Investment Adviser Funds Gambling Habit with Seniors' $2.7 Million!

SEC v. Jenni Yoon Jeong Lee, Evergreen Property Developments LLC — U.S. Securities and Exchange Commission Litigation Release No. 26298, dated April 30, 2025.

The SEC charged Jenni Yoon Jeong Lee and her company, Evergreen Property Developments LLC, with defrauding elderly investors out of approximately $2.7 million. Lee allegedly used her community ties to gain trust, promising legitimate investments but instead funneling funds into her own entities or using them for personal expenses, including gambling.

In Plain English

Imagine someone you trusted, who was part of your community, asked you to invest your savings. They promised to invest it wisely in good companies. Instead, they took your money and put it into their own businesses, which weren't really doing anything, or spent it on themselves. They even tricked some people into using special retirement accounts to buy into these fake investments, often without permission.

Disclaimer: all facts are drawn from the SEC's own filings; the claims described are allegations unless and until a court rules or the parties settle, and some cases end in dismissal.

How the Alleged Scheme Worked

1. Gaining Trust From at least May 2015 to March 2024, Jenni Yoon Jeong Lee, through Evergreen Property Developments LLC and other entities she controlled, began soliciting investments. She leveraged her position within the Korean-American community and her family relationships to build trust with potential investors, many of whom were elderly.
2. False Promises Lee misrepresented herself as an investment adviser. She falsely assured clients that their money would be invested through or in legitimate companies that could provide returns on their investments.
3. Misdirecting Funds Instead of making genuine investments, Lee allegedly violated her fiduciary duties by directing client funds into Evergreen Property Developments LLC or other entities she controlled. These entities, according to the SEC, had no real business operations and lacked the capacity to generate any returns.
4. Targeting Retirement Accounts Lee recommended that some clients fund self-directed individual retirement accounts (SDIRAs). She then allegedly gained access to these SDIRAs through deceptive means, such as naming herself as an interested party or using her own email address on account applications.
5. Unauthorized Investments Using funds from these SDIRAs, often without the clients' knowledge or consent, Lee purchased direct investments in Evergreen and her other entities. These investments were in the form of unsecured promissory notes that Lee offered and sold.
6. Promissory Note Terms The promissory notes offered by Lee included promises of yearly interest payments ranging from 1% to 7%. They also promised the return of the investors' principal upon maturity of the notes.
7. Ponzi-like Payments and Personal Use Rather than genuine investments, Lee allegedly used all the raised funds to make Ponzi-like payments to earlier clients. She also used the money to pay for her personal expenses, including supporting a gambling habit.

The Enforcement Action

On April 30, 2025, the SEC filed charges against Jenni Yoon Jeong Lee and Evergreen Property Developments LLC in the U.S. District Court for the Western District of Washington. The SEC seeks permanent injunctions, disgorgement, and civil penalties. The complaint charges Lee and Evergreen with violating Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder and Section 17(a) of the Securities Act of 1933. Lee is also charged with violating Sections 206(1) and (2) of the Investment Advisers Act of 1940. The SEC investigation was conducted by Adrienne Adkins, Leigh Coutoumanos, and John Lindermuth, under the supervision of Michael Brennan. Litigation is led by James Carlson. The SEC acknowledges assistance from the U.S. Attorney’s Office for the Western District of Washington, the FBI, and the Washington Department of Financial Institutions.

Named in this action: Jenni Yoon Jeong Lee, Evergreen Property Developments LLC.

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