EFTA00078082.pdf

From: Chris Dilorio To Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Date: Fri, 06 Nov 2020 14:09:20 +0000 Attachments: KCG_Appendix_3-20_13_penultimate.docx; KCG_TCR_3-20-13-penultimate_draft.pdf; KCG_TCR_3-20-13-penultimate_draft.docx; KCG_Appendix_3-20_13_penultimate.pdf; Cifu.jpg; Blosteinjpg; KCGMarch2017.jpg Laney et al, NITE/VIRT just released 3Q2020 earnings. A direct result of a massive, ongoing, SEC facilitated fraud on the public the SEC is mandated to protect The Balance sheet fraud shell game continues. https://www.sec.gov/Archives/edgar/data/1592386/000110465920122134/tm2034848d1 ex99-1.htm for the sell siders to ask on the earnings Call: Tangible book BEFORE we get into mechanics of the massive, ongoing accounting fraud as a direct result of illegal naked shorting OTCM (and other) shells: I get les than $2/sh. Tell me where I'm wrong. But, it's MUCH MUCH MUCH worse than that; Account receivable : $1.88 billion EFTA00078082 Payable: $675 million Difference: $1.2 billion AR is where NITE books naked short fails as a result of self clearing. No intention/can't deliver. More accurately: a liability Further: prior commitment on this "asset": settlement. Nothing NITE/VIRT can convert to cash for company use. Also: Trading assets: the old securities owned Trading liabilities: the old securities sold not yet purchased Structural liability as a result of naked shorting. Propped up/off set by securities owned. NITE/VIRT is grossly insolvent STILL/AGAIN/CONSTANTLY. And, no breakdown of the vast driver of trading revenue: US equity market Making Did NITE/VIRT exit the extremely low tech/cash OTCM trading business? NOPE This illegal activity is extremely profitable. Virtually riskless in fact. AND is the driver of trading revenue. WHY the VIRT/KCG merger was done . Abusive naked shorting OTCM/other shells to facilitate money laundering is and always has been the core business at NITE. The SEC knows this. Where are disclosures in SEC filings of this high AML risk business? You won't find any. Cifu stopped reporting post merger. Not in Sell Side models either. INTENTIONALLY misleading the investing public as to the true nature of the NITE/VIRT business model. In short: absolutely NOTHING has changed since the so called "glitch" as a direct result of SEC corruption/obstruction. With help from the SONY and Sell Side analists covering NITE/VIRT Cheers! Christopher.' Dilorio Whistleblower From: Chris Dilorio e > Sent: Wednesday. October 14. 2020 9:00 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix EFTA00078083 The corrupt, criminal relationship with Handler/Jefferies as I have stated is NOT the only corrupt,criminal relationship the SEC/SDNY have with members of their respective "do not investigate lists". AQR, Blackstone as well as Jay Clayton good fried Glenn Hutchins. Hutchins also worked at Blackstone with Schwarzman prior to founding Silver Lake. Hutchins bought SunGard. Then sold it to FIS. This transaction was the basis of the formation of North Island with former NASDAQ CEO Greifeld. North Island is a top shareholder of the criminal enterprise NITE/VIRT. More context: Greifeld was a Director UK/NJ company called Automated Securities Clearance Ltd https://find-and-update.company-information.service.gov.uk/company/03385409/officers AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Officers (free information from Companies House) AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Free company information from Companies House including registered office address, filing history, accounts, annual return, officers, charges, business activity find-and-update.company-information.service.gov.uk Sold to SunGard. Greifeld then became CEO at SunGard. He wasn't at SunGard very long. Then made the jump to CEO of NASDAQ. Curious to say the least. Shortly after becoming NASDAQ CEO, NASDAQ bought the BRUT ECN from SunGard. Self dealing? MUCH WORSE http://innasdaq.comIstatic-files/6b1ca278-75f0-4259-9372-5b3351126a8b ir.nasdaq.com 121e<2h- 21e<16$8;1<76.23$54- 2((1-&22 ir.nasdaq.com As you can see, current NASDAQ CEO Adena Friedman signed off on this transaction. SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to dollars in real time. hups://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion EFTA00078084  Otkritie Capital taps SunGard for automated Ruble conversion Otkritie Capital (Otkritie), one of the leading financial services providers in Russia, has selected SunGard to help launch a new direct market access (DMA) service allowing for automatic real ... www.finextra.com I'll say that again: FROM Russian rubles TO dollars in real time. Providing DMA to WHICH markets???? So, the marriage of Blackstone Alum Hutchins and Greifeld to form N Island and become a