SEC Charges Florida-Based Investment Adviser and Its CEO for Failing to Withdraw the Adviser's Registration and Produce Records Requested by the SEC's Division of Examinations

ADMINISTRATIVE PROCEEDING
File No. 3-22395

January 10, 2025 - The Securities and Exchange Commission today announced settled charges against Touradji Capital Management LP (“Touradji Capital”), a Boca Raton, Florida based investment adviser formerly registered with the Commission, and it’s owner and CEO, Paul Touradji (“Touradji”), for failing to withdraw Touradji Capital’s registration and failing to respond to requests for documents and information from the staff of the Commission’s Division of Examinations.

According to the order, notwithstanding the requirement that registered investment advisers withdraw their registration if regulatory assets under management drop below $90 million, Touradji Capital remained registered with the Commission as an investment adviser despite the firm, by 2020, having less than $90 million under management.  In addition, in June 2023, Touradji Capital failed to respond to requests for documents and information submitted by staff from the Commission’s Division of Examinations.  Although the Examinations staff requested that Touradji Capital produce certain required records, Touradji Capital failed to do so.

The SEC’s order finds that Touradji Capital willfully violated Section 203A of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 203A-1(a) thereunder as well as Section 204(a) of the Advisers Act.  The SEC’s order further finds that Touradji, as Touradji Capital’s owner and sole employee, caused Touradji Capital’s violations of these provisions.  Without admitting or denying the order’s findings, Touradji Capital and Touradji consented to a cease-and-desist order, a censure against Touradji Capital, and an order requiring Touradji to pay a $15,000 civil penalty.

The SEC’s investigation was conducted by Jonathan T. Menitove of the Asset Management Unit and Sarah McAteer and Al Day of the Boston Regional Office.  It was supervised by Colin Forbes, Andrew Dean, and Corey Schuster of the Asset Management Unit.  The team was assisted by Jason Lake, Jonathon Arleo, and Nitish Bahadur of the Division of Examinations of the Boston Regional Office.