SEC Files Subpoena Enforcement Action against Wynn Gustafson

Wynn Gustafson - Subpoena

On October 31, 2017, the Securities and Exchange Commission (“SEC”) announced that the SEC filed an action to enforce compliance with a document subpoena issued and served upon Wynn Gustafson in an SEC investigation captioned In the Matter of WAG Trading and Investments Company LLC.

As set forth in the SEC’s papers, Wynn Gustafson is the President of WAG Company LLC, formerly known as WAG Trading and Investment Company LLC (“WAG Trading”). According to documents produced to the SEC, WAG Trading is in the business of conducting international transactions buying, selling, and redeeming so-called “historical bonds” in China, Hong Kong, Ghana, Singapore, and Germany. As set forth in the SEC’s papers, “historical bonds” are often used to perpetuate fraudulent schemes.According to the application filed by the SEC, in the course of its investigation, the SEC discovered a number of suspicious transactions in Wynn Gustafson’s bank accounts. Often, large sums appear to have been deposited and then wired out of Mr. Gustafson’s account in quick succession. At least some of the transfers from Mr. Gustafson’s bank accounts were wires to foreign entities in China, Hong Kong, or Ghana.

The SEC alleges that at least some of the transfers into Mr. Gustafson’s accounts have been wires from private U.S. citizens who appear to be victims of fraudulent schemes, including advance fee schemes.

Despite repeated requests by the SEC, Wynn Gustafson has failed to produce subpoenaed documents, including emails from an individual in China, which Mr. Gustafson claims to possess, that purportedly directed him to send funds to various overseas accounts, and documents related to an overseas bank account that he claims was set up in his name that purportedly had a balance of $22 million.

The SEC seeks an Order from the District Court of Minnesota requiring Wynn Gustafson to comply with the subpoena issued to him as well as granting any other relief needed to achieve compliance with the subpoena.

The SEC’s investigation in this matter is continuing.

For further information about this securities law blog post, please contact Brenda Hamilton, Securities Attorney at 101 Plaza Real S, Suite 202 N, Boca Raton, Florida, (561) 416-8956, by email at [email protected] or visit   This securities law blog post is provided as a general informational service to clients and friends of Hamilton & Associates Law Group and should not be construed as, and does not constitute, legal and compliance advice on any specific matter, nor does this message create an attorney-client relationship. Please note that the prior results discussed herein do not guarantee similar outcomes.

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Brenda Hamilton, Securities Attorney
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