SEC v. Stephen L. Bailey, Sapphire Exploration LLC, and Harris Exploration Inc. (ponzi schemes, 2023)
Alleged — pending
These are allegations. SEC has filed an action; nothing in it has been proven, and the respondents have not been found liable. Everything described on this page is what the regulator alleges, not what a court has found. See our editorial policy.
Checked against the primary document on October 3, 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.
In September 2023 the SEC charged Stephen L. Bailey, Sapphire Exploration LLC and 1 other. The complaint alleges that Bailey and his two companies raised $7.8 million for oil-and-gas projects and misused $5 million, including $4.1 million for personal expenses and nearly $670,000 for Ponzi-like payments to investors. Officer-and-director and penny-stock bars are sought, not imposed.
The record
| Agency | SEC |
|---|---|
| Release number | LR-25851 |
| Date filed | 2023-09-25 |
| Court | U.S. District Court, Northern District of Texas |
| Status | filed |
| Asset class | equities |
| Criminal parallel | No |
| Defendants | Stephen L. Bailey ; Sapphire Exploration LLC ; Harris Exploration Inc. |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) |
| Techniques | Ponzi schemes |
What was ordered
- Civil penalty
- —
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- —
- Alleged gain
- —
What is alleged to have happened
The Securities and Exchange Commission announced this matter on September 25, 2023 as release LR-25851. The complaint alleges that Bailey and his two companies raised $7.8 million for oil-and-gas projects and misused $5 million, including $4.1 million for personal expenses and nearly $670,000 for Ponzi-like payments to investors. Officer-and-director and penny-stock bars are sought, not imposed.
This library tags the matter as a Ponzi scheme because the document describes returns to earlier investors paid from later investors' money, as alleged or found. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
This matter is at the allegation stage. Nothing in the regulator's filing has been proven, and the respondents are entitled to the presumption that it has not been.
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
- 2023-09-25 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.
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Mark D. Hanf and Hoai-Nam Chu Phan (ponzi schemes, 2026) | SEC | 2026-09-04 | Ponzi Schemes | — | settled |
| SEC v. Leor Moshe, Jacob Goldman, Isaac Odes (ponzi schemes, 2026) | SEC | 2026-08-13 | Ponzi Schemes | — | filed |
| CFTC v. Goliath Ventures, Inc. and Christopher Delgado (ponzi schemes, 2026) | CFTC | 2026-08-11 | Ponzi Schemes | — | filed |
| SEC v. Goliath Ventures, Inc. and Christopher A. Delgado (ponzi schemes, 2026) | SEC | 2026-08-11 | Ponzi Schemes | — | filed |
| SEC v. Aras Investment Business Group S.A.P.I. de C.V. and others (ponzi schemes, 2026) | SEC | 2026-07-24 | Ponzi Schemes | $449k | judgment |
| CFTC v. Trevor L. Vernon and Argent Capital Management LLC (ponzi schemes, 2026) | CFTC | 2026-07-07 | Ponzi Schemes | — | filed |