Changeflow GovPing Banking & Finance BitClave PTE LTD Third Fair Fund Disbursement
Routine Enforcement Amended Final

BitClave PTE LTD Third Fair Fund Disbursement

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Summary

The SEC orders a third distribution of $11,969.62 from the BitClave fair fund to two harmed investors not included in prior disbursements. The Fund Administrator, after reserving $407,485.37 for taxes and administrative costs, determined this subsequent distribution is feasible. Upon completion of all three distributions, affected investors will have received 125.25% of their Recognized Loss.

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What changed

The SEC issued an order directing the third disbursement of $11,969.62 from the BitClave fair fund to two harmed investors previously excluded from prior distributions. The Fund Administrator submitted a payment file with reasonable assurances to Commission staff, who reviewed and accepted it pursuant to Rule 1101(b)(6). Combined with prior disbursements of $4,614,679.81 and $2,500,422.70, the total distributions result in a 125.25% recovery of Recognized Loss for affected investors.

Harmed investors included in future disbursements from the BitClave fair fund may anticipate recovery at or above their Recognized Loss amounts, as distributions continue until the remaining balance is fully disbursed per the approved Plan of Distribution.

Archived snapshot

Apr 22, 2026

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UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 105284 / April 21, 2026 ADMINISTRATIVE PROCEEDING File No. 3-19816

: In the Matter of ORDER DIRECTING THIRD : DISBURSEMENT OF FAIR FUND : BitClave PTE LTD., : : Respondent. :

On December 1, 2022, the Division of Enforcement, pursuant to delegated authority, published a Notice of Proposed Plan of Distribution and Opportunity for Comment ("Notice"), 1 pursuant to Rule 1103 of the Commission's Rules on Fair Fund and Disgorgement Plans ("Commission's Rules"); and simultaneously posted the Proposed Plan of Distribution (the 2 "Proposed Plan"). The Notice advised interested persons that they could obtain a copy of the Proposed Plan from the Commission's public website or by submitting a written request to Sondra Panahi, United States Securities and Exchange Commission, 801 Brickell Ave, Suite 1950, Miami, FL 33131. The Notice also advised that all persons desiring to comment on the Proposed Plan could submit their comments, in writing, within 30 days of the Notice. The Commission received no comments on the Proposed Plan during the comment period. On

: Exchange Act Rel. No. 96423 (Dec. 1, 2022). 1 17 C.F.R. § 201.1103. 2

February 9, 2023, the Division of Enforcement, pursuant to delegated authority, issued an order approving the Proposed Plan, and posted the approved Plan of Distribution (the "Plan"). 3 On November 19, 2024, the Commission issued an Order Directing Disbursement of Fair Fund ("First Disbursement Order"). Pursuant to the First Disbursement Order, the Fund 4 Administrator disbursed $4,614,679.81. On September 23, 2025, the Commission issued an Order Directing Second Disbursement of Fair Fund ("Second Disbursement Order"). Pursuant to the Second 5 Disbursement Order, the Fund Administrator disbursed $2,500,422.70. The Fair Fund has a current balance of $5,981,080.01. Pursuant to paragraphs 87 and 88 of the Plan, the Fund Administrator, in consultation with the Commission staff, has determined that a subsequent distribution (the "Third Distribution") of the remaining funds is feasible. Given the amount remaining in the Fair Fund and after taking into account a reserve of $407,485.37 for any taxes or administrative costs, the Fund Administrator recommends further distribution of the Fair Fund in the amount of $11,969.62 to two (2) harmed investors who were not included in the previous disbursements. 6 Pursuant to the Plan, the Fund Administrator has submitted a payment file to Commission staff with a reasonable assurances letter as to the completeness and accuracy of the information contained therein. The Commission staff has reviewed and accepted the payment file and requests, pursuant to Rule 1101(b)(6) of the Commission's Rules, 17 C.F.R. § 201.1101(b)(6), that the Commission authorize the transfer of $11,969.62 from the Fair Fund to

See Order Approving Corrected Plan of Distribution, Exchange Act Rel. No. 96869 (Feb. 9, 2023). 3 Exchange Act Rel. No. 101653 (Nov. 19, 2024). 4 Exchange Act Rel. No. 104025 (Sept. 23, 2025). 5 Please note that the Fund Administrator has been informed by the Tax Administrator that no federal or state tax 6 withholdings are required.

the Fair Fund's escrow account at The Huntington National Bank, N.A. for distribution by the Fund Administrator in accordance with the Plan. Collectively, from all three distributions, the Payees will have received 125.25% of their Recognized Loss. Accordingly, it is hereby ORDERED, that Commission staff shall transfer $11,969.62 from the Fair Fund to the Fair Fund's escrow account, and the Fund Administrator is directed to distribute $11,969.62 to harmed investors in accordance with the Plan. For the Commission, by the Division of Enforcement, pursuant to delegated authority. 7 Vanessa A. Countryman Secretary

17 C.F.R. § 200.30-4(a)(21)(v). 7

CFR references

17 CFR 201.1103 17 CFR 201.1101(b)(6) 17 CFR 200.30-4(a)(21)(v)

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Last updated

Classification

Agency
SEC
Filed
April 21st, 2026
Instrument
Enforcement
Branch
Executive
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
Release No. 34-105284
Docket
3-19816

Who this affects

Applies to
Investors Public companies
Industry sector
5231 Securities & Investments
Activity scope
Fair fund disbursement Investor restitution SEC enforcement distribution
Geographic scope
United States US

Taxonomy

Primary area
Securities
Operational domain
Finance
Compliance frameworks
Dodd-Frank
Topics
Financial Services Anti-Money Laundering

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