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by x0x0 2864 days ago
From the sec complaint

> Defendants at all relevant times were investment advisers within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C. ยง 80b-2(a)(11)].

My personal guess: that law makes various actions (self-dealing, lying about what investment funds are being used for, non-arms-length transactions, etc) crimes instead of civil torts.

Plus, you know, just plain fraud.