How about transactions made by non-residents, like people trading from outside US. They can transfer out the fund long before SEC can get to it and conclude the investigation.
The regulatory system relies on leveraging financial institutions such as the brokers themselves to do the snitching.
So they may voluntarily freeze funds. But even if they don't there is another layer:
Administrative law judges.
These are employees at the federal agencies that are imbued with the power of the judicial branch and rubber stamp injunctions and "emergency asset freeze" orders from their bosses. And by boss I mean the private sector such as FINRA.
So typically the funds get frozen AND the SEC files charges against non-residents. They can get you in most places on the planet, and also wait till you go on vacation to most places on the planet.
that's only ability in theory. Besides I don't think SEC can "get you in most places on the planet". First they are only a civil agency and it would be a civil charge. Second, they cannot easily get you in most places, and they won't spend the effort and money to do that even if it becomes criminal charge.
they often co-file with the department of justice to get the criminal charges
secondly the indictments leverage financial institutions as well as other federal agencies to be notified when a person - even foreign - is in their grasp or has known whereabouts
SEC indictments are often pretty ballsy. I read one where they indicted people in Eastern Europe who only traded on a CFD exchange. CFD exchanges don't exist in the United States. But the SEC said the traders should have known that the CFD broker would have made actual trades in the US equities markets due to their actions so therefore they have to answer for it.
What became of that? Maybe nothing just like you said
The regulatory system relies on leveraging financial institutions such as the brokers themselves to do the snitching.
So they may voluntarily freeze funds. But even if they don't there is another layer:
Administrative law judges.
These are employees at the federal agencies that are imbued with the power of the judicial branch and rubber stamp injunctions and "emergency asset freeze" orders from their bosses. And by boss I mean the private sector such as FINRA.
So typically the funds get frozen AND the SEC files charges against non-residents. They can get you in most places on the planet, and also wait till you go on vacation to most places on the planet.