In 2022, the SEC charged the principal of an investment adviser with engaging in “a series of undisclosed and fraudulent conflict-of-interest transactions” with a private fund he managed. Those transactions, many of which the SEC claimed were principal transactions, allegedly benefited the principal at the fund’s expense. He and the SEC have reached a settlement. Although the SEC’s complaint included multiple counts of securities and investment adviser fraud, the final judgment covers only the non-scienter adviser fraud and principal transaction claims – and imposes modest financial sanctions. This article details the SEC’s allegations and the settlement’s terms. See “SEC Imposes Substantial Sanctions for Cross Trades & Principal Transactions, Despite Self-Reporting, Cooperation & Remediation” (Apr. 13, 2023).