SEC Charged SQN Capital Management for Fiduciary Breaches
The U.S. District Court for the Southern District of New York entered consent judgments against the firm and its CEO.
Updated on Oct. 10, 2026 in Financial Crime
Live Poll
Do you trust private investment fund managers to accurately report their fund assets?
The SEC charged SQN Capital Management LLC and CEO Jeremiah Silkowski with violating the Investment Advisers Act of 1940. The case centers on alleged breaches of fiduciary duties and failure to conduct mandatory audits.
Why it matters
The case highlights the importance of independent oversight and regulatory compliance in fund management. By allegedly bypassing required audits and expert valuations, the defendants undermined the transparency protections intended for investors.
The U.S. District Court for the Southern District of New York entered consent judgments on 8 October 2026, including the appointment of a receiver for the four funds managed by SQN Capital.
The players
SQN Capital Management LLC
This investment firm managed four distinct funds and was recently charged with violations of the Investment Advisers Act of 1940.
Jeremiah Silkowski
As the CEO of SQN Capital Management, he is accused of unilaterally performing asset valuations and bypassing standard auditing requirements.
U.S. Securities and Exchange Commission
This federal agency is responsible for enforcing the Investment Advisers Act and protecting investors through market oversight.
U.S. District Court for the Southern District of New York
This federal court holds jurisdiction over the case and has officially entered consent judgments against the firm and its leadership.
The details
The SEC alleges that Jeremiah Silkowski personally handled asset valuations instead of utilizing independent experts, and the firm failed to engage accounting firms to audit annual financial statements. These activities were part of a broader series of fiduciary duty breaches spanning from 2019 through 2025.
Timeline
The alleged breaches of fiduciary duty occurred from 2019 through 2025.
The SEC filed its initial complaint against the defendants on 18 September 2026.
The U.S. District Court for the Southern District of New York entered consent judgments on 8 October 2026.
Legal Context
This enforcement action aligns with a long-standing pattern of SEC oversight aimed at ensuring investment advisors adhere to the Investment Advisers Act of 1940. By penalizing firms for valuation and auditing failures, regulators seek to maintain investor confidence in the broader financial market.
The appointment of a receiver for the managed funds is the primary mechanism through which the court will seek to secure remaining assets for investors. Individuals previously invested with the firm should look for official court communications regarding the distribution process.
The takeaway
Investors should always verify that the funds they participate in utilize independent, third-party auditors to validate financial claims. Relying on internal valuations without external expert verification creates significant risks for capital security.
Further reading
For more information on current regulatory actions, visit Financial Crime.
Source note: This article includes information reported by Opalesque.
Live Poll
Do you trust private investment fund managers to accurately report their fund assets?
