Market Manipulation. Search

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.

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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

Structured fields for this action, as recorded in our case library.
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 (individual) ; Toltec Capital LLC (entity)
Cited as charged or alleged Advisers Act s.206 ; Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.5 (statutes and rules cited in the document; not a finding that they were violated)
Techniques Ponzi schemes

What was ordered

Civil penalty
$2.2m
Disgorgement
$2.2m
Prejudgment interest
$151k
Total relief
$4.6m
Alleged gain
—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

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.

Timeline

  1. 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.

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

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)(this record) Judgment entered

This grouping is the library's, made by matching names, techniques, dates and citations when the site is built. It is not the regulator's or a court's determination that the records are one case, and it errs towards missing a link rather than making a false one.

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

Record added September 10, 2026. submit a correction.