The U.S. Securities & Exchange Commission charged Connecticut-based investment adviser Navy Capital Green Management, LLC with misrepresentations to private fund investors about its anti-money laundering (AML) due diligence procedures and related compliance failures, and settled the matter for a USD 150,000 civil penalty. From at least October 2018 to January 2022, Navy Capital told prospective and existing investors that it was voluntarily complying with AML due diligence laws and conducting specified onboarding and ongoing monitoring, even though those laws did not apply to investment advisers. The SEC found the firm did not always perform the described AML diligence, including regarding an investor entity owned by an individual publicly reported to have suspected ties to money laundering; a foreign court later froze assets of one of Navy Capital’s private funds because it held funds from that investor. The order also found Navy Capital failed to adopt and implement written policies and procedures reasonably designed to ensure the accuracy of offering and other investor documents. Without admitting or denying the findings, Navy Capital agreed to a cease-and-desist order, censure, and payment of the civil penalty.
U.S. Securities & Exchange Commission 2025-01-14
U.S. Securities & Exchange Commission charges Navy Capital for misrepresenting anti-money laundering procedures and orders USD 150,000 penalty
The U.S. Securities & Exchange Commission charged Navy Capital Green Management, LLC with misrepresenting its anti-money laundering due diligence to private fund investors and related compliance failures, settling for a USD 150,000 civil penalty. The firm falsely claimed voluntary AML compliance and failed to perform due diligence, leading to asset freezes by a foreign court. Navy Capital agreed to a cease-and-desist order, censure, and the penalty without admitting or denying findings.