Allianz Global Investors U.S. LLC (AGI) offered institutional investors “Structured Alpha” products that provided exposure to a variety of debt or equity securities coupled with a complex options trading strategy that was designed to generate additional profits. Contrary to AGI’s representations to investors, however, the funds that employed that strategy took on more risk than disclosed, the SEC alleged in a settled enforcement proceeding against AGI. Worse, the funds’ portfolio managers repeatedly lied to investors about various critical risk metrics and later tried to conceal their fraud from the SEC, according to the SEC’s enforcement action against them. The funds lost billions during the March 2020 market turmoil and subsequently folded. To resolve parallel civil and criminal proceedings, AGI has agreed to make restitution to investors; pay forfeiture and disgorgement of more than $463 million; and pay nearly $3 billion in fines. This article details the SEC’s allegations against AGI; the enforcement action against the three portfolio managers; the AGI settlement of the SEC civil action; and the parallel criminal proceedings against AGI and the portfolio managers. See “High‑Profile Risk Management Misrepresentation Could Personally Cost Portfolio Manager $13.6 Million
” (May 26, 2022); and “SEC and CFTC Impose Stiff Penalties on Adviser for Failing to Follow Disclosed Risk Management Policies
” (Feb. 20, 2020).