SEC Sanctions Shima Capital and Yida Gao for Misrepresentations

UNITED ST ATES OF AMERI CA Befo re the SECURITI ES AND E XCHANGE COM MISSION INVESTME NT ADVIS ERS ACT OF 194 0 Relea se No. 6951 / Ma rch 4, 2026 ADMINIST RATIVE PROCEE DING File No. 3- 22606 In th e Mat ter o f SHIMA C APITAL MANAGEMENT LLC, Respo ndent. ORDER I NSTITUT ING ADMINIST RATIVE PROCEE DINGS PURSUANT TO SECT ION 203 (e) OF THE INVESTME NT ADVIS ERS ACT OF 194 0, MAKING FIN DINGS, AND IMPOS ING REMEDI AL SANCT IONS I. The Securities and Exchange Commiss ion (“Com mission”) deems i t appro priate and in th e public interest th at public administrative pro ceedings be, and hereby a re, instit uted pursuant to Section 203(e) of the Investment Advise rs Act of 1 940 (“Advisers A ct”) against Shima Capital Manag ement LLC (“Shim a Capit al” or “Respond ent”). II. In anticipation o f the insti tution of thes e proceedings, Respondent has submitted an O ffer of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the purpose of these p roceedings and any other p roceedings br ought by or on b e hal f of th e Commission, or t o which the Commi ssion is a part y, and without admitting or denying th e findings herein, except as to the Comm ission’s jurisdi ction over it and the subject matter of these proceedings and th e findings cont ained in paragrap h 2 below, w hich are admitted, Res pondent consents to the entry of this Order I nstitu ting Ad min istra tive Pr ocee ding s Pur suan t to Sect ion 203(e) of the I nvestment Advisers Act of 194 0, Making F indings, and I mposing Re medial Sanctions (“Order”), as s et forth b elow.

2 III. On the basis of t his Order and Respondent ’s Offer, the Commissi on finds tha t: 1. Shima Ca pita l is a n inve st ment ad viser registe red with the Commission since September 27, 20 22, and is wholly o wned and c ontrolled by Yid a Gao, its M anaging Dire ctor and Chief E xe cutiv e Offi cer. Sh ima Cap ital was form ed and organiz ed in Dece mber 2021, unde r the laws of Puerto Ri co. 2. On February 24, 202 6, a final judgm ent was entere d by consent against S hi ma Capit al, permanently enjoining it from future viol ations of S ection 10(b) o f the Securiti es Exchange Act of 1934 and Rule 10 b - 5 thereunder; Section 17(a) of th e Securities A ct of 1933; and Section 206(4) o f the Advisers Act and Rule 206(4) - 8 thereunder by committ ing or engaging in specified actions or activities relevant to such violations, as set forth in the judgment entered in the civil action entitled Securities and Ex change Commission v. Yi da Gao, et al., Civil Action Num ber 3:25 - cv - 10200 - VC, in the United States District Court for the North ern Dis trict of Cal iforni a. 3. The Commission’s complaint alleg ed that G ao and Shi ma Capi tal made m ate rial misrepresentations to current a nd prospectiv e investors in t wo private funds and one of fshore investment entity that were manag ed by them. G ao and Shima Capit al touted investment returns for certain of Gao’s prior investments that were sign i ficantlly h igher than the returns Gao had actually achiev ed. When conf ronted with the i nflated fig ures, Gao and Shim a Capital fals ely told certai n in vesto rs th at th e i nflat ed fi gures wer e mer e “cl eri cal er rors.” IV. In view of th e foregoing, the Comm ission deems it appropriate and in the pu blic interest to impose the sanction s agreed to in R espondent Shi ma C apit al’s Of fer. Accordingly, it is h ereby ORDER ED pursuant to S ection 203(e) of the A dvis ers Act, that Respondent Sh ima Cap ital ’ s registra tion wi th the Commission a s an investme nt adviser be and hereby is r evoked. By the Commission. Vanessa A. Countrym an Secret ary