Arete Wealth Advisors LLC and its affiliated broker-dealer, Arete Wealth Management LLC, are the subjects of a civil enforcement action brought by the U.S. Securities and Exchange Commission alleging a coordinated selling away scheme that funneled over $8 million in unapproved securities to firm clients. Filed in January 2025 in the Northern District of Illinois, the SEC complaint alleges that former representatives of the Chicago-based firms sold unauthorized shares in Zona Energy Inc. between October 2018 and May 2020, bypassing firm compliance systems through personal phones and private email accounts.
The SEC further alleges that the firm’s own Chief Compliance Officer, UnBo (Bob) Chung, helped conceal the misconduct rather than address it. Investors who purchased Zona Energy or other unapproved offerings through these firms may have viable broker misconduct claims for recovery through arbitration.
How the SEC Alleges Arete Wealth Clients Were Harmed
According to the SEC’s litigation release (No. 26228), the scheme centered on an illegal offering of shares in Zona Energy Inc., a company that was not among the approved investment products of either Arete Wealth Management or Arete Wealth Advisors. The SEC complaint describes a coordinated effort to circumvent the firms’ compliance infrastructure:
- Unapproved private offering sales (selling away): Former dually registered representatives Joey Dale Miller, Jeffrey Scott Larson, and Randall Scott Larson allegedly sold more than $8 million in Zona Energy shares to Arete clients without firm authorization.
- Concealment through personal communications: The complaint alleges that Miller and the Larsons used personal cell phones and private email accounts to conduct and hide the Zona Energy sales from Arete’s supervisory and recordkeeping systems.
- Investor deception: The SEC alleges that clients were misled about the nature and risks of the Zona Energy investment, raising claims of antifraud violations under the federal securities laws.
- Compliance cover-up: Arete Wealth Advisors and its Chief Compliance Officer and General Counsel, UnBo (Bob) Chung, are accused of concealing the representatives’ alleged misconduct and failing to address other compliance deficiencies.
- Recordkeeping failures: Arete Wealth Management is charged with failing to maintain required books and records related to the Zona Energy transactions, in violation of federal recordkeeping provisions.
The SEC is seeking permanent injunctions, civil penalties, conduct-based injunctions, penny stock bars, and officer-and-director bars against Miller, Jeff Larson, and Randy Larson. Arete Wealth Management has been registered with the SEC as a broker-dealer since 1998, and Arete Wealth Advisors has been registered as an investment adviser since 2009, reporting over $2.5 billion in regulatory assets under management.
We Have Recovered Over
$350 Million for Our Clients Nationwide.
Who Are Joey Miller, Jeffrey Larson, Randall Larson, and UnBo Chung?
The SEC’s complaint names six defendants. Understanding their roles is critical for any investor evaluating potential claims:
- Joey Dale Miller: A former dually registered representative of both Arete Wealth Management and Arete Wealth Advisors. The SEC alleges Miller played a central role in selling Zona Energy shares and concealing the transactions from firm compliance.
- Jeffrey (Jeff) Scott Larson: Another former dually registered representative accused of participating in the unauthorized trading and selling away of Zona Energy securities. The SEC alleges Jeff Larson used personal devices to evade supervision.
- Randall (Randy) Scott Larson: A third former representative alleged to have participated in the same selling away scheme.
- UnBo (Bob) Chung: Arete Wealth Advisors’ Chief Compliance Officer and General Counsel, charged with concealing the misconduct of Miller and the Larsons and failing to fulfill his compliance obligations.
- Arete Wealth Management LLC: The SEC-registered broker-dealer charged with recordkeeping violations.
- Arete Wealth Advisors LLC: The SEC-registered investment adviser charged alongside Chung with antifraud violations and concealment.
All allegations remain pending. No defendant has been found liable in this matter, and the SEC’s charges are civil in nature.
How Meyer Wilson Werning Can Help
The SEC’s enforcement action against Arete Wealth Advisors and Arete Wealth Management underscores a critical reality: when firms and their compliance officers allegedly participate in concealing misconduct, investors are the ones left bearing the losses. Recovering those losses requires experienced legal counsel who understands the intersection of federal securities law and arbitration.
Meyer Wilson Werning represents investors nationwide who have been harmed by selling away schemes, unsuitable private offering recommendations, and failures to supervise. With more than 75 years of combined experience and over $350 million recovered for our clients, our team is dedicated to holding negligent firms accountable. Contact us today for a free and confidential consultation to discuss your path to recovery.
Our lawyers are nationwide leaders in investment fraud cases.
Frequently Asked Questions
What are the SEC allegations against Arete Wealth Advisors and Arete Wealth Management?
The SEC has charged Arete Wealth Advisors and affiliated broker-dealer Arete Wealth Management with violations of the registration, recordkeeping, and antifraud provisions of the federal securities laws. The complaint alleges that former representatives Joey Miller, Jeff Larson, and Randy Larson participated in an illegal offering of Zona Energy Inc. securities and helped the firm violate recordkeeping rules. The SEC also charges Chief Compliance Officer UnBo (Bob) Chung with covering up the representatives’ alleged misconduct.
Who are Joey Miller and Jeffrey Larson in the Arete Wealth Advisors SEC case?
Joey Miller and Jeffrey (Jeff) Larson are former dually registered representatives of Arete Wealth Management and Arete Wealth Advisors named as defendants in the SEC’s civil action. The SEC alleges they sold more than $8 million in unapproved Zona Energy Inc. securities to Arete clients between 2018 and 2020, using personal phones and email to conceal the sales from firm supervision. The SEC is seeking permanent injunctions, civil penalties, and industry bars against both.
What is selling away, and how does it relate to the Arete Wealth Advisors allegations?
Selling away occurs when a broker sells securities not approved by their employing firm, often in private offerings that fall outside the firm’s due diligence and oversight. The SEC alleges that Miller and the Larsons sold over $8 million in Zona Energy shares to Arete clients without firm authorization, using personal communication channels to evade compliance systems and leaving investors exposed to undisclosed risks.
How can investors who bought Zona Energy or other unapproved offerings through Arete Wealth Advisors seek recovery?
Investors who purchased Zona Energy or other unapproved offerings through Arete Wealth may be able to pursue recovery through arbitration or related securities fraud claims. A securities attorney can evaluate whether the firm failed to supervise its representatives, allowed selling away, or breached duties under federal securities laws. Investors should gather account statements, communications, and offering documents before consulting counsel.
Recovering Losses Caused by Investment Misconduct.