SEC v. Dawn J. Bennett and DJB Holdings (ponzi schemes, 2017)

Judgment entered

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In August 2017 the SEC charged former financial adviser Dawn J. Bennett and DJB Holdings LLC in Maryland with raising over $20 million through notes of a luxury sports apparel firm and using later funds to repay earlier investors in Ponzi-like fashion. In January 2022 the court granted the SEC summary judgment against both and ordered $14.5 million in disgorgement, deemed satisfied by criminal restitution.

The record

What was ordered

Civil penalty

—

Disgorgement

$14.5m

Prejudgment interest

—

Total relief

$14.5m

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The complaint, filed August 25, 2017, alleged Bennett overstated the safety of the notes and the firm's success, spent some money personally, repaid earlier investors with other funds, lied to regulators and funded repayments with loans obtained by inflating her net worth. It charged registration and antifraud violations.

Outcome: on January 28, 2022 the District of Maryland granted the SEC's motion for summary judgment against Bennett and DJB Holdings, permanently enjoined them from violating Section 10(b), Section 17(a) and Section 5, and held them jointly and severally liable for disgorgement of $14,504,290. The order deems that obligation satisfied by the restitution order in the parallel criminal case, United States v. Bennett, and closed the case. The order shown does not set a civil penalty or interest. The case also named Bradley Mascho; his outcome is not covered by the order we read and was not checked.

This library tags the matter as ponzi schemes because the document describes payments to earlier participants made from later participants' money. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Ponzi schemes — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2017-08-28 Litigation release published
2. 2022-01-28 District of Maryland grants SEC summary judgment against Bennett and DJB Holdings; disgorgement $14,504,290 deemed satisfied by criminal restitution

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC litigation release
• Order granting summary judgment (D. Md., January 28, 2022)

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.