According to the SEC's complaint, Clune, who performed tax work both for the estate that created the charitable foundation and the charitable foundation itself, ignored multiple and repeated red flags revealing Rogicki's and TBA's fraudulent scheme.

Both Gaughran and Clune were actively involved in concealing the theft by providing false information to an outside audit firm during a surprise examination of the charitable foundation that was conducted in 2014, the SEC said.

In another action involving TBA, the SEC in September instituted administrative proceedings against former TBA CEO Brian J. Keenan in connection with his misappropriation of assets from a separate client account. The administrative proceedings against Keenan were settled in October.

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