Fraud comes in many shapes and sizes, especially in the eyes of the SEC. At one end of the spectrum, advisers get into trouble for failing to do what they say or say what they do. At the other, individuals like Bernard Madoff are targeted by the SEC when they hide their misappropriation of investor funds with fabricated track records and account statements. The SEC recently commenced an enforcement action against a hedge fund adviser, who allegedly raised nearly $10 million from investors, at least partly on the basis of fraudulent performance representations and account statements. He incurred nearly $4.6 million in trading losses – and helped himself to more than $2.6 million of investors’ funds, the SEC charged. This article parses the SEC’s complaint and the parallel criminal charges. See “Former SEC Officials Discuss Aggressive Enforcement Climate” (Sep. 14, 2023).