Fw: Formal appeal for preliminary denial covered action 2015-0161

C

To

Mr Arp

Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring complaints AND obstruct complaints while denying me compensation. In short: My information exposes an ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has chosen to cover up so that the illegal activity can continue. It does in 2020 Chris

C

To

Mr Arp

As straightforward as it gets:

The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice. The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna. The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10O in 2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the massive fraud taking place continued well into 2020. The 1Q2020 10O proves this. The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive ,ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY.

In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal investigation OR a GAO investigation.

You are incorrect in your analysis.

I Urge the IG Integrity Board to have SEC IG Hoecker refute my claims point by point.

I will be on a plane tomorrow so he can do it in person.

EFTA00078155

Cheers!
Christopher 1 Dilorio
Whistleblower

C

To

Mr Roach

Mr Roach,

The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying me rightful compensation. This is the latest example

Chris

C

To

Ms Norberg

Ms Norberg,

I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating

evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in notifying me. ALL of my response pertains to the denial appeal at hand.

In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just $105 mil in working capital at June 30, 2011. AND, for the resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive naked shorting. NITE is still in business TODAY.

The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY

INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to $3 OR $1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure financing is an offer to sell. JPM looked the other way. As did the SEC.

Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? 2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal activity.

Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of IMDS at .0001when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS.

I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover. Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ. AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved

the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell.

Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff: Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on steroids. Cereplast ended in bankruptcy.

NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami, Apockinas/Grinshpun/Antonov/RakisheviTrump/Kushner/SBNY/CardWorks/Merrick Bank/ESCt/Cohen etc etc etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer money then announcing it was "unlocking the value in its misunderstood payment processing business" by doing a reverse merger with a CA electric car company started by a former musician. The payment processing business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and somehow settled on "mobile app developer" Austin TX: Phunware. PHUN CEO is well known to the SEC with shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the "genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional, Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings. Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was "securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office. Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the PHUN/Trump/Kushner/Parscale mobile app technology.

Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also transaction/money laundering like NETE. Also involved: Hanover/Magna.

ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity. SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease. This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT. Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born. But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer. Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still "IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and IM0S. The SEC response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In

1Q2020, the receivable at NITE/VIRT increased $1.2 BILLION sequentially. Up almost 90%. AND the tangible book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency. Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include: Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years: what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg: Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank ($50 bil Bad Bank to Goldman). Another Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal: Feinberg,SAC,Icahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by Vector/NewValley:Icahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis, Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black: HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an Epstein money laundering vehicle: JUNK IS JUNK.

THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal obstruction.

SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 312017. Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate Cifu/Coleman/Handler/GS/JPM wrote down more than $4 billion in open naked short fails: "leverage". The SEC let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT grossly OVER paid for insolvent KCG.

Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014 10Q was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not. This portion of the KCG 1Q2014 10O was expunged as well as 2Q2014 OTCM share volumes. I have detailed this to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG.

The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including: management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust: "worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies. Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming Messenger also receiving taxpayer Cares Act money.

Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr) also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint. OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation HOW? According to stories: activity peaked in 1H2014. Coinciding with NITE astronomical OTCM 1Q2014 share volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's. Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR: P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that. Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint. This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells: $850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint. As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them. That was the last I heard from them although I continued to send them my information.

To the SEC IG Carl Hoecker: In 2015 I parted ways with Berger as I was convinced the SEC was using my information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an award application for the UBS Reg Sho complaint. In my submission and my correspondence with Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting

publicly traded shells and money laundering. My application was denied and there was no investigation into this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to obstruct.

I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM,CS, and DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures. Cifu refused to publish KCG 2O2017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 I have never been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes, there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing Audrey Strauss/Trump/Barr don't you think? The SEC needs some fixers. Wonder why.

I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated conspiracy has not occurred yet.

Cheers!
Christopher J Dilorio
Wistleblower