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

WASHINGTON, D.C. — In a sweeping enforcement action highlighting the persistent threat of affinity fraud, the U.S. Securities and Exchange Commission (SEC) announced civil charges today against three residents of Toms River, New Jersey. The trio is accused of orchestrating a sophisticated, multi-year investment scam that raised approximately $47 million from more than 87 investors.

The scheme predominantly targeted members of close-knit Orthodox Jewish communities across New Jersey, New York, and several other states. Promising lucrative, guaranteed fixed returns tied to short-term small business financing, the operation instead functioned as a classic Ponzi scheme, leaving devastating financial and personal fallout in its wake.

According to a complaint filed in the U.S. District Court for the District of New Jersey, the mastermind behind the operation was Leor Moshe. Operating through his company, Capital Funding ASAP LLC, Moshe allegedly preyed upon shared cultural and religious affiliations to build a false sense of trust, ultimately misappropriating millions of dollars for personal enrichment and sustaining the fraud through Ponzi-style payments.

Compounding the civil enforcement, the U.S. Attorney’s Office for the District of New Jersey announced parallel criminal charges against Moshe, signaling the severity of the alleged misconduct. The Federal Bureau of Investigation (FBI) also assisted in the multi-agency crackdown.

Chronology of the Fraud: From Inception to Collapse

The unfolding narrative of Capital Funding ASAP LLC illustrates how modern affinity frauds can take root, expand rapidly, and eventually collapse under the weight of their own deceit.

November 2019: Planting the Seeds of Deception

The scheme allegedly commenced in November 2019, when Leor Moshe established Capital Funding ASAP LLC. Leveraging his standing within the Orthodox Jewish community in New Jersey, Moshe began pitching an investment opportunity centered on short-term bridge loans for small businesses. He assured prospective investors that their capital would be deployed rapidly, generating secure, short-term yields with minimal risk.

By utilizing the social fabric of his own community, Moshe bypassed the typical skepticism investors might feel toward high-yield opportunities offered by unfamiliar parties. Instead, shared religious observance, community networks, and word-of-mouth recommendations acted as a force multiplier for his credibility.

2020–2022: Expanding the Network and Bringing in "Recruiters"

As the influx of capital grew, Moshe enlisted the help of two fellow Toms River residents: Jacob Goldman and Isaac Odes. Neither Goldman nor Odes was registered as a broker-dealer with the SEC, nor were they associated with any registered broker-dealer firm—a critical requirement under federal securities laws designed to protect investors from unlicensed actors.

Despite this lack of registration, Goldman and Odes served as key fundraisers for the enterprise. The SEC complaint alleges that the pair aggressively solicited more than $23 million from at least 25 investors. They actively negotiated investment terms, collected funds, and funneled capital directly into Moshe’s network. In exchange for their recruitment efforts, Goldman and Odes were allegedly paid substantial fees out of the incoming investor funds.

During this peak period, the perpetrators dangled extraordinary incentives in front of prospective clients. According to Thomas P. Smith, Jr., Associate Director of the SEC’s New York Regional Office, some investors were explicitly promised annual returns exceeding 30 percent—a staggering yield that defied traditional financial market realities.

June 2023: The Unraveling

The scheme finally ground to a halt in June 2023, as the mounting pressure of servicing high promised returns, combined with substantial personal withdrawals by Moshe, rendered the enterprise unsustainable. By this point, the operation had collected approximately $47 million. However, the promised small-business loan portfolio was largely a facade.

When distributions slowed or ceased entirely, investors began demanding answers and attempting to claw back their principal investments, setting off alarm bells that ultimately drew the attention of federal investigators and securities regulators.

Supporting Data and Financial Breakdown

The sheer scale of the Capital Funding ASAP LLC fraud is laid bare in the financial figures detailed in the SEC’s federal complaint. The operations reflect classic indicators of financial malfeasance disguised as legitimate alternative lending.

