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FUNDS LOANED TO BOSS AT SCANTY RATES! Investors HOODWLED OUT!

  
September 9, 2025


  
  

    

      
      

    

  




  



        


U.S. Securities and Exchange Commission Litigation Release No. 26393, dated September 9, 2025.


Tomislav Vukota and his two advisory firms, Vukota Capital Management and VCM Global Asset Management, have settled SEC charges for breaching fiduciary duties and making misrepresentations to investors. They allegedly made unauthorized loans from private funds, sent misleading buyout offers, and falsified marketing materials regarding audits, assets under management, and filing status. The settlement includes over $6.9 million in disgorgement and prejudgment interest, plus a $1 million penalty.




In Plain English
Imagine you hired someone to manage your money in special investment groups. This manager, Tom, and his companies, took money from one group to pay bills for another group, which wasn't allowed and wasn't told to you. Later, when Tom wanted to buy out your share, he didn't tell you he had a conflict of interest. Also, his company's ads for another investment group wrongly claimed it had an official auditor, had more money in it than it did, and wasn't honest about its investment style and registration status. To settle this, Tom and his companies agreed to pay back the money they improperly took, plus interest and a penalty.
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. Unauthorized Loans From at least 2017 through May 2022, Tomislav Vukota and Vukota Capital Management, LLC (VCM) caused private funds they advised to make short-term loans to VCM. These loans were at below-market rates and were used to cover cash shortfalls at other private funds, a practice prohibited by the funds' partnership agreements and undisclosed to investors.
  2. Misleading Buyout Offers In February and March 2021, Vukota and VCM sent misleading letters to investors in four private funds. These letters were in connection with Vukota's attempt to buy out investors' interests but failed to disclose Vukota's conflicts of interest and did not obtain investor consent for these conflicts.
  3. False Claims in Marketing From at least 2017 through 2023, Vukota and VCM Global Asset Management Ltd. (VGAM) made material misstatements in marketing and offering materials for the Vukota Multi-Strategy Fund (VMSF).
  4. Fabricated Audit Status The marketing materials for VMSF misleadingly claimed the fund was audited, when in fact, it was not. This created a false impression of regulatory compliance and oversight for potential investors.
  5. Inflated Assets Under Management The VMSF marketing materials also inflated the fund's assets under management (AUM), stating a higher amount than reality. This inflation was by at least $20 million, making the fund appear more successful and larger than it was.
  6. Misrepresented Investment Strategy The offering materials for VMSF misrepresented the fund's investment strategy. It was presented as a public markets fund, but it held significant investments in private assets, a crucial detail not disclosed to investors.
  7. False Filing Status VGAM's filing status as an exempt reporting adviser was also misstated. The materials claimed it had filed as such, when it had not, potentially misleading investors about the regulatory scrutiny the firm was under.


The Enforcement Action
The SEC filed settled charges against Tomislav Vukota and his two advisory firms, Vukota Capital Management, LLC, and VCM Global Asset Management Ltd., for breaching fiduciary duties and making material misrepresentations to investors. The defendants allegedly engaged in unauthorized inter-fund lending, sent misleading buyout offers, and falsified marketing materials regarding audits, assets under management, and filing status. Without admitting or denying the allegations, the defendants consented to injunctions and a total combined monetary relief of $6,943,212 in disgorgement, $1,766,582 in prejudgment interest, and $1,000,000 in penalties, subject to court approval.


Original SEC litigation release ↗ · Browse all cases