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.
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
| 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 |
| Cited as charged or alleged | Securities Act s.5 |
| Techniques | Unregistered distributions |
What was ordered
- Civil penalty
- $750k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $750k
- Alleged gain
- —
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.
- Unregistered distributions — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
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 |