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Ponzi scheme run through the entity defendant – ostensibly a financial services consulting firm – by the individual defendants, who included the entity’s CEO (also a D.C. public official) and its COO. Defendants offered unregistered “Asset Placement Agreements” to over 150 investors, raising approximately $1.4 million. These investments were misrepresented in various ways, including in the claim that they would be used for civic-minded real estate development. Financial redress took place in defendants’ criminal sentencing.