Fund Manager Caught Freezing Investor Assets for YEARS!

SEC v. Jeremiah Silkowski and SQN Capital Management LLC — U.S. Securities and Exchange Commission Litigation Release No. 26671, dated October 9, 2026.

SQN Capital Management LLC and its CEO, Jeremiah Silkowski, were charged by the SEC for defrauding investors in four funds. They allegedly inflated fund asset values, failed to conduct required audits, and misled investors about liquidation efforts. Both defendants settled the charges, agreeing to permanent injunctions, an order appointing a receiver, and a $200,000 penalty against Silkowski.

In Plain English

Imagine you invested in a special savings account managed by a company. The company promised to keep track of your money and get you a good return. Instead, they secretly inflated the value of the investments, didn't get them checked by an accountant like they said they would, and lied about when you could get your money back. The government stepped in to stop them and get a manager to try and return what's left to investors.

Disclaimer: all facts are drawn from the SEC's own filings; the claims described are allegations unless and until a court rules or the parties settle, and some cases end in dismissal.

How the Alleged Scheme Worked

1. Misrepresenting Fund Operations Jeremiah Silkowski and SQN Capital Management LLC, managing four investment funds, failed to follow the funds' governing documents. They did not engage accounting firms to conduct annual audits or even prepare unaudited financial statements that followed Generally Accepted Accounting Principles (GAAP).
2. Inflating Asset Values Silkowski prepared all asset valuations himself, contrary to representations that an independent expert was involved. He materially inflated these values by keeping net asset values unchanged for years, ignoring actual asset performance, market conditions, or whether assets were still held.
3. Deceiving Investors on Liquidation Silkowski repeatedly misled fund investors about the progress of liquidating fund assets. He falsely claimed the process would soon be completed, without disclosing that market conditions prevented sales and that SQN Capital lacked the resources to finish, leaving investors in limbo.
4. Ignoring Audit Requirements The defendants repeatedly violated the custody rule (Rule 206(4)-2) and the compliance rule (Rule 206(4)-7) by failing to deliver audited financial statements to fund investors. This was a repeat offense, as SQN Capital had been charged for the same failures in 2020 and 2023.
5. Continued Violations Despite Past Sanctions Despite previous SEC actions in 2020 and 2023 for failing to deliver audited financial statements, SQN Capital, aided by Silkowski, continued these violations. This pattern of recidivism underscores the defendants' disregard for regulatory requirements and investor protections.

The Enforcement Action

On September 18, 2026, the SEC filed charges against SQN Capital Management LLC and its President, Jeremiah Silkowski, for multiple violations of the Investment Advisers Act of 1940. The defendants settled the charges, and on October 8, 2026, the Court entered consent judgments imposing permanent injunctive relief, ordering Silkowski to pay a $200,000 civil money penalty, and appointing a receiver for the investment funds managed by SQN Capital. Silkowski was also permanently prohibited from acting as or associating with an investment adviser, broker, or dealer, except as necessary to assist the receiver.

Original SEC litigation release ↗ · Browse all cases