SEC v. Vali Management Partners (Avalon FA Ltd), Nathan Fayyer and Sergey Pustelnik (layering, 2022)

Judgment entered

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In 2022, the Securities and Exchange Commission reported an appeals ruling against Vali Management Partners (Avalon FA Ltd), Nathan Fayyer and Sergey Pustelnik. The Second Circuit affirmed a judgment, following a 2019 jury verdict, that the three defendants ran layering and cross-market manipulation schemes producing over $25 million; each was ordered to pay $7.5 million in penalties. Lek Securities and its CEO had settled earlier. The release records a civil penalty of $22.5 million.

The record

What was ordered

Civil penalty

$22.5m

Disgorgement

—

Prejudgment interest

—

Total relief

$22.5m

Alleged gain

$25m

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 June 17, 2022 as release LR-25427. The respondents named are Vali Management Partners (Avalon FA Ltd), Nathan Fayyer and Sergey Pustelnik (2 individuals, 1 entity).

This library tags the matter as layering and spoofing, 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 Second Circuit affirmed a judgment, following a 2019 jury verdict, that the three defendants ran layering and cross-market manipulation schemes producing over $25 million; each was ordered to pay $7.5 million in penalties. Lek Securities and its CEO had settled earlier.

The relief recorded in our data is a civil monetary penalty of $22.5 million. Penalty and disgorgement are distinct: disgorgement returns the gain, while the penalty is punitive. We store them separately so that aggregate figures across the library are not double-counted.

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

Timeline

1. 2022-06-17 Litigation release published

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

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.