Environmental, Social, and Governance (ESG) investing has grown into a $35 trillion global market as of 2025, attracting investors who want their portfolios to align with their values. But as demand for sustainable investments surged, so did opportunities for fraud. ESG greenwashing—when investment firms make false or misleading claims about their sustainability practices—has emerged as one of the most significant threats to investors in the financial markets today, similar to other forms of investment fraud targeting retail and institutional investors.
At Varnavides Law, PC, we represent investors who have been deceived by false ESG claims. With 10 years of experience defending broker-dealers at one of the nation’s leading securities defense firms, attorney Gary Varnavides understands exactly how financial institutions structure their ESG marketing—and where the vulnerabilities lie. Now he uses that insider knowledge to hold wrongdoers accountable when they misrepresent their environmental and social impact to investors.
Key Takeaways
- ESG greenwashing involves false or misleading sustainability claims that deceive investors
- The SEC has brought major enforcement actions against Goldman Sachs, DWS, and WisdomTree for ESG violations
- Investors can recover damages through securities fraud claims, FINRA arbitration, or class action lawsuits
- California’s securities laws provide additional protections for investors harmed by greenwashing
- Time limits apply to ESG fraud claims—acting quickly preserves your legal rights
What Is ESG Greenwashing?
ESG greenwashing occurs when investment firms, companies, or financial advisors make false, exaggerated, or misleading statements about their environmental, social, or governance practices to attract investors. The term “greenwashing” originally referred to environmental claims, but it now encompasses all three ESG pillars.
Common forms of ESG greenwashing include:
- False ESG fund labeling: Marketing a fund as “ESG-focused” or “sustainable” when the fund’s holdings do not meet advertised criteria
- Overstated ESG integration: Claiming that ESG factors are considered in investment decisions when they are not
- Cherry-picked metrics: Highlighting positive ESG indicators while concealing negative ones
- Vague sustainability claims: Using undefined terms like “green,” “sustainable,” or “responsible” without specific criteria
- Failure to follow disclosed ESG policies: Promising to adhere to ESG standards but failing to implement them
- Misleading carbon neutrality claims: Representing investments as “carbon neutral” without adequate verification
The explosive growth of ESG investing—projected to reach $180 trillion by 2034—has created enormous financial incentives for firms to misrepresent their ESG credentials. When these misrepresentations harm investors, they constitute securities fraud.
Major ESG Greenwashing Enforcement Actions
Regulators have increasingly cracked down on ESG greenwashing. Understanding these enforcement actions helps illustrate the scope of the problem and the legal theories used to hold wrongdoers accountable.
Goldman Sachs Asset Management (2022)
The SEC charged Goldman Sachs Asset Management with failing to follow its own ESG investment policies and procedures.
Violation: Failed to research ESG characteristics of certain investments as promised to investors
Penalty: $4 million fine
Significance: First major enforcement showing the SEC will hold firms accountable for failing to implement disclosed ESG processes
DWS Group (Deutsche Bank) (2023-2025)
DWS faced both SEC and German regulatory actions for overstating ESG capabilities in its mutual funds and investment vehicles.
Violation: Misled investors about ESG integration in portfolio management
Penalty: $19 million SEC fine (2023) and €25 million German fine (2025)
Significance: Largest greenwashing enforcement to date, triggered by whistleblower complaint
WisdomTree Asset Management (2024)
The SEC charged WisdomTree with making misstatements about how its funds incorporated ESG factors.
Violation: Marketed funds as ESG-focused while investing in coal mining and tobacco companies
Penalty: Censure and monetary penalty
Significance: Demonstrated gap between ESG marketing and actual portfolio composition
BNY Mellon Investment Adviser (2022)
The SEC found that BNY Mellon made materially misleading statements about ESG considerations.
Violation: Claimed all investments had undergone ESG quality review when many had not
Penalty: $1.5 million fine
Significance: Early enforcement action setting precedent for scrutiny of ESG claims
Regulatory Momentum: As of early 2025, over 2,700 ESG-related lawsuits have been filed globally, more than double the number filed in 2020. The SEC Division of Enforcement has indicated that ESG enforcement remains a priority area, particularly as the market continues to grow.
