SEC Charges Three New Jersey Men in $47 Million Affinity Fraud Targeting Orthodox Jewish Communities

WASHINGTON, D.C. — In a sweeping crackdown on predatory financial schemes, the Securities and Exchange Commission (SEC) announced civil charges today against three residents of Toms River, New Jersey, for their roles in a sophisticated, multi-year affinity fraud. The operation allegedly raised approximately $47 million from more than 87 investors, predominantly targeting members of Orthodox Jewish communities across New Jersey, New York, and several other states.

According to the SEC’s complaint, filed in the U.S. District Court for the District of New Jersey, the scheme was orchestrated by Leor Moshe through his company, Capital Funding ASAP LLC. Between November 2019 and June 2023, Moshe leveraged close community ties to lure investors with promises of low-risk, high-yield returns fueled by short-term small business loans. Instead of deploying the capital as promised, Moshe allegedly diverted millions of dollars for personal luxury and to perpetuate a classic Ponzi-style payout structure.

To expand the reach of the fraudulent enterprise, Moshe enlisted two local associates, Jacob Goldman and Isaac Odes. Operating without the necessary regulatory credentials, Goldman and Odes allegedly acted as unregistered brokers, leveraging their own community networks to rake in tens of millions of dollars from unsuspecting victims.

Simultaneously with the SEC’s civil enforcement action, the U.S. Attorney’s Office for the District of New Jersey announced parallel criminal charges against Moshe for his role in the scheme. Federal authorities, aided by the Federal Bureau of Investigation (FBI), are continuing to unravel the devastating financial and emotional toll the fraud has inflicted on tight-knit religious communities.

Chronology of a Multi-Year Deception

The timeline laid out by federal regulators details a calculated progression of deceit that spanned nearly four years, moving from initial concept to eventual collapse.

November 2019: Inception and the Pitch

The scheme took root in late 2019 when Leor Moshe established Capital Funding ASAP LLC. Positioned ostensibly as a vehicle to provide short-term liquidity and bridge loans to struggling small businesses, the company quickly became a vehicle for fraud. Moshe targeted members of his own religious and social circles within the Orthodox Jewish communities of New Jersey and New York. By leaning on shared cultural touchstones and communal trust—the defining element of an affinity fraud—Moshe was able to bypass the traditional skepticism that investors might otherwise apply to unfamiliar financial advisors.

Moshe promised prospective investors fixed, above-market returns, dangling profit margins that in some instances exceeded 30 percent. To build a veneer of legitimacy, initial investments were solicited under the guise of funding tangible, short-term commercial loans that purportedly offered rapid turnaround times and high safety margins.

2020–2022: Expansion and Unregistered Recruiters

As the operation gained traction, Moshe sought to scale up his fundraising efforts. To do this, he brought in fellow Toms River residents Jacob Goldman and Isaac Odes. Neither Goldman nor Odes was registered as a broker-dealer or associated with any SEC-registered firm, a legal requirement designed to protect investors from unlicensed intermediaries.

Despite lacking the requisite credentials, Goldman and Odes aggressively marketed Capital Funding ASAP to their own spheres of influence. Court documents show that the pair solicited more than $23 million from at least 25 individual investors. They actively negotiated investment terms, answered investor inquiries, and facilitated the mechanics of fund collection, effectively acting as an unlicensed sales force for Moshe’s enterprise.

June 2023: The Collapse and Discovery

By mid-2023, the illusion of a thriving alternative lending enterprise could no longer be sustained. The influx of new capital slowed down, making it increasingly difficult to service the promised returns or sustain the lavish lifestyles funded by investor principal. As the cracks in the facade widened, the SEC and federal investigators stepped in, culminating in the formal filing of civil and criminal charges in August 2026 after a comprehensive multi-agency investigation.

Supporting Data and Financial Breakdown

The sheer scale of the Capital Funding ASAP scheme places it among the more devastating affinity frauds prosecuted in the region in recent years. Financial data compiled in the SEC complaint paints a stark picture of deception, misuse of funds, and widespread geographic impact.

The Numbers Behind the Fraud

• Total Capital Raised: Approximately $47 million.
• Total Investors: More than 87 individuals, primarily from Orthodox Jewish communities.
• Amount Misappropriated by Moshe: More than $11 million diverted for personal use.
• Ponzi-Like Distributions: More than $850,000 used to pay off earlier investors to maintain the illusion of profitability.
• Funds Secured via Unregistered Brokers: More than $23 million raised by Jacob Goldman and Isaac Odes across at least 25 investors.
• Total Net Investor Losses: More than $25 million.
• Geographic Spread of Victims: Investors spanning Arizona, Connecticut, Florida, Illinois, New Jersey, New York, and Ohio.