top investor in the criminal enterprise NITE was a natural fit. Money laundering on a MASSIVE scale. Algos and OTCM shells are very complimentary money laundering vehicles. Not to mention: Russian Mirror trades: RU ADR's trade OTCM Pinks as well. The KCG 1Q2014 astronomical increase in OTCM volumes. Expunged from SEC reviewed filings. Attached on previous emails as part of the OWB record. NASDAQ is also the repository of the vast AQR blank check money laundering shells. FULLY SEC reporting for credibility. As with many OTCM shells. The only real difference between a NASDAQ/AQR blank check shell and an OTCM shell is the amount of money being laundered. Clayton should have been investigated and barred from SEC business pending a full and thorough investigation. So, that precludes the corrupt SEC IG Hoecker from any involvement. Cheers! Christopher J Dilorio Whistleblower From: Chris Dilorio Sent: Thursda Se stember 17 2020 5:56 PM To Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Judge Nathan, I applaud your reproof of the SONY. Now, I urge you to look at the Dan Kamensky case. I have never met Kamensky. When I saw the joint SEC/SDNY complaint I became physically ill. I am an SEC whistleblower. The SEC/SDNY have actively and continuously obstructed a thorough investigation of my extremely serious allegations. In favor of Rich Handler/Jefferies. The IB in the Kamensky case. Based on my experience with the SEC/SDNY I believe they both are withholding exculpatory evidence which impeaches the credibility of the SEC/SDNY/Handler/Jefferies. A corrupt relationship exists between the SEC/SDNY and Handler/Jefferies. In addition to others in my claims. I have contacted Judge Cave as well as Kamensky counsel. Disclosure of this corrupt relationship puts the Neiman Marcus "sting" in a whole different context. The motives of which should be investigated. Respectfully, Christopher J Dilorio EFTA00078085 Whistleblower From: Chris Dilorio Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Please see the new photos attached: Mr Blostein's Eureka moment and Cifu admission that the NITE/VIRT revenue model is driven by the "retail participation" rate: Cifu: "The retail segment of what we do is a SIGNIFICANT portion of our overall American equity segment..." So, are institutions trading .0001 OTCM money laundering shells? Mr Blostein: what are you modeling for NITE/VIRT OTCM share volumes when you KNOW and Cifu admits the importance of these share volumes on the NITE/VIRT revenue model? Does ANY Sell side analyst model this NITE/VIRT revenue driver? WHY doesn't Cifu disclose these share volumes in SEC filings? He used to. Knight/KCG used to as well. See photo. So why did he stop? Did NITE exit OTCM trading? ABSOLUTELY NOT. So the Goldman Analist Blostein KNOWS these share volumes drive revenue at NITE. Blostein doesn't disclose these volumes in his model. Fraud is also an OMISSION of material fact. Time to ask Cifu WHY he doesn't tell you to model OTCM share volumes fellas. This is WHY the SEC/Handler/Jefferies/VIRT/KCG acquisition took place. As Cifu admits: Retail:OTCM drives NITE/VIRT earnings. Cheers! Christopher.' Dilorio Whistleblower From: Chris Dilorio c > Sent: Wednesday, September 16, 2020 3:01 PM EFTA00078086 Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix First Sell Sider, SEC,DoJ who can get me a current NITE/VIRT tangible book value calculation wins a prize: Mr Kamensky's freedom. That's BEFORE properly classification of Naked short fails NITE/VIRT KNOWINGLY books as fraud assets: receivable. Mr Blostein, I remember a NITE/VIRT earnings call not to long ago where you made a direct correlation between NITE OTCM share volumes and NITE trading profits. Remember the 1? I have hard copies of that too. Did Cifu threaten you if you bring it up again? Please forward your model including these share volumes so we can compare notes. Who else has been threatened with retaliation by Cifu/Handler? Who has been promised business? Mr Repetto/Fannon? Who has BUY ratings on NITE/VIRT currently? Cheers! Christopher J Dilorio Whistleblower From: Chris Dilorio < Sent: Wednesday, September 16, 2020 9:20 AM u jec : Fw: Formal appeal or preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Judge Cave, The criminal, corrupt relationship between the SEC/Handler/NITE goes further. Doesn't it Mr Repetto? For the Sell Siders on this e mail: Please tell Judge Cave, The SEC/DoJ, Mr Kamensky's counsel the following: 1) how many red flags in NITE 3 CFO's in a year? 2) What you're modeling for NITE OTCM share volumes 3) WHY none of you question the once again ballooning balance sheet on earnings calls The other questions below can be answered by Mr Repetto and Jefferies Mr Fannon Cheers! Christopher J Dilorio Whistleblower