(Source: SEC) Respondents paid transaction based
compensation to unregistered broker-dealers, causing the broker-dealers to
violate Section 15(a)(1) of the Exchange Act. Those unregistered broker-dealers,
who were mostly immigration attorneys, represented individuals seeking U.S. residency
through the Immigrant Investor Program and recommended and helped effect the purchases
of securities offered by American Life. For a period of time, Respondents paid transaction-based
compensation to these unregistered broker-dealers for each investment that they
facilitated.
Respondent American Life Shall pay a civil money penalty in
the amount of $1,000,000 to the Securities and Exchange Commission for transfer
to the general fund of the United States Treasury, subject to Exchange Act
Section 21F(g)(3). Read settlement here.
