Shiloh Luckey

U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 26424 / November 21, 2025

Securities and Exchange Commission v. Shiloh Luckey, No. 2:25-cv-10026 (C.D. Cal. filed Oct. 20, 2025)

SEC Charges Startup Founder with Fraud

The Securities and Exchange Commission announced today that it filed charges against Shiloh Luckey (formerly Shiloh Johnson), the founder and CEO of technology startup, ComplYant App, Inc., for allegedly fraudulently raising more than $13 million, mostly from venture capital investors, between 2020 and 2023.

The SEC’s complaint alleges that Luckey made false claims to investors about the success of ComplYant’s business, a subscription-based online tax management platform for small to medium businesses. According to the complaint, Luckey painted a rosy picture for investors of ComplYant’s business performance, allegedly telling investors that ComplYant’s monthly revenues had grown from around $2,500 in November 2020 to over $250,000 by September 2022,, and that the company was bringing in dozens if not hundreds of new paying subscribers each month. As alleged by the SEC’s complaint, however, ComplYant only generated on average monthly revenues of about $250 during roughly the same time period and averaged fewer than four new subscribers each month. The SEC’s complaint further alleges that Luckey misrepresented herself to ComplYant’s investors as a licensed CPA. The complaint alleges that, on top of the salary she paid herself, Luckey spent at least $2.2 million of investor funds for her own personal benefit, including funding the purchase of a home, and paying for Super Bowl tickets and a destination wedding in the Caribbean.

The complaint was filed in federal district court in Los Angeles, California, and charges Luckey with violating the antifraud provisions of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities and Exchange Act of 1934 and Rule 10b-5 thereunder. The SEC seeks permanent injunctions, an officer-and-director bar, disgorgement with prejudgment interest, and civil penalties against Luckey.

The SEC’s investigation was conducted by Patricia Pei and Carol Kim, and was supervised by Spencer E. Bendell, of the SEC’s Los Angeles Regional Office. The litigation will be led by Kathryn C. Wanner and supervised by Douglas M. Miller, also of the Los Angeles Regional Office.