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<table border="1"><tr><td>soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct complaints/deny whistleblower rightful compensation.</td></tr><tr><td>Cheers!</td></tr><tr><td>Christopher J Dilorio</td></tr><tr><td>Whistleblower</td></tr></table>

From: Chris Dilorio <

**Sent:** Tuesday, April 28, 2020 6:43 AM



Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix

More evidence of SEC fraud on the court in Gibraltar.

It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action. The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity? The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed a fraud on the court in Gibraltar. Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011. https://www.pr.com/press-release/355246

## Gibraltar Global Securities Now Offering Offshore Brokerage Accounts - PR.com

Nassau, Bahamas, The, September 22, 2011 --()-- Gibraltar Global Securities is now offering offshore brokerage accounts in addition to their broad array of financial services.Gibraltar Global ...



www.pr.com



## https://www.pr.com/press-release/355247

## GGSI Bahamas is Now Offering Pink Sheet Clearance

Offshore Broker Adds to Buying and Selling Services



www.pr.com



https://www.pr.com/press-release/369649

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# GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions and Communication

GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures designed to protect their client&rsquo;s personal data, and to secure electronic communication.



www.pr.com



The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT.

Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS. 2 criminal entities bailed out by the SEC.

Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015-016: "The investigators never saw the claimants information".

WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on the OWB itself.

More criminal activity.

Criminals bailing out criminals while denying Whistleblowers due process and compensation.

Cheers!

Christopher J Dilorio

Whistleblower

From: Chris Dilorio <

**Sent:** Sunday, April 26, 2020 9:36 AM

Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix



Subject: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix

I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015-016

This is my formal appeal of the SEC preliminary determination.

My award application was based on this very simple FACT:

The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action



FINRA





https://www.finra.org/sites/default/files/fda_documents/2009018668801_FDA_KMX39652.pdf



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This is a simple Markdown document with no headings or paragraphs. It contains just one line of text.



of - FINRA


which isFINRA a party, to the entry of findings and violations consistent with the allegations of the (asComplaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ...



www.finra.org



## The SEC

https://www.sec.gov/litigation/admin/2015/33-9711.pdf

## Before the SECURITIES AND EXCHANGE COMMISSION

Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 / January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 .

ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE PROCEEDING . File No. 3 -16361 . In the Matter of



www.sec.gov



## FINCEN

https://www.fincen.gov/news/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-anti-money-laundering

## FinCEN Fines Oppenheimer & Co. Inc. $20 Million for Continued Anti-Money Laundering Shortfalls | FinCEN.gov

Washington, D.C. – The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S. Securities and Exchange Commission (SEC), assessed a $20 million civil money penalty today against Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities broker-dealer in New York, admitted that it failed to establish and implement an adequate ...



www.fincen.gov



In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also cc'd Sean McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In fact, per the FINRA Opco complaint above, customer "TC" was dumping worthless AppTech (APCX) certificates well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share

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my information with SEC investigators? Current SEC OWB Chief Norberg was previously an assistant to then OWB Chief McKessy.
WHO ultimately executed the trades cited in the FINRA Opco complaint?
Further, the SEC Gibraltar Securities complaint raises more questions than answers as well.
https://www.sec.gov/litigation/complaints/2013/comp22683.pdf

## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov

12. David Della Sciucca, Jr., age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or complaint, the Commission charged Della Sciucca with acting as a nominee



www.sec.gov



The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing BD/MM.

The SEC Oppenheimer AML cites Gibraltar trading activity also.

The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY?

The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants ill-gotten gains..."



http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/



## Bahamian broker in $25m sanction | The Tribune

A former Bahamian broker/dealer and its principal have been hit with a combined $24.484 million in financial sanctions by a US court, which found that their "ill gotten gains" were likely ...



www.tribune242.com



WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out" $46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its OMISSION of material information?

The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions than answers.

My Award application for the Oppenheimer AML SEC complaint was 5 years ago. That's FIVE years ago. So, WHY NOW am I so blessed by the SEC with a preliminary judgement?

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