Naming a shell company after artificial intelligence in 2024 was not an accident. AI Investment Education Foundation Ltd. filed its Form ADV with the SEC in June 2024, presenting itself as an investment advisory firm managing $1 million in assets from an office in Denver, Colorado, advising a private fund backed by a separate registered investment adviser. It was, according to the SEC, none of those things. The business at the Denver address had no knowledge of the entity or its purported CEO. The separate registered investment adviser had never reported information about the private fund. The fund itself did not exist. On April 20, 2026, the United States District Court for the District of Colorado entered a final default judgment against AI Investment Education, permanently barring it from the SEC filing process and ordering it to pay a civil penalty of $1,182,254. The company never appeared in court to contest a single allegation.
A Form ADV Built Entirely on Fabricated Details
The Form ADV filing process is how investment advisers introduce themselves to federal regulators. An Exempt Reporting Adviser, the status AI Investment Education claimed, is a category of private fund adviser below the registration threshold that still must file disclosures with the SEC. The filing AI Investment Education submitted in June 2024 stated that it operated from office space in Denver, that it managed $1 million in client assets in the United States, that it advised a private fund, and that a separate registered investment adviser reported information about that fund on its own SEC filings.
The SEC’s investigation found that the business occupant of the Denver office space had no knowledge of AI Investment Education or its purported CEO. A search of the SEC’s public company database returned no results for the entity. The separate registered investment adviser named in the filing had not reported any information about the purported private fund. When the SEC sent a formal request for records to substantiate the information on the Form ADV, AI Investment Education did not respond.
Part of a Six-Firm Network Filing Fraudulent Forms to Enable a Stock Scheme
AI Investment Education was not an isolated case of sloppy compliance. It was one of at least six entities charged by the SEC on November 13, 2025 for filing fraudulent Forms ADV as part of a coordinated network of shell companies. The others were Bluesky Eagle Capital Management Ltd., Supreme Power Capital Management Ltd., AI Financial Education Foundation Ltd., Invesco Alpha Inc., and Adamant Stone Limited. The complaints against four of the six, including AI Investment Education, were filed in the District of Colorado. Two were filed in the Southern District of New York.
The purpose of these filings was not regulatory compliance. According to a federal indictment unsealed the following day by the Department of Justice, the fraudulent SEC forms gave the sham entities the appearance of legitimate financial advisory firms, which co-conspirators then used to solicit retail investors through WhatsApp and social media. Guanhua Su, 37, of Hong Kong, also known as Michael Su, was charged as the network’s organiser. Su operated through a Hong Kong-based firm called Rhino Consulting Business Service Ltd. and allegedly created at least 10 shell entities between February 2023 and March 2025, filing false adviser forms on their behalf.
The Ramp-and-Dump at the End of the Paper Trail
The goal of the entire filing architecture was to manufacture credibility for a stock promotion scheme. Co-conspirators posing as financial advisers affiliated with the sham firms promised investors returns of 300 to 500 percent through WhatsApp messages and told them they would be fully compensated for any losses. As retail investors bought shares in a Nasdaq-listed company based in the Cayman Islands with operations in China, foreign brokerage accounts sold the same stock simultaneously, collecting gross proceeds of as much as $211 million. On April 17, 2024, the promoted company’s stock price collapsed by approximately 88 percent. The investors who had trusted the WhatsApp advisers lost a significant portion of their money.
The name AI Investment Education Foundation was part of the same manufacturing process. In 2024, attaching “AI” to any financial brand carried implicit credibility with retail investors who associated the technology with superior analytical capability and institutional seriousness. The entity had no staff, no assets, no Denver office, and no investment capability of any kind. The name was the product.
A Default Judgment With No Defence Filed
The SEC filed its complaint against AI Investment Education on November 13, 2025 in the District of Colorado. The company did not respond to the complaint, did not appear in court, and did not provide any records in response to the SEC’s prior information request. On April 20, 2026, the court entered a final default judgment permanently enjoining AI Investment Education from future violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940, permanently barring its owners and executive officers from filing any further Form ADV as an Exempt Reporting Adviser, and ordering payment of a civil penalty of $1,182,254. The litigation was conducted by Alexandra Lavin, Xinyue Angela Lin, David London, Sarah McAteer, Ryan Murphy, Michele Perillo, and Dahlia Rin of the SEC’s Boston Regional Office, with assistance from FINRA.
Conclusion
AI Investment Education Foundation existed on paper for less than two years. It filed one Form ADV, listed an address where nobody knew it existed, claimed assets it did not manage, and named a fund that was never formed. When the SEC came looking for records, no one answered. The civil penalty of $1,182,254 entered by default on April 20, 2026 is owed by a company that was never operational. Su’s criminal case in Washington continues. The retail investors who bought stock on the strength of WhatsApp promises from people claiming to represent firms like this one are still waiting for their money back.
