The SEC noted that because the scheme has been going on for so long, the commission has not yet fully determined the scope of the fraud. But from its detailed analysis, it believes that from January 1, 2019, through August 2021, the Ponzi scheme involved more than $100 million.

By the end of July 2021, investors were owed more than $110 million in principal, at which time Horizon had liquid assets worth less than $16 million. The SEC said most of the other assets of which it’s aware “are fractional ownership interests in small real estate projects in various stages of development. The commission estimates that Horizon has invested less than $20 million in those projects, and liquidating them will be complicated [and] time consuming and yield uncertain amounts.”

The complaint charges Mooney, Wright and Flippen with violating the antifraud provisions of the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940. Each of the defendants also faces charges of aiding and abetting the previous securities law violations made by Woods, Southport and Horizon. The complaint seeks injunctive relief, disgorgement plus prejudgment interest, and civil penalties against each defendant.

The commission said the investigation is ongoing.

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