SEC Charges Former Cco of Investment Adviser Who Misappropriated Funds

Litigation Release No. 25408 / June 2, 2022

Securities and Exchange Commission v. Jennifer Campbell, No. 22-cv-00423 (W.D.N.Y. filed June 2, 2022)

The Securities and Exchange Commission today announced charges against Jennifer Campbell, the former Chief Compliance Officer of a previously registered investment adviser, in connection with Campbell's misappropriation of client funds between February 2019 and May 2021.

The SEC's complaint, filed in federal court in Buffalo, New York, alleges that Campbell misused her access to client accounts to modify account settings, which then allowed her to misappropriate funds from client accounts through fraudulent checks and wire transfers. According to the complaint, Campbell also executed unauthorized securities transactions to generate cash that she then misappropriated. The complaint further alleges that Campbell went to great lengths to avoid detection, including creating fake documents, hacking into her colleagues' email accounts, and even using voice-altering software to impersonate her colleague on the phone. As alleged in the complaint, in total, Campbell misappropriated approximately $483,000 from a number of client accounts, including those related to elderly individuals and deceased individuals who had left assets in trusts.

The SEC's complaint charges Campbell with violations of Section 17(a)(1) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934, and Rules 10b-5(a) and (c) thereunder, and with aiding and abetting violations of Sections 206(1) and 206(2) of the Investment Advisers Act of 1940. The complaint seeks permanent injunctive relief, disgorgement plus prejudgment interest, and civil penalties.

The U.S. Attorney's Office for the Western District of New York announced parallel criminal charges against Campbell, charging her with wire fraud and aggravated identity theft.

The SEC's investigation was conducted by Nicholas Karasimas and Sandeep Satwalekar in the New York Regional Office. The litigation will be led by Mr. Satwalekar and Mr. Karasimas. The case is being supervised by Thomas P. Smith, Jr. The SEC appreciates the assistance of the United States Attorney's office for the Western District of New York and the Federal Bureau of Investigation.