Arete Wealth Management Lawsuit: Zona Energy, GWG, and GPB Claims

The lawsuit against Arete Wealth Management is a Securities and Exchange Commission enforcement action filed on January 17, 2025 in the U.S. District Court for the Northern District of Illinois, alleging that the Chicago-based broker-dealer, its advisory affiliate, three former representatives, and its chief compliance officer participated in and then tried to paper over an $8 million scheme selling shares of a sham oil-and-gas company to firm clients. The case remains active as of mid-2026, with most of the SEC’s core claims surviving motions to dismiss and no trial date set.¹

Who the SEC Sued

The complaint names six defendants: Arete Wealth Management LLC, Arete Wealth Advisors LLC, three former registered representatives (Joey Miller, Jeffrey Larson, and Randall Scott Larson), and the firm’s chief compliance officer and general counsel, UnBo “Bob” Chung.²

The charges break down by role. Miller and Jeffrey Larson face the broadest exposure, charged with violating antifraud provisions of the Securities Act, Exchange Act, and Investment Advisers Act, plus acting as unregistered broker-dealers and aiding and abetting the firms’ violations. Randall Larson faces the same unregistered-broker and aiding-and-abetting counts plus Advisers Act antifraud charges, but not the Securities Act antifraud counts or Rule 10b-5. Chung is charged with aiding and abetting Arete Wealth Advisors’ antifraud and compliance violations. Arete Wealth Advisors faces Advisers Act antifraud and compliance charges, and Arete Wealth Management faces recordkeeping charges for failing to retain business communications sent from personal devices.³

The SEC is seeking permanent injunctions, civil penalties, penny stock bars, and officer-and-director bars against Miller and the Larsons, and permanent injunctions and civil penalties against Chung. Firm founder Joshua Rogers is not personally charged.³

The Zona Energy Sales

The investment at the center of the case was Zona Energy Inc., a Texas company claiming to acquire Permian Basin oil and gas reserves. Zona was actually controlled by Richard Dale Sterritt Jr., a convicted felon operating under an alias who had previously served five years in federal prison for securities fraud, money laundering, and false tax returns. Sterritt later pleaded guilty in November 2023 and was sentenced in June 2025 to 18 years for the Zona scheme.⁴

From October 2018 to May 2020, according to the complaint, Miller and the two Larsons agreed to raise capital for Zona in exchange for deeply discounted shares. They solicited dozens of Arete clients and ultimately sold more than $8 million in Zona stock. Arete never approved the offering for sale to clients, which securities regulators call “selling away.”²

To keep the activity off the firm’s radar, the representatives allegedly used personal phones and non-Arete email accounts and told clients to do the same.⁵ The SEC alleges Miller and Jeffrey Larson made false and misleading statements to prospective investors and led clients to believe they were recommending Zona without any personal compensation, when in fact they were being paid in discounted stock.² Investors lost nearly everything they put in.

The Alleged Cover-Up

After Arete leadership learned about the unauthorized Zona sales, the SEC alleges the firm did not report the problem or make clients whole. Instead, Chung and firm management directed the three representatives to obtain settlement releases from more than 100 affected clients, who received nominal payments of between $1 and $5,000 in exchange for signing.⁵

The releases, according to the SEC, told clients the Arete representatives had not been acting as financial advisors when they recommended Zona. They acknowledged that Miller and Jeffrey Larson had bought Zona stock at a discount but did not disclose those shares were compensation for raising millions of dollars. The releases also included a broad liability disclaimer that misled clients into believing they had waived claims that cannot legally be waived under securities law. Chung, according to the complaint, claims he did not read the documents the 100-plus clients signed.³

Where the Case Stands

The case is assigned to U.S. District Judge Lindsay C. Jenkins. Defendants filed motions to dismiss, which the court denied without prejudice on April 22, 2025 after the SEC signaled it would amend. The SEC filed a First Amended Complaint on April 28, 2025. The court declined to stay fact discovery, and both sides have requested a jury trial.¹

In February 2026, Judge Jenkins ruled on a second round of motions to dismiss. The SEC’s core fraud claims were allowed to proceed. The judge upheld both the recordkeeping charge against Arete Wealth Management and the aiding-and-abetting recordkeeping charge against the individual representatives, rejecting arguments that the recordkeeping rule was unconstitutionally vague. She found the text messages at issue covered “fundamental broker-dealer business matters: customer solicitations, investments, approvals, and fundraising,” and concluded it was reasonable to infer the representatives knew the messages would not be retained given Arete’s policy against using personal devices for business.⁶

