Ellen Polcari, 38, of Haddonfield, New Jersey, started working for the owner of a Montana venture capital firm in late 2014, as the nanny to his two young children. In November 2015 he also hired her as an executive assistant, initially with limited responsibilities. Over the following decade those responsibilities grew until she was sending offering documents and wire instructions to investors, answering their questions about terms, wiring fund money to portfolio companies, and serving as the firm’s point of contact with its third-party administrator. In March 2024 the firm amended its Form ADV to name her its Controller and regulatory contact person. According to the Securities and Exchange Commission, between April 2023 and March 2025 she took approximately $1.28 million of investor money from the funds, routing much of it through Forks Up LLC, a Delaware company she wholly owned. About $141,300 of it went directly from fund bank accounts to online gambling. On September 18, 2026, the SEC charged her in the District of New Jersey.
The complaint charges Polcari with violating Sections 17(a)(1) and (3) of the Securities Act and Section 10(b) of the Exchange Act and Rules 10b-5(a) and (c), and seeks permanent injunctions, disgorgement with prejudgment interest, civil penalties and a conduct-based injunction barring her from participating in securities offerings. The allegations have not been tested in court. The firms and their owner are not named in the filing and are not accused of wrongdoing.
The Only Employee Who Was Not an Owner
The structure made the scheme possible. Venture Capital Firm A, based in Whitefish, Montana and formed in 2010, advised a series of single-purpose funds, each raising money to invest in one designated portfolio company. In mid 2024 the owner formed a second adviser, Venture Capital Firm B, in Kalispell, with its own set of funds. Throughout the period Polcari was the firms’ only non-owner employee. At Firm B, she and the owner were the only two people who worked there at all, and by early 2025 the only contact information on the firm’s website was her email address.
Her pay was tied to the business. The funds charged a management fee of 2 percent of investors’ capital contributions, and Polcari was entitled to up to a quarter of that fee as salary, subject to the owner’s approval. Over the period in question she received about $117,000 in authorised compensation. The SEC says none of the $1.28 million was authorised.
She Named Herself the Owner on the Bank Forms
The mechanism was the bank accounts. In April 2023, at the owner’s direction, Polcari opened an account for Fund 1 to receive investor money and make its portfolio investment. She was the sole authorised signatory. On the account opening application, without the owner’s knowledge, she identified herself as a Partner with Control of the Entity and an 80 percent owner of the fund, and listed her own home address as the fund’s mailing address. Neither the owner nor his co-owner had access to that account.
When Firm B and its funds were formed in 2024, she did the same thing again. The owner had access to only one of the new fund accounts. Polcari had sole access to the accounts for Funds 4, 5 and 6. On the applications she described herself as the 100 percent beneficial owner of Funds 4 and 5 and the Controller of Fund 6, and again gave her home address.
Those representations are what put the money beyond anyone else’s sight. Investors wired their capital to accounts that only she could see, opened by a bank that believed she owned them.
Taken the Day It Arrived
The complaint’s own chart sets out the damage fund by fund. Across the five funds concerned, investors put in approximately $28.67 million. Most of it did reach the portfolio companies. But in several cases the money was taken almost as soon as it landed.
On September 20, 2024, Fund 6 received a $100,000 investment. That same day Polcari transferred $33,500 of it to her own accounts, and on the next business day another $45,000. On September 26, a $50,000 investment arrived, and $14,500 left the following day. Fund 5 received its first investment, $250,000, on October 1, 2024, and within a day $28,000 had been moved to her account. When $800,000 arrived two days later, $97,500 followed over the next three weeks.
Fund 5 was hit hardest. Of $1.34 million raised, roughly $768,720 was misappropriated, well over half of the fund, and most of it before the fund had made its investment at all.
Robbing Four Funds to Cover a Fifth
By late December 2024 Fund 5 did not have enough money left to make the investment its investors had been told it would make. The response described in the complaint is the most revealing act in the case. On or about December 31, 2024, Polcari transferred $997,555 from four Firm A fund bank accounts into the Fund 5 account to make up the shortfall.
That transfer did not repair anything. It moved the hole from one set of investors to another, so that Fund 5 could appear whole at the point anyone looked. It is also the mark of someone who understood exactly what the money was for and exactly what would happen if a fund failed to make its stated investment.
$141,300 to Online Gambling, Straight From Fund Accounts
Of the $1.28 million, about $1.13 million was transferred from fund accounts to Polcari’s personal account or to Forks Up. The rest was spent without leaving the funds at all: approximately $141,300 in online gambling charges and about $9,120 in personal credit card payments were paid directly from fund bank accounts, the bulk of the gambling from Fund 5.
The money transferred to her own accounts went, according to the SEC, on personal credit card and loan payments, further online gambling, and numerous purchases at restaurants, grocery stores and other retailers. The investors were high net worth individuals and family offices who had been told, in documents Polcari herself sent them, that their capital would be used to pursue long-term appreciation through a single venture investment.
She Signed Her Boss’s Name on the Stock Transfers
The cash was not the only thing taken. Fund 2 held common stock it had received from one of its portfolio investments. On or about August 26, 2024, Polcari submitted a stock transfer agreement to the issuer stating that Fund 2 wished to transfer 2,273 of those shares to Forks Up. She signed it on behalf of the fund using the owner’s DocuSign e-signature, without his knowledge or consent.
Four days later she agreed to sell 2,000 of those shares to a third party for $56,000. The sale closed on November 6, 2024. In January 2025 she tried again, submitting a second agreement, again signed with the owner’s e-signature, to transfer a further 15,333 shares to Forks Up. That request was still sitting in the issuer’s processing queue when the scheme came apart, which is the only reason the owner was able to stop it.
Her Own Lawyer Told the Firm
The end came from an unusual direction. In late February 2025, Polcari and the owner learned that SEC staff were investigating matters relating to the firms and the funds. About three weeks later, on or about March 21, 2025, it was Polcari’s own counsel who informed the firms that she had misappropriated a significant amount of money. The owner terminated her and cut off her access to every account.
On or about March 30, 2025, she telephoned the owner and admitted that she had stolen at least some of the money. The complaint designates the United States Attorney’s Office for the District of New Jersey to receive service of papers, which is a standard filing formality and does not in itself indicate a criminal case. None has been announced.
Her background adds one further detail. Between May 2019 and June 2023 she was also associated, in an administrative role, with a dually registered broker-dealer and investment adviser unrelated to the firms, a detail also noted in independent coverage of the charges. She was not new to regulated financial services when the first transfer was made.
Conclusion
Ellen Polcari came into this business as a nanny and ended it as the named Controller of two venture capital advisers, the only person besides the owner who worked at one of them. The SEC says she opened fund bank accounts naming herself as their owner, gave her home as their address, and took investor money the day it arrived, in one case $78,500 out of a $100,000 investment within two business days. When one fund could no longer make its investment she moved nearly a million dollars in from four others to hide the gap. She paid $141,300 of online gambling straight from the fund accounts, and signed her employer’s name to transfer fund stock into her own company. When the SEC started asking questions, her lawyer told the firm before anyone found out. Nine days later she called her former employer and admitted it.
