SEC v. PTG Capital Partners LTD, et al. (sham tender offers, 2015)
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.
The SEC's June 2015 case over false tender offers filed on EDGAR for Avon, Tower Group and Rocky Mountain Chocolate ended on 2 March 2020 in the Southern District of New York. Two entities settled and Nedko Nedev took a default judgment. Penalties total $1,470,000, with $30,479 in disgorgement and $789.44 in interest, and the SEC dropped the two named shell entities as fictitious.
The record
| Agency | SEC |
|---|---|
| Release number | LR-23301 |
| Date filed | 2015-07-10 |
| Date resolved | 2020-03-02 |
| Court | U.S. District Court, Southern District of New York |
| Status | judgment |
| Criminal parallel | No |
| Defendants | PTG Capital Partners LTD ; Nedko Nedev ; Strategic Capital Partners Muster Limited ; Strategic Wealth Investments, Inc. |
| Techniques | EDGAR filing fraud , Sham tender offers |
What was ordered
- Civil penalty
- $1.5m
- Disgorgement
- $30.5k
- Prejudgment interest
- $789
- Total relief
- $1.5m
- Alleged gain
- —
What is alleged to have happened
The Securities and Exchange Commission announced this development on July 10, 2015 as litigation release LR-23301, in civil action 15-CV-04290 in the Southern District of New York. The release names Nedko Nedev, Strategic Capital Partners Muster Limited and Strategic Wealth Investments, Inc.; the caption also names PTG Capital Partners LTD, and the release says there are other defendants.
The complaint, filed on June 4, 2015, alleges that the defendants posted false tender offers for Avon Products, Tower Group International and Rocky Mountain Chocolate Factory on the SEC's EDGAR database and issued a fraudulent press release, hoping to drive up prices so they could sell positions that had been losing value. This release reports a ruling on July 7, 2015: Judge Kaplan granted the SEC's preliminary injunction motion in part against the two Strategic companies, made findings against them, and continued a freeze of more than $2 million in their brokerage accounts. The temporary restraining order against Nedev was extended, with further proceedings set for September 10, 2015.
On 2 March 2020 the court approved consent judgments against Strategic Capital Partners Muster Limited ($28,079 in disgorgement, $716.59 in interest and a $500,000 penalty) and Strategic Wealth Investments, Inc. ($2,400, $72.85 and a $500,000 penalty) and entered a default judgment against Nedko Nedev with a $470,000 penalty and an injunction. Frozen brokerage balances were directed to the SEC against the Strategic judgments. The SEC had dropped the two named shells, PTG Capital Partners LTD and PST Capital Group LTD, saying they were fictitious. The totals stored here add the three judgments. The two entities settled without admitting or denying the allegations; Nedev's liability was decided on a default, not after contested proof.
For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.
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.
- EDGAR filing fraud — see how it works, what statute it engages, and every other action tagged the same way.
- Sham tender offers — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2015-07-10 Litigation release published
- 2020-03-02 Judgments entered against Strategic Capital, Strategic Wealth and Nedev (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 24766
- Default judgment as to Nedko Nedev
- Final judgment as to Strategic Capital Partners Muster Limited
- Final judgment as to Strategic Wealth Investments, Inc.
Same matter
The library links these 3 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.
| Date filed | Agency | Record | Status |
|---|---|---|---|
| 2015-07-10 | SEC | SEC v. PTG Capital Partners LTD, et al. (sham tender offers, 2015) | Judgment entered |
| 2016-03-11 | SEC | SEC v. PTG Capital Partners LTD, et al. (sham tender offers, 2016) | Judgment entered |
| 2020-03-11 | SEC | SEC v. PTG Capital Partners, Ltd. (sham tender offers, 2020) | Judgment entered |
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Lee Simmons (price manipulation, 2022) | SEC | 2022-08-19 | EDGAR Filing Fraud , Price Manipulation +1 | $223k | judgment |
| SEC v. PTG Capital Partners, Ltd. (sham tender offers, 2020) | SEC | 2020-03-11 | EDGAR Filing Fraud , Sham Tender Offers | $1.5m | judgment |
| SEC v. Mark E. Burns (price manipulation, 2019) | SEC | 2019-08-12 | EDGAR Filing Fraud , Price Manipulation +1 | $60k | judgment |
| SEC v. Mark E. Burns, Robert W. Murray (price manipulation, 2018) | SEC | 2018-07-17 | EDGAR Filing Fraud , Price Manipulation +1 | — | settled |
| SEC v. Nauman A. Aly (sham tender offers, 2018) | SEC | 2018-03-28 | EDGAR Filing Fraud , Sham Tender Offers | — | judgment |
| SEC v. Robert W. Murray (sham tender offers, 2018) | SEC | 2018-03-22 | EDGAR Filing Fraud , Sham Tender Offers | — | settled |