The judge did dismiss one SEC fraud theory that pinned Exchange Act antifraud liability on Miller and Jeffrey Larson specifically for their use of off-channel communications. Claims tied to the settlement releases were also dismissed.⁷ No trial date has been set as of mid-2026.¹

Other Investor Claims Against Arete

The SEC case is not Arete’s only investor exposure. The firm has lost a series of FINRA arbitration claims involving alternative investments sold by its advisors.

GWG L Bonds

GWG Holdings, which issued high-yield bonds backed by life insurance settlements, filed for bankruptcy in 2022. Arete’s exposure grew after its April 2021 acquisition of Center Street Securities, a Nashville broker-dealer whose advisors had been significant sellers of GWG L Bonds before Center Street shut down in late 2023.⁸

In February 2024, a FINRA panel ordered Arete to pay $75,000 plus interest to a GWG L Bond investor who called the bonds “outrageously speculative.”⁸ In August 2025, a separate panel awarded $280,000 to an investor whose broker had allegedly put nearly 100 percent of his liquid net worth into the bonds. The nine-day hearing included testimony from Arete’s CEO, its compliance officer, and the broker; the panel denied Arete’s counterclaim that the trades were unsolicited.⁹

GPB Capital Holdings

In 2021, a FINRA panel awarded $515,000 in damages plus more than $250,000 in attorneys’ fees to two claimants who alleged Arete sold them high-risk private placements managed by GPB Capital Holdings without adequate due diligence. GPB, which raised $1.8 billion beginning in 2013, was later accused by the SEC and federal prosecutors of running a Ponzi-like scheme. The claimants argued Arete identified serious red flags about GPB yet approved the product for sale anyway.⁸

2024 Payouts

In the first three months of 2024, Arete reported paying more than $1.1 million in investor settlements. A firm spokesperson attributed most of that to a single previously terminated financial advisor, and the firm said it recovered $987,000 through its errors-and-omissions insurance.⁸

Where the Individuals Are Now

Joey Miller was discharged from Arete in October 2023 after the firm found he had been “not forthcoming during an internal investigation.” He registered with DAI Securities LLC and DAI Wealth LLC in late 2023. His FINRA BrokerCheck record lists five disclosures, including the pending SEC action, a pending customer dispute seeking $779,212, and two prior settlements totaling $435,000.¹⁰

Jeffrey and Randall Larson also left Arete in October 2023 and are now managing partners of a private wealth management firm that had previously operated as an Arete branch office. Randall Larson is also an attorney and a member of the Missouri bar.⁵

Bob Chung remained at Arete until February 2026. As of mid-2026, he holds no state licenses or FINRA registrations. His record shows the pending SEC action and two customer disputes settled in late 2024 for a combined $164,999, both of which he has denied.¹¹

Joshua Rogers, who founded Arete in 2007 by purchasing Keystone Securities, stepped down as CEO in February 2026 and became executive chairman of the firm’s board.¹²

1
CourtListener. SEC v. Arete Wealth Management LLC, Docket
2
SEC.gov. SEC Charges Arete Wealth Management and Others
3
SEC.gov. SEC v. Arete Wealth Management LLC, et al., Litigation Release
4
U.S. Department of Justice. Serial Fraudster Sentenced to 18 Years in Prison
5
Wolters Kluwer Securities Regulation Daily. SEC Complaint
6
Harvard Law School Forum on Corporate Governance. Litigated Off-Channel Communications Charge Survives Motion to Dismiss
7
Law360. Arete Wealth GC Can’t Slip SEC Claims in Offering Fraud Suit
8
InvestmentNews. Arete Wealth Pays Out $1.1M in Arb Claims to Start 2024
9
Stock Law. Jonathan W. Evans and Associates Notches Arbitration Win
10
FINRA BrokerCheck. Joey Dale Miller, Individual Summary
11
FINRA BrokerCheck. UnBo (Bob) Chung, Individual Summary
12
WealthManagement.com. Arete Wealth’s Founder Steps Down From CEO Position