Arsalan Rawjani; Trade with Ayasa, LLC (Texas); Trade with Ayasa, LLC (Wyoming); Trade with Ayasa, LLC (Nevada)

U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 26391 / September 8, 2025

Securities and Exchange Commission v. Arsalan A. Rawjani, et al., No. 3:25-civ-02404-L (N.D. Tex. filed Sept. 5, 2025)

SEC Charges Man with Perpetrating an Affinity Fraud and Ponzi Scheme in the North Texas Ismaili Community

The Securities and Exchange Commission announced today that it filed charges against Arsalan A. Rawjani and the business enterprise he operated, Trade with Ayasa, LLC, which operated through various corporate forms, for allegedly conducing an affinity fraud and Ponzi scheme centered in the North Texas Ismaili community, where Rawjani was an active member and community leader.

The SEC’s complaint alleges that, between 2021 and 2024, Rawjani held himself out in his community as an expert in options trading and solicited investments for his company by falsely promising that the investors’ money would be pooled for trading options contracts and that investors would be paid a guaranteed monthly dividend, typically three to five percent, from Trade with Ayasa’s options trading profits. According to the complaint, however, only a small fraction of the investors’ money was ever invested in the options market and trading profits were insufficient to pay the guaranteed dividends; most of the money was instead either misappropriated for Rawjani’s personal gain or misused for, among other things, Ponzi payments necessary to keep the scheme afloat. The complaint alleges that Rawjani’s lackluster trading and inability to attract new investors caused the scheme to collapse in late 2023 and early 2024; at that time, Rawjani stopped paying monthly dividends to investors and left investors with millions of dollars in losses.

The SEC’s complaint, filed in federal district court in Dallas, Texas, charges Rawjani, Trade with Ayasa, LLC (Texas), Trade with Ayasa, LLC (Wyoming), and Trade with Ayasa, LLC (Nevada) (collectively, the “Defendants”) with violating the antifraud provisions of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The complaint further charges the Defendants with violating the registration provisions of Sections 5(a) and 5(c) of the Securities Act of 1933. The SEC seeks injunctive relief, disgorgement plus pre-judgment interest on a joint and several basis, and civil penalties.

The SEC’s investigation was conducted by Jennifer R. Turner and supervised by Marc D. Ricchiute and Nicholas P. Heinke, all of the SEC’s Denver Regional Office. The litigation will be led by James P. McDonald and supervised by Gregory A. Kasper.