Broker-Dealer Litigation - Greenberg Traurig LLP

The Commission’s complaint alleged that Awan, Koppel, and the other defendants fraudulently
raised more than $2 million from investors in three offerings by means of fraudulent
misrepresentations, including promises of imminent initial public offerings and/or substantial
increases in stock price; misappropriated investor funds for personal expenses, and failed to
disclose their disciplinary histories. The court permanently enjoined Awan and Koppel from
violating the antifraud provisions of the federal securities laws, ordered Awan to pay $655 in
disgorgement plus prejudgment interest and a $10,000 civil penalty, ordered Koppel to pay $851
in disgorgement plus prejudgment interest and a $10,000 civil penalty, and barred Koppel from
participating in the offering of any penny stock. In related administrative proceedings brought
by the Commission, Awan consented to the entry of an order barring him from association and
from participating in the offering of any penny stock, and Koppel consented to the entry of an
order barring him from association.
In re Buchholz, Release No. 63800, 2011 SEC LEXIS 344 (Jan. 31, 2011).
Q.1.c(i)
The Commission accepted an offer of settlement from Buchholz, a registered
representative of a registered broker-dealer. In an earlier criminal proceeding, Buchholz pleaded
guilty to one count of wire fraud. The criminal indictment alleged that Buchholz engaged in a
scheme to defraud his clients of more than $1.3 million through such tactics as forging client
signatures, depositing client funds into personal accounts, misrepresenting that his clients had
authorized redemptions, and misrepresenting to clients that funds would be placed into their
accounts when he actually placed those funds into his personal accounts. The Commission
barred Buchholz from association and from participating in any offering of penny stock.
In re Zangari, Release No. 63923, 2011 SEC LEXIS 650 (Feb. 17, 2011).
Q.1.c(i)
The Commission accepted an offer of settlement from Zangari, a stock loan trader who
was employed by several major Wall Street brokerage firms over an eleven year period. In an
earlier action brought by the Commission, a federal district court entered a partial judgment by
consent against Zangari, permanently enjoining him from violating the antifraud provisions of
the federal securities laws. The Commission’s complaint alleged that Zangari knowingly
engaged in a scheme to defraud broker-dealers in connection with the lending and borrowing of
securities. The Commission barred Zangari from association.
In re Sarnicola, Release No. 63924, 2011 SEC LEXIS 651 (Feb. 17, 2011).
Q.1.c(i)
The Commission accepted an offer of settlement from Sarnicola, a securities lending
representative of a registered broker-dealer. In an earlier criminal proceeding, Sarnicola pleaded
guilty to one count of conspiracy to commit wire fraud. The criminal indictment alleged that
Sarnicola conspired to defraud the registered broker-dealer of money and property, and to obtain
money and property from the broker-dealer by means of materially false and fraudulent
pretenses. The Commission barred Sarnicola from association.
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