SEC Secures Final Judgments in Alleged $91 Million Ponzi Scheme
SEC final judgments order Robert Welsh and Caedrynn Conner to pay disgorgement, interest and penalties tied to an alleged $91 million Ponzi investment scheme.
Summary
The U.S. District Court for the Eastern District of Texas entered final consent judgments on September 28, 2026, against Dallas Fort Worth residents Robert D. Welsh and Caedrynn E. Conner. The SEC alleged Kenneth W. Alexander II and Welsh, substantially assisted by Conner, raised at least $91 million from more than 200 investors between May 2021 and February 2024 through the Vanguard JV Cash Program and Vanguard Holdings Group Irrevocable Trust, or VHG. They allegedly marketed VHG as a highly profitable international bond trading business while using investor money for Ponzi payments. Conner created the Benchmark JV Cash Program in July 2022 to pool investments into Vanguard and allegedly knew, or was severely reckless in not knowing, indicators of fraud by year end 2022.
Without admitting the allegations, Welsh and Conner accepted permanent injunctions covering Sections 5 and 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5. They also are permanently barred from securities issuance, purchases, offers or sales, except transactions for their personal accounts. Welsh must pay $1,062,069 in disgorgement, $168,077 in prejudgment interest and a $450,000 civil penalty. Conner must pay $8,575,250, $1,357,072 and $500,000, respectively. SEC Litigation Release No. 26668, issued October 7, 2026, concerns SEC v. Kenneth W. Alexander II, et al., No. 4:25-cv-00446-JCB, filed April 29, 2025. Jason Rose leads the litigation under Keefe Bernstein of the SEC’s Fort Worth Regional Office.
Positives
- September 28, 2026 final judgments impose permanent injunctions on Welsh and Conner.
- Welsh was ordered to pay $1,062,069 in disgorgement, $168,077 in interest and a $450,000 penalty.
- Conner was ordered to pay $8,575,250 in disgorgement, $1,357,072 in interest and a $500,000 penalty.
- Permanent restrictions bar both defendants from securities activity beyond transactions for their personal accounts.
Risks & concerns
- At least $91 million was allegedly raised from more than 200 investors between May 2021 and February 2024.
- VHG allegedly used investor funds for Ponzi payments after being promoted as a highly profitable international bond trading business.
- Conner allegedly pooled money through the Benchmark JV Cash Program despite fraud indicators known, or recklessly disregarded, by year end 2022.
- Welsh and Conner consented to the judgments without admitting the SEC’s allegations.