From: Chris Dilorio .zz > Sent: Monday, September 14, 2020 9:22 AM EFTA00078087 To: Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix I look forward to speaking with you Regards, Chris From: Chris Dilorio Sent: Monday, September 14, 2020 6:02 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Judge Jones, Judge Cave Straight forward, irrefutable proof of SEC corrupt relationship with Handler Jefferies: KCG was engaged in abusive naked shorting in months leading up to the SEC/Handler/Jefferies VIRT acquisition closing 7/31/2017 SEC/Handler/Jefferies KNEW the core business at KCG is and always has been abusive naked shorting OTCM and other shells to facilitate money laundering. SEC/Handler/Jefferies knew KCG was insolvent in 2012 as well as 2017 as a direct result of this illegal activity Handler/Jefferies were the largest shareholder of KCG in 2017 when the SEC/Handler/Jefferies/Cifu orchestrated VIRT/KCG merger was consumated https://www.clearygottlieb.com/news-and-insights/news-listing/14-billion-merger-of-kcg-holdings-and-virtu- financial $1.4 Billion Merger of KCG Holdings and Virtu Financial I Cleary Gottlieb Cleary Gottlieb is representing Goldman, Sachs & Co., as financial advisor to KCG Holdings in its sale to Virtu Financial in an all-cash transaction valued at $1.4 billion. www.clearygottlieb.com SEC/Handler/Jefferies/Cifu used known fraud "assets" on the KCG balance sheet to determine the grossly inflated tangible book value calculation used to value the KCG acquisition price. Immediately prior to the transaction closing on 7/31/2017 the SEC/Cifu wrote down more than $4 billion in leverage from the KCG balance sheet. INCLUDING fraud assets used to calculate the grossly inflated acquisition price of KCG. SEC/Handler/Jefferies KNEW KCG was insolvent in 2012 AND July 2017 The SEC has known about the Knight/KCG/VIRT accounting fraud and securities fraud for years. I TOLD THEM. The SEC has engaged in a massive criminal obstruction scheme that is ongoing to protect NITE/VIRT. As a direct result of this corrupt, criminal scheme the investing public is put at risk, NITE/VIRT is insolvent again/always, Handler/Jefferies benefit, my rights as a whistleblower have been egregiously abused, Kamensky's life is ruined. EFTA00078088 The SEC/SDNY is making a mockery of your respective courts. Worse: the SEC and SDNY are committing a massive and well known FRAUD on your respective courts. The true character of Handler/ Jefferies as well as the corrupt relationship the SEC has with Handler/Jefferies must be disclosed to Mr Kamensky. Any verdict without these disclosures is a known miscarriage of justice. https://www.lexology.comilibraryidetail.aspx?g=9e2b4e49-See2-48f6-b8c7-03d39d02b5ca SEC ordered to produce Brady and Giglio materials due to joint investigation with U.S. Attorney's office - Lexology A district court ordered the SEC to produce material solely in its possession to a defendant in a parallel criminal prosecution by the U.S. Attorney... www.lexology.com Mr Kamensky WILL have my information. Mr Kamensky WILL have justice. The SEC/Handler/Jefferies/Cifu corrupt criminal relationship and ongoing frauds on the public will be exposed and ENDED. Regards, Christopher J Dilorio Whistleblower From: Chris Dilorio < Sent: Saturday, September 12, 2020 8:23 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Judges Cave and Jones, The SEC corruption goes well beyond just Handler/Jefferies/NITE. My research: I developed a template. I would search NITE top traded OTCM shells. From there: Derivatives. I have filed several separate but related TCR's based on that information. The SEC has brought several actions related to my 2013 Knight TCR with Berger: Hanover/Magna, JMJ,Keener, Hicks, Fife,UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA brought a complaint against Brown Brothers Harriman AFTER the SEC was in possession of my information for almost a year. That complaint IS also my information. New SEC NY Richard Best brought that FINRA complaint. ALL of the entities are un named. WHY? Per the complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. NITE as the #1 trader in the space would most certainly have executed BBH trades converting worthless certs to real money. The BBH complaint also cites un named Swiss Banks and FFI's. As a result of EFTA00078089 exposing these frauds the SEC/FINRA no longer allow searches of OTCM share volume by Market Maker. Further, Cifu,Handler,the SEC have allowed the post VIRT/KCG: NITE to no longer disclose these share volumes in any SEC filings NOR SEC reviewed investor presentations. Has NITE exited this business? ABSOLUTELY not. It is and always has been the DRIVER of NITE trading profits. Virtually riskless albeit illegal. The investing public is intentionally