Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu
gems

Can Precious Gem Buying Being Securities Fraud?

Posted on November 21, 2025November 20, 2025 by Doug Cornelius
Print Friendly, PDF & Email

As Matt Levine says, “Everything is Securities Fraud“.

Michael G. Hull, Christopher J. Nohl, Greenpoint Asset Management II LLC, Chrysalis Financial LLC, Bluepoint Investment Counsel LLC, Greenpoint Tactical Income Fund LLC, and Greenpoint Rare Earth Trading Account LLC all got sued by the Securities and Exchange Commission for securities fraud back in 2020. The heart of the action was that they  fraudulently inflated returns on investments in an illiquid portfolio of gems, minerals, and private equity.

Just owning previous gems is not going to get you subject to SEC jurisdiction. But selling interest in a fund that purports to own precious gems is going to get you subject to jurisdiction. If you are wildly overstating the value of those gems to raise money and charge management fees, you are committing securities fraud.

The SEC complaint puts the group’s own words against them by noting that the investment materials call it a securities offering.

“As of June 30, 2018, Greenpoint Tactical Income Fund reported assets with a cost basis of $40.1 million and a fair market value of $135.3 million. These purported remarkable returns were derived primarily from two sources. The Fund reported that as of June 30, 2018, its collection of gems and minerals was worth $68.3 million, composed of $21.9 million in original cost and $46.4 million in unrealized gains. The Fund also reported that its shares in Amiran were worth $46.2 million, similarly composed of $9 million in original cost and $37.2 million in unrealized gains.”

According to the SEC, the shares of Amarin were worthless because the company was defunct. They also claimed the value of the gems were wildly overstated.

A jury agreed and judge made a final judgment against them.

Sources:

  • Court Orders Managers of a Wisconsin Investment Fund and Their Related Entities to Pay Over $27 Million Following Jury Trial Verdict
  • SEC Complaint
  • Final Judgment
  • Jury Verdict

Share this:

  • Print (Opens in new window) Print
  • Share on Facebook (Opens in new window) Facebook
  • Share on LinkedIn (Opens in new window) LinkedIn
  • Share on X (Opens in new window) X
  • Email a link to a friend (Opens in new window) Email

Leave a ReplyCancel reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Search for Stuff

Recent Stories

  • No Insider Trading Too Small
  • Cancel-Rebill and Screw Your Clients
  • New Risk Alert on Investment Adviser Annual Compliance Reviews
  • When Compliance Says “Do It”, But the Firm Doesn’t
  • Extending Compliance Dates for Form PF
  • The Massive Scope of Digital Asset Investment Scams
  • SEC Proposes Rescission of Political Contribution Rule for Investment Advisers
  • Is Failure to Disclose Misappropriation Committing Securities Fraud?
  • SEC Sweep of Fake Form ADV Filers
  • New Custody Rule Is On Its Way

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.

© 2026 Compliance Building | Powered by Superbs Personal Blog theme