SEC v. Bernardo Mendia-Alcaraz and Toltec Capital LLC (ponzi schemes, 2026)
Judgment entered
Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In 2026 the SEC announced a final judgment against Bernardo Mendia-Alcaraz and Toltec Capital, who made Ponzi-like payments to investors, holding them liable for $2,207,524 of disgorgement and $150,866 of interest, with a $2,207,524 civil penalty on Mendia-Alcaraz.
The record
| Agency | SEC |
|---|---|
| Release number | LR-26457 |
| Date filed | 2026-01-06 |
| Date resolved | 2026-01-06 |
| Court | U.S. District Court, Northern District of California |
| Status | judgment |
| Criminal parallel | No |
| Defendants | Bernardo Mendia-Alcaraz ; Toltec Capital LLC |
| Cited as charged or alleged | Advisers Act s.206 ; Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.5 |
| Techniques | Ponzi schemes |
What was ordered
- Civil penalty
- $2.2m
- Disgorgement
- $2.2m
- Prejudgment interest
- $151k
- Total relief
- $4.6m
- Alleged gain
- —
What is alleged to have happened
The complaint alleged that the defendants raised about $3.3 million with false statements and used investor money for Ponzi-like payments to other investors and for personal expenses. Relief defendants Fondo Toltec and Ramirez Cano are liable for parts of the disgorgement.
The record carried the disgorgement and interest but no penalty; the release states that the judgment orders Mendia-Alcaraz to pay a civil penalty equal to the disgorgement.
This library tags the matter as ponzi schemes because the document describes money from later investors being used to pay earlier ones. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
What technique is this, and how does it work?
This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.
- Ponzi schemes — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2026-01-06 Litigation release published
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Same matter
The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.
| Date filed | Agency | Record | Status |
|---|---|---|---|
| 2024-08-28 | SEC | SEC v. Bernardo Mendia-Alcaraz and Toltec Capital LLC (2024) | Judgment entered |
| 2026-01-06 | SEC | SEC v. Bernardo Mendia-Alcaraz and Toltec Capital LLC (ponzi schemes, 2026) | Judgment entered |
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Mark D. Hanf and Hoai-Nam Chu Phan (ponzi schemes, 2026) | SEC | 2026-09-04 | Ponzi Schemes | — | settled |
| SEC v. Leor Moshe, Jacob Goldman, Isaac Odes (ponzi schemes, 2026) | SEC | 2026-08-13 | Ponzi Schemes | — | filed |
| CFTC v. Goliath Ventures, Inc. and Christopher Delgado (ponzi schemes, 2026) | CFTC | 2026-08-11 | Ponzi Schemes | — | filed |
| SEC v. Goliath Ventures, Inc. and Christopher A. Delgado (ponzi schemes, 2026) | SEC | 2026-08-11 | Ponzi Schemes | — | filed |
| SEC v. Aras Investment Business Group S.A.P.I. de C.V. and others (ponzi schemes, 2026) | SEC | 2026-07-24 | Ponzi Schemes | $449k | judgment |
| CFTC v. Trevor L. Vernon and Argent Capital Management LLC (ponzi schemes, 2026) | CFTC | 2026-07-07 | Ponzi Schemes | — | filed |