The financial architecture of the scheme relied heavily on the traditional mechanics of a Ponzi game. When capital came in from new participants, a fraction was siphoned off to pay artificial "returns" to older investors, creating a false sense of security that encouraged both groups to keep their money in the fund and recommend it to others. Meanwhile, millions in investor principal vanished into Moshe’s personal accounts, funding lifestyle expenses entirely divorced from the purported small business lending operations.

Official Responses and Regulatory Warnings

Federal regulators and law enforcement agencies have expressed deep concern over the predatory nature of affinity frauds, which weaponize cultural, religious, and social trust for financial gain.

Thomas P. Smith, Jr., Associate Director of the SEC’s New York Regional Office, underscored the absurdity of the financial promises made by the defendants and the betrayal of community trust involved.

"As our complaint alleges, the defendants promised some investors that they could see returns in excess of thirty percent which definitely falls into the ‘if it sounds too good to be true, it probably is’ category," Smith said. "In reality, the Jersey Shore triumvirate took advantage of their relationships within Orthodox Jewish communities to raise money for Moshe’s scheme and enrich themselves."

The SEC’s legal action seeks comprehensive remedies against all three defendants. For Leor Moshe, the complaint demands permanent injunctive relief, the disgorgement of all ill-gotten gains coupled with prejudgment interest, civil monetary penalties, and a conduct-based injunction designed to bar him from engaging in similar activities. For Goldman and Odes, the SEC is pursuing permanent injunctions, disgorgement with interest, and civil penalties for violations of the broker registration provisions outlined in the Securities Exchange Act of 1934.

Concurrently, the U.S. Attorney’s Office for the District of New Jersey is pressing criminal charges against Moshe, signaling that prison time is a very real possibility for the scheme’s principal architect. Federal prosecutors have lauded the collaborative efforts of the FBI and SEC in bringing the case to light.

Protecting Vulnerable Communities

Recognizing that tight-knit cultural and religious groups are frequent targets for fraudulent actors who rely on insider status to avoid scrutiny, regulatory bodies have ramped up educational outreach.

The SEC’s Office of Investor Education and Assistance maintains dedicated resources to help insulate specific communities from predatory actors. Investors are encouraged to consult the SEC’s Investment Scams Targeting Groups webpage for guidance on identifying and avoiding culturally targeted schemes. Furthermore, regulators reiterate that anyone considering an investment should independently verify the credentials and disciplinary history of individuals offering financial products by utilizing Investor.gov.

Broader Implications for Market Integrity and Affinity Fraud

The case of Capital Funding ASAP LLC highlights a persistent vulnerability in the modern financial ecosystem: the erosion of objective due diligence in favor of subjective trust.

The Danger of Affinity Fraud

Affinity frauds succeed because fraudsters exploit the natural bonds of shared identity. Whether rooted in religious affiliation, ethnic background, professional associations, or geographic communities, victims are often conditioned to lower their guard. When a promoter shares a victim’s faith, cultural background, or social circle, basic questions regarding licensing, regulatory compliance, and audited financial statements are frequently left unasked.

In this case, the defendants allegedly used their standing within the Orthodox Jewish communities of New Jersey and New York to short-circuit standard risk assessments. Victims trusted that because Moshe, Goldman, and Odes were members of their community, the investments were inherently safe. This misplaced trust allowed a fraudulent operation to flourish for years, eventually extracting tens of millions of dollars before regulatory intervention halted the cash flow.

The Role of Unregistered Intermediaries

A critical element of the SEC’s prosecution involves the targeting of Goldman and Odes as unregistered broker-dealers. Under federal securities law, individuals who assist in raising capital, soliciting investors, and negotiating terms must be properly registered with the SEC and associated with a registered broker-dealer. This requirement is not merely bureaucratic; it ensures that individuals selling financial products are subject to background checks, supervisory oversight, and regulatory standards designed to protect the public.

By utilizing unregistered middlemen, Moshe was able to tap into pools of capital that might otherwise have remained inaccessible had licensed financial professionals been involved, as professional advisors would likely have spotted and flagged the glaring discrepancies in Capital Funding ASAP’s business model.

A Warning to the Market

As the legal proceedings in federal court unfold, the case serves as a sobering reminder to investors across the country. Regulators hope that the joint civil and criminal enforcement actions will send a deterrent message to other bad actors who might seek to exploit community trust for personal enrichment. For investors, the message is clear: no matter how close the personal relationship or how compelling the promise of outsized returns, rigorous verification remains the ultimate line of defense against financial ruin.