The Securities and Exchange Commission has filed charges against 38 entities it says submitted fraudulent registration forms to pose as legitimate US investment advisers. The goal, according to the SEC, was straightforward: exploit the credibility of official regulatory filings to win the trust of retail investors who had no reason to question a firm that appeared in the SEC’s own database.

The scheme behind the filings

The SEC’s complaints, initially filed on November 13, 2025, target a group of entities that submitted Forms ADV containing material misrepresentations. Among the six entities named in early civil actions were Bluesky Eagle Capital Management Ltd., Supreme Power Capital Management Ltd., AI Financial Education Foundation Ltd., AI Investment Education Foundation Ltd., Invesco Alpha Inc., and Adamant Stone Limited.

These firms claimed to have US offices in cities like New York and Denver. They reported assets under management ranging from $1M to $10M. They fabricated advisory roles and client relationships wholesale.

The broader investigation reveals these entities were not operating independently. According to the SEC, the scheme is linked to an alleged conspiracy orchestrated by Guanhua Su, a Hong Kong resident who was indicted around the same time. Su is accused of creating at least 10 shell companies between February 2023 and March 2025, all of which submitted fraudulent filings to the SEC.