SEC Complaint Against New Jersey Fund Operator Illustrates Ponzi Scheme Warning Signs

by Alden Hey and Mark Xiao

On September 10, 2026, The Securities and Exchange Commission (“SEC”) charged a New Jersey fund operator and two companies he controls, alleging that they raised approximately $16 million from more than 200 unsophisticated investors through a Ponzi scheme beginning in January 2020. The complaint alleges misappropriation of more than $5.8 million for the operator’s personal use and Ponzi-like payments of approximately $6.6 million. The allegations remain unproven. This article examines the warning signs the SEC associates with such offerings, how affinity fraud operates within trust networks, and the options that may follow an enforcement action.

What is a Ponzi Scheme?

A “Ponzi scheme” is a form of fraud where an individual or group markets a supposed investment opportunity to customers and, after accepting their money, rather than investing it, uses the money to pay out fraudulent gains to earlier customers or cover their own personal expenses.

Details of the Alleged Scheme

The SEC complaint identifies Ernest Ossei Boateng, and his related business entities, Intercontinental Wealth Network LLC and I Wealth Network LP, as defendants in an alleged fraud scheme.  Boateng allegedly targeted inexperienced investors, many of whom were, like Boateng, part of a group of Christians of Ghanaian heritage who reside in New York and New Jersey (the “Ghanaian Group”) and encouraged them to take out large loans and lines of credit to invest in his scheme. The investors included retirees, students and at least two churches that were planning to use to returns for a church building.

The complaint describes a pattern of Boateng marketing investments as “safe and without risk” and guaranteeing 100% or more in returns in ten years, all under the protection of so-called “financial, investment insurance.”    The complaint also describes how Boateng would forward money to his clients to pay the interest payments on these loans and further promised to pay back the principal when it was due via return on his firms’ investments.  Finally, the SEC claims that, unbeknownst to his investors, Boateng had primarily used the funds to pay fake returns to previous investors and to cover personal expenses like buying his family home.

It is alleged that Boateng failed his Series 6 and Series 63 examinations, making him ineligible to market or sell most common securities and financial products to outside investors. Additionally, Boateng allegedly produced falsified records of non-existent investments and investment returns with the letterhead of an unspecified major investment bank.

Hallmarks of Ponzi Schemes and Red Flags to Look Out For

While the SEC alleges that Boateng went to great lengths to conceal the fraudulent nature of his businesses, his marketing methods demonstrates common red flags to look out for when evaluating the legitimacy of an investment opportunity.

Boateng allegedly promised high returns with little or no risk, while also providing, when asked, documentation that corroborated a pattern of overly consistent returns. The SEC describes this kind of “guaranteed investment opportunity” as a common red flag potentially indicative of a Ponzi scheme. Furthermore, Boateng’s alleged non-compliance with the necessary brokerage examinations could have been reviewed by potential investors through the FINRA BrokerCheck website.

What is Affinity Fraud?

Affinity fraud refers to the exploitation of the trusting and insular nature of many close-knit communities for the purpose of fraud (i.e. affinity for the “in-group”). Affinity fraud can be particularly difficult for victims to detect due to the greater trust that comes with knowing a fraudster personally or associating them with your community. Religious, ethnic, and racial groups, particularly when they constitute a minority in their area, can be particularly vulnerable to affinity fraud. The SEC alleges that Boateng engaged in behavior that could be described as affinity fraud—targeting the Ghanaian Group, which included immigrants to the United States, who would be inclined to trust him over a regular investor due to his involvement with their community.

Can Ponzi Scheme Victims Recover Their Money?

Victims of Ponzi schemes are frequently entitled to disgorgement, wherein the profits and assets of the fraudsters are returned to the investors. However, recovery of lost funds in Ponzi schemes can be difficult, as schemes are frequently revealed at the point where outgoing funds exceed incoming funds, leading to total collapse of the underlying fund.

SEC Whistleblower Program

While some Ponzi schemes are revealed too late for investors to recover all or even most of their lost funds, the SEC provides avenues for investors who are concerned about a particular investment to report their concerns early. The SEC Whistleblower Program allows investors to submit their concerns directly to the SEC and, if the allegations are proven, they are eligible to receive a reward of between 10% and 30% of the relief ordered.

How Miller Shah Can Help

If you are concerned that a certain investment could constitute fraud, Miller Shah can help you report your findings and assist you in the process of legal recovery. If you believe this may apply to you, fill out the form at the bottom of this page and one of our attorneys or staff will get back to you as soon as possible.