misled as to the true, core business of NITE. The August 1 2012 "glitch" proved my allegations that Knight was insolvent. Knight had to raise virtually the entire "glitch" loss despite claiming to have a "highly liquid balance sheet". The accounting fraud is a result of the illegal naked shorting. The SEC,Handler,Jefferies et al "glitch" and bailout wasn't JUST a cover up of a massive SEC failure to protect the investing public however. The 2012 "glitch" was the first of many cover ups so that this massive fraud on the public can continue. Per previous correspondence and the extensive record with the SEC: As with the "glitch" ALL participants KNEW exactly the NITE core business and accounting fraud at NITE in 2017 had not changed. As the record clearly shows: NITE was engaged in abusive naked shorting OTCM (and other) money laundering shells immediately prior to the VIRT/KCG merger closing. Many of the same players in the 2017 "glitch" as the 2012 "glitch". JPM,GS,JEF/Handler, and Jay Clayton Sull Crom colleague Jared Fishman. How did the VIRT/KCG merger get approved in the face of the overwhelming evidence I provided? The same way the 2013 Knight/Getco reverse merger got approved: SEC criminal obstruction. In 2017 the SEC,Cifu,Handler wrote down 4 billion+ Naked short fails immediately prior to the VIRT/KCG deal closing. These fraud "assets" were sitting on the KCG balance sheet and used to calculate the grossly inflated tangible book value used in the KCG acquisition price. KCG was grossly insolvent. ALL participants and the SEC knew this. The primary beneficiary of this fraud: Handler/Jefferies. In 1Q2020 I alerted the SEC that absolutely nothing had changed. NITE reported a receivable of 2.5 BILLION+. This was up 90% sequentially. HUGE red flags. No investigation. In 2Q2020 the receivable had fallen by just $100 mil from 1Q. Meaning: The 1Q receivable would have zeroed out within days of March 312020 as is required: settlement Then, the receivable at June 30 was within 100 mil of the March 31 balance. Inconceivable. The March 31receivable was NEVER zeroed out as is required by law. Further, the fails listed as "assets" are a fraud. More accurately: liability. AND there is nothing in the receivable that can be converted into cash for company use. There are prior commitments: settlement. Combine this with the THIRD CFO in a year and you have the makings of ANOTHER "glitch" As I've told the SEC: HFT holdings:seconds. No receivable there. DMM? KCG sold theirs in 2016. So that leaves the VIRT DMM. Even AFTER the massive 2Q2017 Cifu/Handler/SEC write down, the receivable is up more than 6X from the last VIRT stand alone 2Q2017. AGAIN the effects of the core NITE illegal activity. So, what has changed since August 1 2012? Absolutely nothing. This is an ongoing, massive fraud perpetrated on the American people. Well orchestrated by the SEC,Handler/Jefferies,Sull Crom et al. Did Clayton recuse himself from my Award denial? Did Clayton recuse himself from the VIRT/KCG approval? Did Clayton EVER disclose his Sull Crom NITE conflicts? The answer can be found in the very carefully structured complaints against several entities in my 2013 and derivative TCR's: NONE of the activity in these SEC/FINFtA complaints takes place without a willing, executing BD/MM converting worthless certs into real money. Then trader in the space: NITE. Yet, you won't find NITE in ANY of these complaints. As far as the SEC is concerned: :"penny stock trading fairies". The corrupt, criminal SEC/Handler/Jefferies relationship explained. I offer AGAIN to fly to SEC DC HQ or NY Office on my own dime to have the best and brightest at the SEC rip me apart and refute my extremely serious allegations 1 by 1. Bring the SDNY too. Better yet: RE forward my information to Handler,Cifu et al. I know they have already seen it from the SEC. I still have yet to be sued by ANYONE related to my information. The Opco Denial Award is also further evidence of SEC criminal obstruction. A gross mishandling of my information to both bring strategic complaints while protecting the criminal entity NITE. Ms Norberg has created some of the most extraordinary reasons for denying my award. The best so far: "SEC investigators never saw my information". An acknowledgement of SEC criminal Obstruction. It is the job of the OWB exclusively and explicitly to distribute whistleblower information within the SEC. A whistleblower has EFTA00078090 no way of knowing WHO at the SEC is working on a case. Further, despite my request for Norberg to produce the entirety of my extensive record with the SEC, she failed to do so. What was the denial in Opco based on? The SEC, Clayton, Handler, Jefferies, NITE et al ongoing massive fraud on the public must continue. So it