From March 2014 through April 2016, HIRST, along with his co-conspirators Jason Galanis, John Galanis, a/k/a "Yanni," Hugh Dunkerley, Michelle Morton, Devon Archer, and Bevan Cooney, engaged in a fraudulent scheme to misappropriate the proceeds of bonds issued by the Wakpamni Lake Community Corporation ("WLCC"), a Native American tribal entity (the "Tribal Bonds"), and to use funds in the accounts of clients of asset management firms controlled by HIRST and others to purchase the Tribal Bonds, which the clients were then unable to redeem or sell because the bonds were illiquid and lacked a ready secondary market.The WLCC was convinced to issue the Tribal Bonds through false and fraudulent representations by John Galanis. Once the Tribal Bonds were issued, HIRST and Morton used funds belonging to clients of two related investment advisers, Hughes Capital Management, Inc. ("Hughes") - where HIRST served as Chief Investment Officer - and Atlantic Asset Management, LLC ("Atlantic"), to purchase the Tribal Bonds, even though HIRST and Morton were well aware that material facts about the Tribal Bonds had been withheld from clients in whose accounts they were placed, including the fact that the Tribal Bond purchases fell outside of the investment parameters set forth in the investment advisory contracts of certain Hughes clients and of the Atlantic pooled investment vehicle in which the Tribal Bonds were purchased. In addition, HIRST and his co-defendants failed to apprise clients of Hughes and Atlantic regarding substantial conflicts of interest with respect to the issuance and placement of the Tribal Bonds before the Tribal Bonds were purchased on these clients' behalf.Hughes and Atlantic clients were provided no prior notice that HIRST and Morton caused them to purchase the Tribal Bonds. When these clients learned about the purchase of the Tribal Bonds in their accounts, several of them demanded that the Tribal Bonds be sold. However, because there was no ready secondary market for the Tribal Bonds, no Tribal Bonds have been sold from any Hughes or Atlantic client accounts.