SEC v. OTC Live, Inc. and Mark A. Suleymanov (unregistered distributions, 2004)

Dismissed

✓ Checked against the primary document on October 2, 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.

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In 2004, the Securities and Exchange Commission published a release reporting the dismissal of the proceeding against OTC Live and Mark Suleymanov over unregistered distribution. This library classifies the conduct as unregistered distributions.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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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 Securities and Exchange Commission announced this matter on September 30, 2004 as release 3-11309. The respondents named are OTC Live, Inc. and Mark A. Suleymanov (0 individuals, 1 entity). The action was brought in the SEC administrative law judge.

The administrative law judge's initial decision dismissed the proceeding against a website operator paid in stock for advertising, finding that it was not an underwriter; the decision records that no Section 17(b) violation was alleged. The paid-promotion tag has therefore been removed.

This library tags the matter as unregistered distributions, 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 conduct is recorded against equities, with OTC identified in the release.

The action was dismissed. We keep dismissed matters in the library precisely so that the outcome is visible alongside the original allegation.

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.

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

Timeline

1. 2004-09-30 Initial decision

Primary documents

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

• Initial decision (ID-261)
• Finality order

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.