How ESG Greenwashing Harms Investors and Legal Claims Available
ESG greenwashing causes real financial harm to investors in multiple ways:
Direct Financial Losses
- Price inflation: Investors pay premium prices for investments marketed as ESG-compliant, believing they are purchasing superior products with lower risk profiles
- Performance shortfalls: When ESG claims prove false, funds may underperform expectations, leading to losses
- Reputational damage: When greenwashing is exposed, fund values can plummet as investors exit positions
Opportunity Costs
- Missed alternative investments: Money invested in falsely marketed ESG funds could have been placed in legitimate sustainable investments
- Diverted capital: Investors dedicated to ESG principles lose the ability to direct capital toward genuinely responsible companies
Regulatory and Legal Risks
- Pension fund liability: Institutional investors who placed client funds in greenwashed investments may face their own liability
- Reputational harm: Investors associated with greenwashing scandals may suffer damage to their own reputations
Legal Claims for ESG Greenwashing Fraud
Investors harmed by ESG greenwashing have several legal avenues to pursue recovery:
| Legal Claim | Basis | Defendant | Venue |
|---|---|---|---|
| Securities Fraud (Federal) | Section 10(b) of Securities Exchange Act, Rule 10b-5 | Investment firm, advisors, executives | Federal court |
| Investment Adviser Fraud | Investment Advisers Act Section 206 | Registered investment advisers | Federal court or SEC |
| FINRA Arbitration | Customer agreement, FINRA rules | Broker-dealers, financial advisors | FINRA arbitration |
| California Securities Fraud | California Corporations Code Section 25401 | Any party involved in sale | State or federal court |
| Breach of Fiduciary Duty | State common law | Financial advisors, trustees | State court |
| Negligent Misrepresentation | State common law | Investment professionals | State court |
Elements of an ESG Securities Fraud Claim
To establish securities fraud based on ESG greenwashing, investors must prove:
- Material misrepresentation or omission: The defendant made a false statement or omitted a critical fact about ESG practices
- Scienter: The defendant acted with intent to deceive, manipulate, or defraud, or with severe recklessness
- Connection to purchase or sale: The misrepresentation occurred in connection with the purchase or sale of securities
- Reliance: The investor relied on the false statement in making the investment decision
- Economic loss: The investor suffered financial damages as a result
- Loss causation: The misrepresentation caused the financial loss
Statute of Limitations Warning: Federal securities fraud claims must generally be filed within five years of the violation or two years after discovery of the fraud, whichever comes first. California law provides for a four-year statute of limitations. Acting quickly is essential to preserve your rights.
Common ESG Greenwashing Schemes
ESG greenwashing takes many forms. Recognizing these patterns helps investors identify potential fraud:
The “Sustainable” Label Scheme
Investment firms slap “ESG,” “sustainable,” or “green” labels on conventional funds without meaningful changes to investment criteria.
Red flags:
- Fund renamed to include ESG terms
- No change in underlying holdings
- Vague ESG integration descriptions
The Cherry-Picking Scheme
Firms highlight positive ESG metrics while concealing negative ones, creating a misleading overall picture.
Red flags:
- Focus on only one ESG pillar
- Selective disclosure of metrics
- Lack of third-party verification
The Exclusion-Only Scheme
Funds claim ESG credentials based solely on excluding certain industries (tobacco, weapons) without affirmative ESG integration.
Red flags:
- ESG policy limited to exclusions
- No positive screening criteria
- Holdings with poor ESG records
The Proxy Voting Scheme
Firms claim ESG commitment through shareholder engagement but fail to vote proxies consistently with stated ESG principles.
Red flags:
- No proxy voting disclosure
- Votes against ESG proposals
- Lack of engagement documentation
The Third-Party Rating Scheme
Reliance on ESG ratings without independent verification or understanding of rating methodologies.
