Three California-based sales agents were sued by the SEC for illegally selling Woodbridge Group as part of that firm's $1.2 billion Ponzi scheme.

David H. Goldman, Brook Church-Koegel and Nicole J. Walker are the latest participants to be charged in the fraud operated by Robert H. Shapiro from 2012 to 2017.

Shapiro, 61, of Sherman Oaks, Calif., pleaded guilty to conspiracy and tax evasion and was sentenced to 25 years in prison in October in relation to the scheme.

According to the SEC's complaint, David H. Goldman of Chatsworth, Calif., and Brook Church-Koegel and Nicole J. Walker, both of Marina Del Rey, Calif., sold and assisted others in selling about $444 million in Woodbridge securities in unregistered transactions to thousands of predominantly elderly investors.

The complaint alleged that the trio were among Woodbridge's largest revenue-producing internal sales agents, and Church-Koegel and Goldman eventually became “team leaders,” responsible for coordinating and assisting the wide-ranging sales efforts of many internal sales agents who sold Woodbridge securities.

Church-Koegel, Goldman, and Walker also coordinated and assisted external sales agents in their efforts to sell Woodbridge’s securities, including regularly speaking with them over the telephone, the complaint said. They also pitched Woodbridge’s securities to the general public via email, telephone and at in-person meetings. Further, they provided investors with Woodbridge’s sales and marketing materials, touting Woodbridge’s securities as “safer” and “conservative,” the complaint said.

Woodbridge and Shapiro, its then owner and president, operated Woodbridge as a Ponzi scheme that raised at least $1.22 billion from more than 8,400 investors, many of whom were elderly, nationwide through fraudulent unregistered securities offerings.

Shapiro had promised returns as high as 10% from investments in loans to property developers. Instead, he used money from new investors to repay earlier ones and used $36 million to buy luxury homes, wines, paintings and custom-designed jewelry for his wife.

The Ponzi scheme collapsed in December 2017, when Shapiro caused Woodbridge and its many related companies to file for bankruptcy, the complaint said. Once Woodbridge filed for bankruptcy, investors stopped receiving their monthly interest payments and have not received a return of their investment principal.

Church-Koegel, Goldman and Walker, acting as unregistered brokers, together were responsible for raising through their own efforts and the efforts of external sales agents that they assisted, from thousands of investors in more than 40 states, the complaint said.

The trio was rewarded with at least $2.75 million in transaction-based compensation—Church-Koegel and Goldman receiving more than $1 million each, and Walker receiving more than $750,000—in addition to their salaries. The complaint also said they held no securities licenses, were not registered with the SEC and were not associated with registered broker-dealers during their time with Woodbridge.

Woodbridge’s securities were not registered with the commission, nor did they qualify for an exemption from registration. Thus, they were not permitted to sell Woodbridge’s securities, the complaint noted.

The SEC's complaint, filed in the Southern District of Florida, accuses Church-Koegel, Goldman and Walker with violating the securities registration provisions and the broker-dealer registration provision, and seeks disgorgement of ill-gotten gains, prejudgment interest and civil penalties against each of them.

The SEC said its investigation is continuing.