does. Mr Kamensky must have my information. This massive fraud on the public MUST end. ALL of it Per the extensive record and my derivative TCR's: It isn't just NITE,Cifu,Handler,Jefferies et al the SEC is protecting. Is it Jane? Regards, Christopher J Dilorio Whistleblower From: Chris Dilorio < > Sent: Tuesday, July 7, 2020 6:09 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Janey, MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of my award application/denial/appeal AND REQUIRED by the statute I have referenced: 240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed. But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not EFTA00078091 confined to Opco,NITE,UBSS,Sason,Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money laundering/transaction laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity. Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill. ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the brain child of Chair Clayton and his SuII Cromm colleague Jared Fishman who has played a key role in keeping the criminal entity NITE/VIRT up and running. NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE? Only another fraud: Mullen. Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership. The K50 EV is manufactured in China by Cdantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US. But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to the SEC: the record: known as SeeThroughEquity https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259.pdf Seethruequity, LLC, Ajay Tandon, and Amit Tandon THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in 2011 by brothers Ajay Tandon and Amit Tandon. www.sec.gov SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018 https://www.netelement.com/press-releases/release-content/1062906tXwRXEOWSnIV EFTA00078092  SeeThruEquity Issues Update on Net Element, Inc. NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE April 2018 Update Note. Net Element Inc. (NASDAQ: NETE, "Net Element") is a global financial www.netelement.com https://www.neteI ement.com/press-releases/release-content/10734671/1.XwRXGuWSnIV SeeThruEquity Issues Update on Net Element, Inc. NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE August 2018 Update Note. Net Element Inc. (Nasdaq CM: NETE, "Net Element") is a global financial www.netelement.com So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone? The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares Act money. A summary of the record. Janey, Hoecker et al, Please update my Net Element and AQR TCR's Cheers! Christopher J Dilorio Whistleblower Not just irony but a massive fraud on the From: Chris Dilorio Sent: Tuesday, June 30, 2020 1:01PM EFTA00078093 Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Janey, the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any more clear: run the clock out and protect NITE,UBSS,Magna et al while denying me rightful compensation. But, As I have repeatedly told you, Hoecker, your colleagues: the last overt act of this vast conspiracy has not yet occurred: NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal, shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the criminal enterprise known as Knight/KCG/VIRT: NITE. Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut down IMMEDIATELY. Certainly not exhaustive BUT a good start Cheers! Christopher J Dilorio Whistleblower From: Chris Dilorio e > Sent: Tuesday, June 30, 2020 7:36 AM EFTA00078094 Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Janey, please add the following info to my appeal of your preliminary denial of my Opco award. More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence to support my allegations. Highlighted in my attached TCR and related to my Opco Award application: Joshie Sason/Hanover/Magna: CGFIA, IMDS,NewLead,FreeSeas, PRTH etc etc etc. The SEC Sason/NewLead complaint is also my information as I filed separate but related NewLead, and FreeSeas TCR's with your office. The SEC complaint: Sason assignments: bogus notes. NO SHIT? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the FINRA World Trade Financial complaint. https://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-anti- money-laundering FINRA Fines Three Firms $900,000 for Inadequate Anti-Money Laundering Programs I FINRA.org WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined three firms a total of $900,000 for failing to establish and implement adequate anti-money laundering (AML) programs and other supervisory systems to detect suspicious transactions. www.finra.org Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA requested information from Keener related to his assignments and acquisition of bogus convertible notes