COMPLAINT
Plaintiff Securities and Exchange Commission (the “Commission”), for its complaint
against Defendant, Samuel Bankman-Fried (“Bankman-Fried”), alleges as follows:
SUMMARY
1. From at least May 2019 through November 2022, Bankman-Fried engaged in a
scheme to defraud equity investors in FTX Trading Ltd. (“FTX”), the crypto asset trading
platform of which he was CEO and co-founder, at the same time that he was also defrauding the
platform’s customers. Bankman-Fried raised more than $1.8 billion from investors, including
U.S. investors, who bought an equity stake in FTX believing that FTX had appropriate controls
and risk management measures. Unbeknownst to those investors (and to FTX’s trading
customers), Bankman-Fried was orchestrating a massive, years-long fraud, diverting billions of
dollars of the trading platform’s customer funds for his own personal benefit and to help grow
his crypto empire.
...
5. But Bankman-Fried did not stop there. Even as it was increasingly clear that
Alameda and FTX could not make customers whole, Bankman-Fried continued to
misappropriate FTX customer funds. Through the summer of 2022, he directed hundreds of
millions more in FTX customer funds to Alameda, which he then used for additional venture
investments and for “loans” to himself and other FTX executives. All the while, he continued to
make misleading statements to investors about FTX’s financial condition and risk management.
Even in November 2022, faced with billions of dollars in customer withdrawal demands that
FTX could not fulfill, Bankman-Fried misled investors from whom he needed money to plug a
multi-billion-dollar hole. His brazen, multi-year scheme finally came to an end when FTX,
Alameda, and their tangled web of affiliated entities filed for bankruptcy on November 11, 2022.
