SEC v. Lek Securities Corporation, Samuel Lek, Avalon FA Ltd, Nathan Fayyer and Sergey Pustelnik (layering, 2017)

Judgment entered

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The SEC sued Lek Securities, Samuel Lek, Avalon FA, Nathan Fayyer and Sergey Pustelnik in March 2017 over layering and cross-market manipulation. Lek Securities and Lek settled in October 2019, a jury found against the Avalon defendants in November 2019, and an amended final judgment of February 9, 2021 imposed $7.5 million penalties on each; the Second Circuit affirmed in 2022.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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 10, 2017 as release LR-23776. The respondents named are Lek Securities Corporation, Samuel Lek, Avalon FA Ltd, Nathan Fayyer and Sergey Pustelnik (3 individuals, 2 entities).

This library tags the matter as layering, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

The SEC alleged that Ukraine-based Avalon made more than $21 million from layering in U.S. stocks and over $7 million from a cross-market scheme, and that the New York broker Lek Securities and its CEO enabled it, including by relaxing layering controls. The matter is an allegation at this stage; the court froze Avalon's assets.

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.

Outcome. The SEC reported that on October 1, 2019 Lek Securities and Samuel Lek settled, admitting violations: Lek Securities agreed to a $1 million penalty and $525,892 in disgorgement and interest combined, Sam Lek to a $420,000 penalty, both to injunctions, with a three-year monitor for the firm and associational and penny stock bars for Mr Lek that he may seek to lift after ten years. For the other defendants, a jury found on November 12, 2019 that Avalon, Fayyer and Pustelnik engaged in layering and cross-market manipulation. An amended final judgment entered February 9, 2021 enjoins them and orders each to pay a $7.5 million penalty, and the Second Circuit affirmed it on June 15, 2022. The penalty figure recorded is the sum of the five penalties ($23.92 million); the disgorgement and interest figure for Lek Securities is not split in the source and is not recorded. Checked on 2026-10-04.

Money note: the dollar amounts in this record's text describe the penalties in the 2019 consent judgments and the 2021 amended judgment; to avoid counting the same amounts twice, the money fields are left empty here and the figures are held on the record for the same case under litigation release LR-23923 (sec-lek-securities-corp-et-al-layering-2017).

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.

• Layering — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2017-03-10 Litigation release published
2. 2019-10-01 Lek Securities and Samuel Lek settle (penalties, disgorgement, injunctions)
3. 2021-02-09 Amended final judgment against Avalon, Fayyer and Pustelnik ($7.5 million penalty each); affirmed June 15, 2022

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 on the Lek settlement (LR-24639)
• SEC litigation release on the Second Circuit affirmance (LR-25427)

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 4 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.