SEC v. Gomes et al. (unregistered distributions, 2020)
Judgment entered
Checked against the primary document on October 4, 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.
Judgments have now been entered against all eleven defendants in the microcap case, the last a consent judgment against Shane Schmidt on July 17, 2026. Individual defendants consented to injunctions and in several cases penny stock bars, while the five offshore entities were hit with default judgments totaling $12.9 million.
The record
| Agency | SEC |
|---|---|
| Release number | LR-24839 |
| Date filed | 2020-06-18 |
| Date resolved | 2026-07-17 |
| Status | judgment |
| Asset class | equities |
| Criminal parallel | Yes: charged (Schmidt), District of Massachusetts |
| Bars imposed | penny stock bar |
| Defendants | Nelson Gomes ; Michael Luckhoo-Bouche ; Douglas Roe ; Kelly Warawa ; Shane Schmidt ; FFS Capital Limited ; Atlantean Management Corporation |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Exchange Act s.13(d) and 13(g) ; Securities Act s.17(a) ; Securities Act s.5 |
| Techniques | Unregistered distributions |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- $25m
What is alleged to have happened
On June 18, 2020 the SEC announced an emergency action filed June 9 in Massachusetts, alleging a scheme that generated more than $25 million from illegal sales of microcap stock including Sandy Steele, WOD Retail, Bioscience Neutraceuticals and Rivex Technology. Nelson Gomes, Michael Luckhoo-Bouche and others allegedly hid control persons' identities, with COVID-19 promotions in some cases. Charges include Securities Act Sections 5(a) and 5(c) against Gomes, Luckhoo-Bouche, Roe, Warawa, FFS Capital Limited and Atlantean Management Corporation. These are allegations. Only some of the eleven defendants are named in the release.
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.
Outcome. SEC releases show the case ended in stages: default judgments on December 4, 2020 against five entities for a combined $12,895,750 in penalties, disgorgement and interest; a consent judgment on May 26, 2021 against Michael Luckhoo-Bouche ($20,000 penalty, five-year penny stock bar); against Nelson Gomes on September 9, 2021 ($1,153,058 disgorgement and interest, $390,094 penalty, five-year penny stock bar); against Douglas Roe, Atlantean Management and Kelly Warawa in 2022, with penalties of $248,435, $300,000 and $9,190 plus disgorgement; and on July 17, 2026 against Shane Schmidt ($15,802 disgorgement deemed satisfied by a criminal forfeiture, with a penny stock bar). The July 2026 release calls the litigation complete. The money fields stay empty because the figures mix penalties with combined disgorgement and interest and some are deemed satisfied.
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
- 2020-06-18 Litigation release published
- 2020-12-04 Default judgments entered against five entity defendants
- 2021-09-09 Final consent judgment entered against Nelson Gomes
- 2026-07-17 Final consent judgment entered against Shane Schmidt; SEC calls litigation complete
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
- SEC litigation release 24979 (entity default judgments)
- SEC litigation release 25100 (Luckhoo-Bouche judgment)
- SEC litigation release 25200 (Gomes judgment)
- SEC litigation release 25563 (Roe, Atlantean, Warawa judgments)
- SEC litigation release 26588 (Schmidt judgment, case complete)
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 |