The allegations read: The securities and exchange commission (\\u201ccommission\\u201d) deems it appropriate and in the public interest that public cease-and-desist proceedings be, and hereby are, instituted pursuant to section 8a of the securities act of 1933 (\\u201csecurities act\\u201d) and section 203(k) of the investment advisers act of 1940 (\\u201cadvisers act\\u201d) against rita mansour (\\u201crespondent\\u201d). The commission finds that these proceedings arise out of respondent\\u2019s sales of securities in connection with private securities offerings conducted by two pooled investment vehicles that respondent\\u2019s employer advised (the \\u201cpivs\\u201d). Those pivs offered and sold securities to raise bridge funding for the construction of a resort in montenegro. Investor monies raised through these offerings were to be used to purchase debt in a montenegrin entity that was to construct the resort. Between september 2013 and continuing through january 2017, respondent\\u2019s employer offered and sold more than $14 million in securities issued by the pivs to investors located in the united states, including both its brokerage customers and its advisory clients. In october 2016, respondent and respondent\\u2019s employer became aware of allegations that their point-person at the montenegrin entity had misappropriated $488,331 of investor funds by misusing a debit card belonging to that entity to pay for certain personal expenses. After being confronted with the allegations that this individual had misappropriated funds from the montenegrin entity, he conceded that he was not entitled to certain of the funds alleged to have been misappropriated. Accordingly, after negotiation, the individual agreed to repay approximately $335,000 that he had allocated to personal expenses. Neither respondent nor respondent\\u2019s employer disclosed the misappropriation to existing investors in october 2016. In early 2017, respondent\\u2019s employer then raised approximately $1.5 million in additional funds through sales of securities issued by piv2 to both existing security holders and new investors, including brokerage customers and advisory clients, without disclosing the misappropriation to those investors. Respondent was responsible for recommending and selling certain of these securities. By this conduct, respondent caused her employer to violate sections 17(a)(2) and (3) of the securities act and sections 206(2) and 206(4) of the advisers act and rule 206(4)-8 thereunder.
