The SEC (“the Commission”) alleges that Michael Bander, an immigration lawyer and partner at Bander Law Firm, received commissions from EB-5 Investment Offerers for their clients’ EB-5 investments. Between January 2010 and February 2014, Bander made over $225,000 in commission as an unregistered broker.

According to the Commission, Bander effectuated transactions between investors and projects. These transactions included acting as a liaison, providing recommendations on projects and Offerers to clients, and transferred funds to Offerers.

In December 2015, Bander agreed to cease and desist from acting as an unregistered broker. Although he did not have to admit nor deny the SEC’s findings, he agreed to pay financial penalties which included disgorgement (profits obtained by illegal or wrongful acts) and prejudgment interest.