Market Manipulation. Search

SEC v. Flyfish Club, LLC (unregistered distributions, 2024)

Settled

Checked against the primary document on October 3, 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 2024 the SEC settled an administrative order against Flyfish Club, LLC for conducting an unregistered offering of NFTs, with a $750,000 civil penalty.

The record

Structured fields for this action, as recorded in our case library.
Agency SEC
Release number 33-11305
Date filed 2024-09-16
Date resolved 2024-09-16
Status settled
Asset class crypto
Criminal parallel No
Defendants Flyfish Club, LLC (entity)
Cited as charged or alleged Securities Act s.5 (statutes and rules cited in the document; not a finding that they were violated)
Techniques Unregistered distributions

What was ordered

Civil penalty
$750k
Disgorgement
—
Prejudgment interest
—
Total relief
$750k
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

On September 16, 2024 the SEC accepted a settlement with Flyfish Club, LLC. The order finds that between August 2021 and May 2022 it sold about 1,600 NFTs to raise roughly $14.8 million for a members-only restaurant, marketing them as investments, without a registration statement, in violation of Securities Act Sections 5(a) and 5(c). It orders a cease-and-desist and a $750,000 civil penalty.

The release number is 33-11305. Earlier versions of this record also tagged it as a chat group pump; the order describes an unregistered NFT offering, not a coordinated buying campaign, and that tag was removed on 2026-09-29.

This library tags the matter as unregistered distributions, based on the conduct the document describes. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

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. 2024-09-16 Administrative proceeding instituted (cease-and-desist)

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.

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

Action Agency Filed Technique Penalty Status
SEC v. Zachary Miller (unregistered distributions, 2026) SEC 2026-03-05 Unregistered Distributions — settled
SEC v. David Hudzik (unregistered distributions, 2025) SEC 2025-12-23 Unregistered Distributions $70k judgment
SEC v. Ongkaruck Sripetch and others (pump and dump, 2025) SEC 2025-06-20 Pump And Dump , Unregistered Distributions $204k judgment
SEC v. Peter Scalise III and The3rdBevco Inc. (unregistered distributions, 2025) SEC 2025-06-17 Unregistered Distributions $236k settled
SEC v. Investview, Inc. (unregistered distributions, 2025) SEC 2025-01-17 Unregistered Distributions $375k settled
SEC v. Tai Mo Shan Limited (unregistered distributions, 2024) SEC 2024-12-20 Unregistered Distributions $36.7m settled

Record added September 10, 2026. submit a correction.