Jeremiah Silkowski Settles SEC Charges Over Alleged Recidivist Violations of the Advisers Act

Jeremiah Silkowski, the President, Chief Executive Officer, Chief Compliance Officer and majority owner of SQN Capital Management LLC, consented to a court-appointed receiver liquidating the funds the firm manages to resolve SEC charges of violating antifraud and other provisions of the Advisers Act, the agency said in a release Oct. 9.

The SEC filed its complaint against Silkowski and the firm in federal court in Manhattan on Sept. 18, and the court entered consent judgments against both on Oct. 8, according to litigation release LR-26671. The SEC alleges that from at least 2019 through 2025, Silkowski and SQN Capital repeatedly breached their fiduciary duties to four investment funds they managed by failing to comply with fund documents and inflating the funds' net asset values.

According to the complaint, the only asset valuations for the funds were prepared by Silkowski alone rather than by an independent valuation expert. The complaint alleges that Silkowski "simply kept the net asset values unchanged for years" regardless of market conditions or asset performance.

The complaint also says the SEC twice charged SQN Capital in settled administrative proceedings with violating Advisers Act rules, first in 2020 and again in 2023. According to the complaint, Silkowski was charged in the second proceeding with aiding and abetting and causing those violations.

Without admitting the allegations in the complaint, Silkowski and SQN Capital consented to the receiver order and to final judgments permanently enjoining them from the charged violations, the release says. The judgments order Silkowski to pay a $200,000 civil penalty and permanently bar Silkowski from acting as or associating with an investment adviser, broker or dealer, except as the receiver deems necessary.