SEC v. Gregory W. Gray, Jr., et al. (ponzi schemes, 2015)

Settled

✓ 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.

Report an error in this record (sec-gregory-w-gray-jr-et-al-ponzi-schemes-2015) by email

In February 2015 the SEC charged Buffalo fund manager Gregory W. Gray, Jr. and his firms Archipel Capital LLC and BIM Management LP with a Ponzi-like scheme around a pre-IPO Twitter fund, and froze assets. On January 10, 2017 the court entered consent judgments against all three: injunctions and $7,894,100 in disgorgement with $140,255.19 in interest, deemed satisfied by the criminal forfeiture and restitution orders. Gray was sentenced to 24 months in the parallel criminal case.

The record

What was ordered

Civil penalty

—

Disgorgement

$7.9m

Prejudgment interest

$140k

Total relief

$8m

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 Securities and Exchange Commission announced this matter on March 27, 2015 as release LR-23221, a later notice in a case filed February 27, 2015 in the Southern District of New York. This library tags the matter as ponzi schemes, based on the conduct the SEC describes; the tagging is ours, not the regulator's.

The SEC's complaint alleged that Gray raised nearly $5.3 million for a fund to buy pre-IPO Twitter shares, bought too few shares, and paid investors in that fund with money taken from three unrelated funds, mostly from one investor who was told he had bought a fund holding Uber stock that Gray had not purchased.

Outcome. SEC litigation release 23717 (January 12, 2017) says Judge Lewis Kaplan entered judgments on January 10, 2017, on the consent of Gray, Archipel Capital LLC and BIM Management LP, without admission or denial. They are permanently enjoined from violating Securities Act section 17(a), Exchange Act section 10(b) and Rule 10b-5, and Advisers Act sections 206(1), 206(2) and 206(4), and must pay disgorgement of $7,894,100 plus prejudgment interest of $140,255.19, jointly and severally. The release says that obligation is deemed satisfied by the $5 million forfeiture and restitution orders in the parallel criminal case, United States v. Gray, where he pleaded guilty to securities fraud and perjury on December 23, 2015 and was sentenced on October 25, 2016 to 24 months. The release also says the court approved a plan to distribute funds to investors. The complaint named relief defendants whose outcome we did not check; this outcome covers Gray, Archipel and BIM.

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. 2015-03-27 Litigation release published
2. 2017-01-10 Consent judgments entered against Gray, Archipel and BIM (S.D.N.Y.)

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 23717 (consent judgments)

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.

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.

Related actions

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

Record added September 10, 2026. submit a correction.