Securities Regulation Daily Wrap Up, FRAUD AND MANIPULATION—D.N.J.: SEC charges three Toms River men in alleged $47 million affinity investment fraud, (Aug 14, 2026)

By Kristin J. Angelino, J.D.

Most of the investors were, like the scheme’s orchestrator, active members of the Orthodox Jewish communities in New York and New Jersey.

The SEC has filed a complaint in federal court in the District of New Jersey alleging that Leor Moshe, a resident of Toms River, New Jersey, engaged in a multi-year fraud in which he convinced investors to invest in his company, Capital Funding ASAP, LLC, by falsely representing that their money would be used to fund short-term loans for small businesses and that they would receive significant fixed returns from the lending business. Instead, it is alleged that Moshe misappropriated more than $11 million for his personal use and used more than $850,000 to make Ponzi-like payments to earlier investors. The complaint further alleged that Moshe paid two other Toms River residents, defendants Jacob Goldman and Isaac Odes, to recruit investors, even though they were not registered as broker-dealers or associated with any registered broker-dealers. (SEC v. Moshe, No. 3:26-cv-10253 (D.N.J. Aug. 13, 2026)).

The alleged scheme. The SEC’s complaint alleged that, between approximately November 2019 and June 2023, Moshe, the orchestrator of the fraud, exploited the reputation and relationships he cultivated within his religious community to raise approximately $47 million from at least 87 investors in multiple states. Moshe promised investors fixed returns of between 22% and 53% on one-year investments, and between 9% and 10% on shorter two- to three-month investments. He represented to investors that their money would be used exclusively to fund short-term loans to small businesses in need of immediate capital. In reality, the complaint alleged, Capital Funding made few, if any, legitimate loans and the company’s lending business generated a small fraction of the returns that investors received. It is also alleged that he used investor funds to pay returns to earlier investors in a Ponzi-like fashion. Additionally, Moshe is alleged to have misappropriated at least $11 million for his personal expenses--to pay gambling debts, personal credit card bills, home renovation expenses, and mortgage and car payments. By the time the scheme collapsed in mid-2023, investors from seven states, including New York and New Jersey, had lost more than $25 million.

Role of Goldman and Odes. The SEC’s complaint further alleged that, from approximately August 2021 through June 2023, Moshe paid defendants Odes and Goldman to solicit more than $23 million from at least 25 investors. As alleged, Odes and Goldman’s role involved describing the investment opportunity to investors, helping negotiate terms, facilitating the collection of funds, and receiving transaction-based compensation, even though neither one of them had ever registered as a broker-dealer or were associated with any registered broker-dealer.

Commenting on the case, Thomas P. Smith, Jr., the Associate Director of the SEC’s New York Regional Office, said, “As our complaint alleges, the defendants promised some investors that they could see returns in excess of thirty percent which definitely falls into the ‘if it sounds too good to be true, it probably is’ category. In reality, the Jersey Shore triumvirate took advantage of their relationships within Orthodox Jewish communities to raise money for Moshe’s scheme and enrich themselves.”

Violations and relief sought. The SEC’s complaint charged defendant Moshe with violations of the anti-fraud provisions of the federal securities laws and charged Goldman and Odes with violations of the broker registration provisions of the Exchange Act. The complaint is seeking permanent injunctive relief, disgorgement of ill-gotten gains with prejudgment interest, civil penalties against all defendants, and a conduct-based injunction against Moshe.

Parallel criminal action. On the same day that the SEC filed charges against the three defendants, the U.S. Attorney’s Office for the District of New Jersey announced criminal charges against defendant Moshe for similar conduct.

The case is No. 3:26-cv-10253.

Attorneys: Paul G. Gizzi for the SEC.

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