ADMINISTRATIVE PROCEEDING
File No. 3-19965

September 8, 2020 - The Securities and Exchange Commission today announced settled charges against Alexander S. Gould of Menlo Park, California, for misappropriating funds from a private venture capital fund that he advised.

The SEC's order found that in 2018, Gould, a Silicon Valley venture capitalist and university economics lecturer, misappropriated funds from Goulden Boy LLC, a private venture capital fund that Gould founded and advised. As set forth in the SEC's order, the amount of money that Gould misappropriated exceeded half of the total capital invested in the fund. According to the order, Gould used the misappropriated funds to repay a debt that he owed to another fund he had managed and to pay for other personal expenses, including travel.

The SEC's order finds that Gould violated the antifraud provisions of Sections 206(1) and 206(2) of the Investment Advisers Act of 1940. Without admitting or denying the findings in the SEC's order, Gould agreed to the entry of a cease-and-desist order, an associational bar and investment company prohibition with the right to reapply after five years, and to pay disgorgement of $476,033 plus prejudgment interest and a $200,000 penalty. The Commission also issued an order directing repayment to Goulden Boy's investors.

The SEC's investigation was conducted by Ruth Hawley with assistance from the Office of Market Intelligence and supervised by Jeremy Pendrey and Monique C. Winkler of the SEC's San Francisco Regional Office.