SEC v. Christopher D. Dougherty, et al. (ponzi schemes, 2019)

Settled

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In April 2019 the SEC charged San Diego investment adviser Christopher Dougherty and three of his companies with a Ponzi scheme involving nonexistent private placements. On 19 August 2022 a California federal court entered a consent judgment against Dougherty ordering $4,751,590 in disgorgement and $563,226 in interest, treated as satisfied by a state restitution order. The three companies' outcomes were not found.

The record

What was ordered

Civil penalty

—

Disgorgement

$4.8m

Prejudgment interest

$563k

Total relief

$5.3m

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 SEC announced the complaint on April 26, 2019 (LR-24461) in the Southern District of California; San Diego prosecutors filed criminal charges. It alleges new investor money paid dividends to earlier investors and Dougherty's expenses, and that farm and real estate investments were commingled into the scheme. The SEC sought injunctions, disgorgement and penalties.

The record named the defendant as "Christopher D. Dougherty, et al."; the four defendants are now listed.

This library tags the matter as ponzi schemes because the document describes it as a scheme paying earlier investors with later investors' money. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

Outcome. A final judgment filed in the Southern District of California on 19 August 2022 records that Dougherty consented to its entry. It enjoins him from the charged antifraud provisions and makes him liable for $4,751,590 in disgorgement and $563,226 in prejudgment interest (total $5,314,816), which the judgment deems satisfied by a restitution order entered on 26 October 2021 in the California state criminal case. This outcome covers Dougherty only; the judgment does not address the three companies, and I did not look for separate judgments against them. The judgment was by consent, so the allegations were not tried.

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

1. 2019-04-26 Litigation release published
2. 2022-08-19 Final consent judgment entered against Christopher Dougherty

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• Final judgment as to Christopher D. Dougherty (SEC-hosted court filing)

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.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.