SEC v. Gonul Colak and Milen K. Kostov (naked short selling debate, 2014)
Settled
Checked against the primary document on October 3, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In January 2014 the Securities and Exchange Commission settled an administrative order with Gonul Colak and Milen Kostov, finding that they kept uncovered short positions in over 20 stocks by moving them between brokers and staging sham trades. The combined relief is $420,000 disgorgement, $32,315 interest and $220,000 in penalties.
The record
| Agency | SEC |
|---|---|
| Release number | 3-15712 |
| Date filed | 2014-01-31 |
| Date resolved | 2014-01-31 |
| Status | settled |
| Asset class | equities, options |
| Criminal parallel | No |
| Defendants | Gonul Colak ; Milen K. Kostov |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Securities Act s.17(a) |
| Techniques | The naked short selling debate |
What was ordered
- Civil penalty
- $220k
- Disgorgement
- $420k
- Prejudgment interest
- $32.3k
- Total relief
- $672k
- Alleged gain
- $420k
What is alleged to have happened
The Securities and Exchange Commission announced this matter on January 31, 2014 as release 3-15712. The respondents named are Gonul Colak and Milen K. Kostov (2 individuals, 0 entities).
This library tags the matter as naked short selling debate, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
The relief recorded in our data combines both respondents: Colak, disgorgement of $285,600, interest of $21,975 and a $150,000 penalty; Kostov, disgorgement of $134,400, interest of $10,340 and a $70,000 penalty. The order treats about $420,000 as the profit from the scheme.
For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.
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.
- The naked short selling debate — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Robinhood Financial LLC and Robinhood Securities, LLC (naked short selling debate, 2025) | SEC | 2025-01-13 | Naked Short Selling Debate | $45m | settled |
| SEC v. Maxim Group, LLC (naked short selling debate, 2023) | SEC | 2023-09-29 | Naked Short Selling Debate | $800k | settled |
| SEC v. Simplex Trading, LLC (naked short selling debate, 2023) | SEC | 2023-09-11 | Naked Short Selling Debate | $200k | settled |
| SEC v. Hal D. Mintz and Sabby Management LLC (naked short selling debate, 2023) | SEC | 2023-06-14 | Naked Short Selling Debate | — | filed |
| ASIC bans former fund manager for naked short selling (2023) | ASIC | 2023-05-22 | Naked Short Selling Debate | — | judgment |
| SEC v. IMC Chicago, LLC (naked short selling debate, 2022) | SEC | 2022-08-12 | Naked Short Selling Debate | $125k | settled |