Webb’s purported basis for guaranteeing a return of capital and projecting and 

promising extravagant returns was the on-line advertised returns he had seen for the Barclays 

Expert Advisor software, which he had purchased using crypto assets.  Webb did not know 

anyone personally who had actually used the software to trade in a real account.   

23. In order to execute his Forex trading plan, Webb opened accounts at overseas 

brokerage firms located in Dubai and St. Vincent and the Grenadines.  The overseas brokerage 

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 7 

firms provided Webb access to a platform for trading Forex, to which he was able to connect the 

Barclays Expert Advisor software.   

24. The overseas brokerage firms also allowed Webb to trade with up to 500:1 

leverage.  Webb understood that there is always a risk of loss when investing and that the risk 

was greatly increased by using leverage.   

25. In order to make deposits at the overseas brokerage firms, Webb sent investor 

money to a U.S. based crypto asset trading platform, converted the U.S. dollars to crypto assets, 

and then transferred the crypto assets to the overseas brokerage firms.   

26. By at least the end of 2022, Webb’s trading resulted in the loss of significant 

investor funds.  For example, the records from one overseas brokerage firm show that Webb lost 

approximately $100,000 during the first two days of November 2022.  Records from another 

overseas brokerage firm show that by March 2023, Webb had lost over $700,000.   

27. Even after losing significant investor funds in November 2022, Webb continued 

to solicit investments from employees, church members, and friends, and continued to falsely 

promise exorbitant returns of 100% or 200% per year and a guaranteed return of capital after one 

year.  Webb knew, based on his recent loss of investor funds, that his guarantee to return capital 

and promises of exorbitant returns were false.  As with previous investors, when some of those 

individuals did not have the funds to invest, Webb helped them apply for personal loans and 

promised to make monthly payments on the loans.  At least 14 different individuals made a total 

of more than $500,000 in investments with Webb after he had suffered large investment losses in 

November 2022.  

28. After losing significant investor funds, Webb tried different Forex trading 

strategies.  One of those strategies was using retail proprietary trading firms to trade Forex.  

These firms charge retail customers a fee to take a trading challenge.  If the customer passes the 

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trading challenge, which typically consists of trading Forex using simulated funds in a simulated 

market, he or she is given access to firm capital to trade in a “funded account.”  At some 

proprietary trading firms customers with access to a funded account are able to trade in actual 

Forex markets, while at other firms customers with access to a funded account are only able to 

trade simulated funds in simulated Forex markets.  The customer then splits any profits 

generated from their trading with the firm.  However, if at any point the customer loses more 

than a pre-determined percentage of the funded account’s value, the customer loses access to the 

funded account.  Webb sent investor funds to both types of proprietary trading firms. 

29. By August 2023, Webb had lost most of the investor money that had actually 

been invested in Forex.  These losses totaled more than one million dollars.   

30. However, Webb did not use all of the investor funds for “investment purposes.”  

Despite promising to use the funds for investment purposes, Webb used some incoming investor 

funds from later investors to make payments to earlier investors.  He also misappropriated 

investor funds and used funds to pay for personal expenses.  Many of the payments to earlier 

investors were not for the repayment of their capital investment or investment returns, but rather 

to make monthly payments on  personal loans investors had taken out to invest with Webb.   

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

Violations of Section 17(a) of the Securities Act [15 U.S.C. 77q(a)] 

31. The Commission realleges and incorporates by reference paragraphs 1 through 30 

above, as if fully set forth herein. 

32. By engaging in the acts and conduct alleged above, Webb directly or indirectly, in 

the offer or sale of securities, by use of the means or instruments of transportation or 

communication in interstate commerce or by use of the mails: (1) employed devices, schemes, or 

artifices to defraud; (2) obtained money or property by means of untrue statements of material 

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fact or by omitting to state material facts necessary in order to make statements made, in the light 

of the circumstances under which they were made, not misleading; and (3) engaged in 

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

deceit upon the purchasers, in violation of Sections 17(a)(1), (2), and (3) of the Securities Act 

[15 U.S.C. § 77q(a)(1), (2), and (3)]. 

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

Violations of Section 10(b) of the Exchange Act and Rule 10b-5 Thereunder 
[15 U.S.C. § 78j(b), 17 C.F.R. § 240.10b-5] 

33. The Commission realleges and incorporates by reference paragraphs 1 through 30 

above, as if fully set forth herein. 

34. By engaging in the acts and conduct alleged above, Webb, directly or indirectly, 

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

interstate commerce, or of the mails, or of a facility of a national securities exchange: 

(1) employed devices, schemes, or artifices to defraud; (2) made untrue statements of material 

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

the circumstances under which they were made, not misleading; and (3) engaged in acts, 

practices, or courses of business which operated or would operate as a fraud or deceit upon other 

persons, including purchases and sellers of securities, in violation of Section 10(b) of the 

Exchange Act [15 U.S.C. § 78j(b)] and subsections (a), (b), and (c) of Rule 10b-5 thereunder [17 

C.F.R. § 240.10b-5(a), (b), and (c)].   

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court find Defendant 

committed the violations alleged, and: 

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A. Enter a Final Judgment permanently restraining and enjoining Webb, as well as 

his agents, servants, employees, attorneys, and other persons in active concert or participation 

with them, from directly or indirectly engaging in the conduct described above, or in conduct of 

similar purpose and effect, in violation of: 

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

2. 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]. 

B. Enter a Final Judgment permanently restraining and enjoining Webb from, 

directly or indirectly, including but not limited to, through any entity owned or controlled by 

him, participating in the issuance, purchase, offer, or sale of any security, provided, however, 

that such injunction shall not prevent him from purchasing or selling securities for his own 

personal accounts. 

C. Enter a Final Judgment ordering Webb to disgorge his ill-gotten gains or unjust 

enrichment, with prejudgment interest thereon, to effect the remedial purposes of the federal 

securities laws. 

D. Enter a Final Judgment ordering Webb to pay civil penalties pursuant to Section 

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

U.S.C. § 78u(d)]. 

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

orders and decrees that may be entered. 

F. Grant such other and further relief as this Court may deem just and proper. 

  

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DEMAND FOR JURY TRIAL 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Commission demands a 

jury trial in this action for all claims so triable.. 

Dated:  March 13, 2025   Respectfully submitted, 
 
      SECURITIES AND EXCHANGE COMMISSION 
 
      By its attorneys, 
 

  
//s//  Martin F. Healey     
Martin F. Healey (BBO# 227550) 
Kerry Dakin (BBO# 640826) 
Jeffrey Olshan (BBO# 693337) 
Boston Regional Office 
33 Arch Street, 24th Floor 
Boston, MA  02110 
Phone:  (617) 573-8900 
Facsimile: (617) 573-4590 
Healey Email:  [email protected] 
Healey Phone: (617) 573-8952  

 

 
 
 

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