Attorney at Law – Dr. Jur. Marius R. Stef
L&S Law Firm Ltd
Insights | 24 September 2026
Introduction
This note records our thoughts on a public civil enforcement action announced on 23 September 2026 by the United States Securities and Exchange Commission (the “SEC”) concerning CMI Capital LLC, also known to do business as Check Mate Investments, and its founder and manager, Michael D. Williams of Port St. Lucie, Florida. It is written in continuous prose with short section headings in a formal DIFC-style presentation: figures for dates and amounts, and no bullet-point lists.
The commentary under “Our thoughts” below is that of Attorney at Law – Dr. Jur. Marius R. Stef and L&S Law Firm Ltd. The factual narrative under “Background” and the following sourced sections is drawn only from the named public sources listed at the end of this note. Nothing herein is a finding of fact or a determination of liability beyond what those authorities expressly state.
The matters described by the SEC remain civil allegations unless and until a court enters a final judgment that expressly adjudicates them. Consent to the entry of a judgment without admitting the allegations is not an admission of liability.
Background
On 23 September 2026 the SEC announced that it had charged CMI Capital LLC and Michael D. Williams for an alleged fraudulent investment scheme that, according to the Commission, raised approximately USD 860,000 from at least 18 investors, many of whom are current or retired law-enforcement officers in South Florida.
The defendants have agreed to a bifurcated settlement in connection with the charges, subject to court approval.
According to the SEC’s complaint as summarised in the Commission’s 23 September 2026 press release, from at least October 2023 through August 2024 Williams made numerous false and misleading statements in order to convince clients to invest in two funds that he controlled. The investors, many of whom trusted Williams because he worked for a third-party police and firefighter pension plan administrator, were allegedly told that one of the funds had a portfolio value of more than USD 5 million and achieved returns exceeding 140 percent.
Stephanie N. Moot, Director of the SEC’s Miami Regional Office, is quoted in that same press release as stating that one of the tactics the defendants allegedly used to trick investors was to send them cropped screenshots of graphics that showed exorbitant trading profits, and that the Commission strongly urges investors to use caution when entrusting their funds to others and to be wary of anyone promising high returns with little to no risk.
The allegations as framed by the SEC
According to the SEC’s press release, Williams allegedly misappropriated approximately USD 384,000 of investor and client funds to pay for personal expenses, including credit card balances, a sports car, and vacations. The Commission further states that Williams began repaying certain investors in August 2024 and has repaid more than USD 375,000 to certain investors.
Secondary reporting of the SEC’s complaint adds further detail that this note attributes expressly to that reporting of the complaint, not to any independent finding of this Firm. According to that reporting, Williams was never registered with the Commission; he solicited investments for two CMI funds he never incorporated and claimed the funds would trade in stock options, crypto assets, and S&P 500 equities; he allegedly never opened a brokerage account for CMI Capital and based return claims on a personal trading history marked by losses; and he allegedly posted cropped screenshots of returns from a practice trading platform to a Facebook group chat for CMI Capital investors.
That reporting further states that, according to the complaint, approximately 45 percent of the total funds were used for personal expenses including credit card and mortgage payments, cash withdrawals, a high-end sports car, luxury car rentals, jewelry, luxury goods, vacations, restaurants, and medical spa treatments, and that repayment of more than USD 375,000 was largely funded by family members.
Readers should treat the secondary-reporting details as a secondary account of the SEC’s complaint. The binding primary characterisation of the case for this note remains the Commission’s own 23 September 2026 press release.
The civil charges and the consented relief as framed by the SEC
The SEC’s complaint, filed in the United States District Court for the Southern District of Florida, charges Williams and CMI Capital with violating antifraud and registration provisions of the Securities Act of 1933 and antifraud provisions of the Securities Exchange Act of 1934 and the Investment Advisers Act of 1940.
Without admitting the allegations in the complaint, the defendants consented to the entry of judgments, subject to court approval, that would permanently enjoin them from violating the charged provisions of the federal securities laws and further enjoin Williams from participating in the issuance, purchase, offer, or sale of any security except for certain transactions in his personal accounts. The proposed judgments further provide that the Court shall order disgorgement with prejudgment interest against Williams and civil penalties against the defendants in amounts to be determined by the Court. Williams also agreed to a forthcoming associational bar against him.
Our thoughts
Affinity and occupational trust are powerful fundraising tools. When an introducer works inside or alongside a police and firefighter pension-administration setting, current and retired law-enforcement officers may reasonably assume that the person they know from that professional context is operating with institutional discipline. The SEC’s account of this matter is a reminder that occupational familiarity is not a substitute for independent verification of strategy, custody, trading accounts, and the source of advertised returns.
Cropped screenshots, practice-account graphics, and unverified portfolio values are not diligence materials. They are marketing artifacts. An investor who cannot reconcile advertised returns to a named brokerage statement in the fund’s own name, produced by a third-party custodian or broker, is looking at a narrative rather than at an audited cash trail. Partial repayment after discovery, even repayment funded by family, does not convert an alleged offering into a successful investment history. That observation is commentary. The preceding sections are sourced narrative only.
For boards, family offices, and individual investors evaluating private trading or “managed fund” pitches that arrive through workplace or affinity channels, three practical checks follow from this matter as framed by the authorities. First, insist on registration status that can be checked independently, and treat an unregistered manager who solicits friends, colleagues, and referrals as a heightened risk signal rather than as a community convenience. Second, require live, uncropped brokerage evidence in the investment vehicle’s own name before transferring capital, and reject screenshots that cannot be traced to a verified account.
Third, do not equate a civil settlement consent entered without admission of the allegations with a finding of liability; the court must still approve the proposed judgments, and amounts for disgorgement and penalties remain to be determined.
Our firm view is straightforward: if the only reason you trust the pitch is that you trust the person from a shared professional world, pause — and verify the books before you introduce anyone else.
Sources
U.S. Securities and Exchange Commission, SEC Charges South Florida Resident and His Company for Alleged Investment Scheme Defrauding Law Enforcement, Press Release No. 2026-92 (23 September 2026): https://www.sec.gov/newsroom/press-releases/2026-92-sec-charges-south-florida-resident-and-his-company-alleged-investment-scheme-defrauding-law-enforcement.
Newsfile Corp. wire of the same SEC Press Release No. 2026-92 (23 September 2026), republished as a press digest (used where the Commission’s HTML page was temporarily rate-limited during drafting): https://www.finanznachrichten.de/nachrichten-2026-09/69659413-newsfile-sec-press-digest-sec-charges-south-florida-resident-and-his-company-for-alleged-investment-scheme-defrauding-law-enforcement-296.htm.
Patrick Donachie, Florida Man Accused of Defrauding Law Enforcement Officers, Wealth Management (23 September 2026) (secondary reporting of the SEC complaint): https://www.wealthmanagement.com/regulation-compliance/florida-man-accused-of-defrauding-law-enforcement.
Important notice
This article is for general information and investor-education purposes only. It is not legal advice and does not create a solicitor–client (or attorney–client) relationship. Allegations described herein are those of the named public authorities and have not been proven in court unless a final judgment is expressly cited.
Civil consent to judgment entered without admitting the allegations is not an admission of liability. Proposed judgments remain subject to court approval, and monetary relief remains to be determined. Readers should consult the primary sources cited above and take independent professional advice before acting.
Contact: office@lslawfirm.co.uk | www.lslawfirm.co.uk