including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off" https://www.finra.org/sites/default/files/OHODecision/p182993 0 0.pdf FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS 5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA EFTA00078095  www.finra.org FINRA barred Keener/JMJ in 2013 as a "Bad Actor" The SEC was certainly aware of the FINRA action https://www.sec.gov/litigation/opinions/2012/34-68014.pdf As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink Charging fka New Image Concepts https://www.sec.gov/cgi-bin/browse-edgar? action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0 https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm EDGAR Filing Documents for 0001144204-19-004046 Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 I State of Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G/A I Act: 34 ... WV:Vi.sec.q ov New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to Keener involvement. https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf Case No. 2:16-cv-03250 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document 1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ... vo.vvy sec g ov But Keener not the only 1 involved who knew New Concept was a money laundering shell. CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days. The SEC revoked the registration of Farkas/Skyway in 2007 https://www.sec.gov/cgi-bin/browse-edga r? action=getcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0 The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction laundering blank check shell: Cazador/Arco: Net Element A director of Blink is a guy named Donald Engel who worked at Drexel with Milken. New Concepts was HQ'd in Santa Monica: Milken But it gets better the Jaclin shell factory also linked to Honig,Stetson,Alpha Cap, Frost as well http://www.teribuhl.com/2019/08/06/honigs-shell-factory-attorney-gregg-jaclin-barred-as-sec-lawm1 EFTA00078096  Honig's Shell Factory Attorney Gregg Jaclin Barred as SEC lawyer - TERI BUHL Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - L.A. Cannabis News on Text messages show Cannabis investors Defrancesco & Serruya allegedly Colluded with Clarus Securities' Christodoulis in Multiple Stocks; High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - www.teribuhl.com Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled Gruntal int Ladenburg. Gruntal: Icahn,Sater,SAC,Feinberg et al: Milken The SEC intentionally omitted a Honig/Stetson shell from this complaint: Millenium Bio/lnergetics linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019. https://www.sec.gov/cgi-bin/browse-edgar? action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0 Finally, SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey, The SEC is going after Keener/JMJ related to my information AGAIN 17.5 BILLION shares of money laundering penny stocks. https://www.sec.gov/litigation/litreleases/2020/Ir24779.htm Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020) wwwsecgov WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering shells???? What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint AND where NITE and UBSS traded billions of shares of CGFIA AND where NITE and UBSS traded billions of shares of IMDS also Now, what are the odds of all of that? All you have to do is read my attached TCR Janey. Cheers! EFTA00078097 Christopher J Dilorio Whistleblower From: Chris Dilorio Sent: Tuesday, June 23, 2020 4:11 PM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix small typos/corrections: Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume data in 1Q2014 and 2Q2014 that were expunged from KCG 10Q SEC filings. Not 2Q2014 and 3Q2014 SEC reviewed 10Q's as I previously stated corrected below Chris From: Chris Dilorio < Sent: Tuesday. June 23. 2020 9:48 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Ms Norberg, I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating EFTA00078098 evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in notifying me. ALL of my response pertains to the denial appeal at hand. In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just $105 mil in working capital at June 30, 2011. AND, for the resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive naked shorting. NITE is still in business TODAY. The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY EFTA00078099 INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to $3 OR $1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure financing is an offer to sell. JPM looked the other way. As did the SEC. Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? 2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal activity. Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS. I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/M