Ponzi Scheme Promised Medical Cures, Delivered Pocket Cash!

SEC v. Justin R. Kimbrough, Prosperity Consultants, LLC — U.S. Securities and Exchange Commission Litigation Release No. 26402, dated September 17, 2025.

The SEC charged Justin R. Kimbrough and others with running a multi-million dollar Ponzi scheme. Kimbrough and his company, Prosperity Consultants, LLC, defrauded at least 31 investors out of $3 million by falsely promising to invest their money in a real estate wholesale business and medical product resale. Instead, Kimbrough and his co-defendants misappropriated funds for personal use and paid existing investors with new investors' money. Kimbrough and Prosperity have consented to final judgments, permanently enjoining them from future securities law violations and requiring them to pay disgorgement, which is deemed satisfied by a forfeiture order in a parallel criminal case.

In Plain English

Imagine someone promises to invest your money in a cool business, like buying and selling medical supplies. They tell you your money will grow. But instead of investing it, they take a lot of it for themselves and use some of it to pay off earlier investors, making it look like the business is doing well. This is called a Ponzi scheme. The SEC stepped in and stopped this, getting judgments against the people involved to prevent them from doing it again.

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. Promised Investments From June 2020 through at least April 2021, Justin R. Kimbrough and Terry Nikopoulos pitched an investment opportunity to potential investors. They claimed that investor funds would be used to finance a real estate wholesale business and to purchase medical products for resale by a company located in India.
  2. Misappropriation of Funds Instead of using the investors' money as promised, Kimbrough and Nikopoulos allegedly retained at least $1.75 million of the funds for their own benefit. This directly contradicted their representations about how the money would be used.
  3. Ponzi Payments To maintain the illusion of a successful business and encourage further investment, Kimbrough and Nikopoulos used approximately $1.05 million of the investors' money to pay purported 'dividend' or 'interest' payments to existing investors. These payments were made from new investor funds, a hallmark of a Ponzi scheme.
  4. Investor Deception The defendants made false and misleading statements to investors regarding the investment opportunities, the prospects of the purported businesses, and the use of investor funds. They also failed to disclose the misappropriation of investor funds and the fact that payments to existing investors were funded by new investors.
  5. SEC Complaint Filed On July 1, 2022, the Securities and Exchange Commission filed a civil complaint against Justin R. Kimbrough, Terry Nikopoulos, and four entities controlled by Nikopoulos, detailing the alleged Ponzi scheme and securities fraud.
  6. Consent Judgments Entered On August 5, 2025, the SEC announced that final consent judgments were entered against Justin R. Kimbrough and Prosperity Consultants, LLC. These judgments permanently enjoin them from violating antifraud and registration provisions of federal securities laws.

The Enforcement Action

On August 5, 2025, the SEC obtained final consent judgments against Justin R. Kimbrough and Prosperity Consultants, LLC, in a case alleging a Ponzi scheme that raised at least $3 million from at least 31 investors. The judgments permanently enjoin Kimbrough and Prosperity from violating antifraud provisions of the Securities Act of 1933 and the Securities Exchange Act of 1934. Kimbrough is also permanently enjoined from violating securities registration and broker-dealer registration provisions. The judgments impose an officer and director bar on Kimbrough and a conduct-based injunction. Kimbrough and Prosperity are ordered to pay jointly and severally disgorgement of $1,137,437.45 plus prejudgment interest of $86,882.82, which amounts are deemed satisfied by a forfeiture order of $2,560,938.87 against Kimbrough in a parallel criminal proceeding. The civil action remains pending against Kimbrough’s and Prosperity’s co-defendants, Terry Nikopoulos and four entities controlled by Nikopoulos.

Named in this action: Justin R. Kimbrough, Prosperity Consultants, LLC.