↓ Skip to Main Content
SEC ACTIONS
  • Home
  • Articles
  • Archives
  • Media
  • Related Links
  • About
  • Subscribe to our Mailinglist
Home › SECActions ›

Proceeds of Offering Fraud Used to Acquire Tropical Fish

Proceeds of Offering Fraud Used to Acquire Tropical Fish

T. GormanPosted on October 04, 2023 Posted in SECActions

As the Government fiscal year drew to a close last week the Commission put on what can only be called an incredible show, filing over 50 new enforcement actions in one week. That is more cases than the agency at times files in one month. Equally incredible is the fact that over 20 different types of cases were filed. The entire week was an achievement.

Now, however, the pace of filing new cases has slowed too normal. This week one of the more notable cases filed is an offering fraud action. In this action Defendants were able to raise over $2 million supposedly for investments but actually diverted to their personal use for a variety of endeavors including the acquisition of tropical fish, perhaps a first. SEC v. Zera Financial LLC, Civil Action No. 8:23-cv-01807 (C.D. Cal. Filed September 27, 2023).

The case names as defendants the firm, a California based entity, and Luis Romero, the CEO, sole owner and control person of Zera. Since the beginning of 2021 Defendants have raised over $2.2 million from about 170 investors. Those investors were solicited through a website, Instagram, a mobile application and word of mouth.

The sales pitch was straight forward – good investment returns were promised. The website challenged investors with slogans such as “See How Much You Can Make.” The promise was 3% interest every month.

Defendants offered three different programs. One was for 6 months for an investment of $500 to $15,000; a second was for one year for investments of $15,000 to $100,000; and the third was for two years if the investment was over $100,000. The interest from each program could be withdrawn and redeposited each month. The principal investment could not be withdrawn until the end of the term. The deposits were, according to the sales pitch, FDIC insured.

Investor funds were deposited in crypto asset accounts. Some portions of the investor cash were used to make Ponzi type payments. Others were diverted to the personal use of Mr. Romero. He used substantial sums of investor capital to pay his personal expenses, purchase an electric truck and of course, tropical fish. The complaint alleges violations of Exchange Act Section 10(b), and Securities Act Section 17(a). The case is in litigation. See Lit. Rel. No. 25878 (October 3, 2023).

Print 🖨 PDF 📄
‹

This Week In Securities Litigation (Week of October 2, 2023)

Musk and the SEC – At Battle Again

›
Tagged with: offering fraud, SEC

Search SEC Actions

Prepared:

Thomas O. Gorman

DC Attorney specializing in securities
and other agency litigation

Former SEC Senior Counsel, Enforcement
and Special Trial Counsel, GC Office
    © 2025 SEC ACTIONS
    • Subscribe to our Mailinglist
    Manage Cookie Consent
    To provide the best experiences, we use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us to process data such as browsing behavior or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.
    Functional Always active
    The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
    Preferences
    The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
    Statistics
    The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
    Marketing
    The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
    Manage options Manage services Manage {vendor_count} vendors Read more about these purposes
    View preferences
    {title} {title} {title}