• Total Capital Raised: Approximately $47 million was extracted from more than 87 individual investors.
• Geographic Reach: Victims hailed from at least seven states, including Arizona, Connecticut, Florida, Illinois, New Jersey, New York, and Ohio.
• Total Net Investor Losses: Collective losses stemming from the collapsed scheme exceeded $25 million.
• Personal Misappropriation: Rather than funding small-business loans as promised, Moshe allegedly diverted more than $11 million in investor funds directly for personal use, funding a lifestyle well beyond what his legitimate means would allow.
• Ponzi-Style Distributions: More than $850,000 was cycled back to earlier investors to create the illusion of a functioning, profitable enterprise and to stave off suspicion.
• Unlicensed Broker Solicitation: Jacob Goldman and Odes collectively brought in more than $23 million from at least 25 distinct investors without holding the proper regulatory credentials.

The diversity of the victim pool—spanning multiple states while remaining anchored by cultural ties to the Northeast—underscores how effectively the fraudsters used personal networks to project a veneer of legitimacy.

Official Responses and Regulatory Enforcement

Federal authorities pulled no punches in condemning the conduct of the defendants, emphasizing the particularly predatory nature of targeting insular cultural and religious groups.

"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," said Thomas P. Smith, Jr., Associate Director of the SEC’s New York Regional Office. "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."

Legal Charges and Penalties Sought

The SEC’s civil complaint formally targets all three individuals with distinct violations of federal law:

• Leor Moshe is charged with violating the antifraud provisions of the federal securities laws. The SEC is seeking permanent injunctive relief, the disgorgement of all ill-gotten gains plus prejudgment interest, substantial civil monetary penalties, and a conduct-based injunction designed to bar him from engaging in similar activities in the future.
• Jacob Goldman and Isaac Odes are charged with violating the broker-dealer registration provisions outlined in Section 15(a) of the Securities Exchange Act of 1934. The SEC is pursuing permanent injunctions, disgorgement with interest, and civil penalties against them as well.

In tandem with the SEC’s civil enforcement action, the U.S. Attorney’s Office for the District of New Jersey formally announced criminal charges against Moshe. The simultaneous civil and criminal filings illustrate a coordinated federal effort to hold the perpetrators accountable through both financial restitution and potential criminal incarceration.

Implications and Broader Lessons for Investors

The case of Capital Funding ASAP LLC serves as a stark warning regarding the dangers of affinity fraud—a specialized type of investment scam that preys upon members of identifiable groups, such as religious organizations, ethnic populations, professional associations, or senior citizen communities.

The Anatomy of Affinity Fraud

Fraudsters who engage in affinity fraud often target tight-knit communities precisely because trust is already established. By embedding themselves within the social or religious fabric of a group, con artists can bypass the rigorous due diligence that individuals might normally exercise when dealing with independent financial advisors. Victims frequently lower their guard because "someone like us" or a respected community leader is vouching for the investment.

Regulators note that fraudsters frequently exploit shared values, using religious or cultural terminology to disarm skepticism and discourage independent verification. When victims believe they are supporting peers or investing in mutual community growth, they are less likely to question aggressive claims of guaranteed double-digit returns.

Protecting Your Wealth: SEC Recommendations

In the wake of this enforcement action, the SEC is strongly encouraging all investors to utilize federal resources to protect themselves from predatory schemes.

1. Check Backgrounds: Investors should always visit Investor.gov to verify the professional background, registration status, and disciplinary history of anyone offering or selling an investment product. Unregistered individuals selling securities represent a major red flag.
2. Beware of Guaranteed High Returns: Financial markets carry inherent risk. Any investment pitching "guaranteed" or "risk-free" returns significantly above prevailing market rates—such as the 30% promises alleged in this case—should be treated with extreme caution.
3. Recognize Targeted Scams: The SEC’s Office of Investor Education and Assistance maintains a dedicated webpage on Investment Scams Targeting Groups, offering tailored guidance on how affinity frauds operate and how community members can protect their assets.

As the legal proceedings against Leor Moshe, Jacob Goldman, and Isaac Odes move forward in federal court, the case stands as a sobering reminder that trust should never replace verification, and that even the most close-knit communities are not immune to financial predators.