Red flags:
- Overreliance on single rating provider
- No internal ESG analysis
- Inconsistent ratings across providers
The Impact Washing Scheme
Funds claim to generate positive environmental or social impact without measurable outcomes or verification.
Red flags:
- Vague impact claims
- No impact measurement framework
- Lack of impact reporting
How to Identify ESG Greenwashing
Investors can protect themselves by conducting thorough due diligence on ESG investments:
Review Fund Documents Carefully
- Prospectus: Does it clearly define ESG criteria and integration methodology?
- Statement of Additional Information (SAI): What are the actual investment restrictions?
- Form ADV: For investment advisers, does Part 2A describe ESG strategies in detail?
- Marketing materials: Do claims match disclosures in regulatory filings?
Examine Portfolio Holdings
- Request complete holdings list
- Cross-reference holdings against ESG claims
- Look for controversial companies that contradict stated ESG principles
- Check if holdings match ESG fund benchmarks
Ask Specific Questions
- What specific ESG criteria are used in investment selection?
- How is ESG data sourced and verified?
- What percentage of holdings undergo ESG analysis?
- Are there third-party ESG certifications or audits?
- How does the fund vote proxies on ESG issues?
- What ESG-related exclusions are applied?
Warning Signs of Greenwashing
- Vague or undefined ESG terminology
- No quantifiable ESG metrics or targets
- Lack of transparency about ESG methodology
- ESG claims not reflected in regulatory filings
- Recent fund rebranding with ESG themes
- Holdings inconsistent with ESG positioning
- No independent ESG verification
Regulatory Enforcement and FINRA Arbitration
The Role of SEC Enforcement in ESG Cases
The SEC has made ESG enforcement a priority. Understanding the SEC’s approach helps investors recognize the strength of potential claims.
SEC’s ESG Enforcement Focus Areas
| Focus Area | SEC Concern | Recent Action |
|---|---|---|
| ESG fund disclosures | Accuracy of ESG claims in fund documents | Goldman Sachs, BNY Mellon, WisdomTree |
| Investment adviser representations | Implementation of disclosed ESG strategies | DWS, Goldman Sachs |
| Corporate ESG disclosures | Materiality and accuracy of ESG statements | Vale S.A. (environmental disaster) |
| Proxy voting | Voting inconsistent with ESG commitments | Ongoing examinations |
| ESG ratings and data | Conflicts of interest, methodology transparency | Ongoing examinations |
In February 2024, Gurbir Grewal, Director of the SEC Division of Enforcement, stated that “as investors become more interested in companies’ ESG considerations, companies have more incentives to exaggerate or make misleading statements about their positive ESG developments.” This signals continued regulatory focus on ESG fraud.
FINRA Arbitration for ESG Greenwashing Claims
Many investors must pursue ESG fraud claims through FINRA arbitration due to arbitration agreements in their account opening documents. Similar to other securities litigation cases, FINRA arbitration offers several advantages:
Advantages of FINRA Arbitration
- Speed: Cases typically resolve in 12-18 months vs. 3-5 years in court
- Expert arbitrators: Panel members understand securities industry practices
- Lower costs: Streamlined discovery and procedures reduce legal expenses
- Confidentiality: Proceedings are not public (though awards are published)
- Finality: Limited grounds for appeal provide closure
Disadvantages to Consider
- Limited discovery: Cannot conduct extensive document requests
- No jury: Panel of arbitrators decides case
- Difficult appeals: Very limited ability to challenge adverse decisions
- Industry arbitrators: Panel may include industry representatives
- Fee sharing: Investors may pay portion of arbitration costs
At Varnavides Law, we have extensive experience with FINRA arbitration gained from 10 years defending broker-dealers. We know how the process works, what evidence arbitrators find persuasive, and how to present ESG greenwashing claims effectively.
State Law Advantages and Building Your Case
California’s Advantages for ESG Fraud Victims
California law provides significant advantages for investors pursuing ESG greenwashing claims:
Strong Securities Fraud Statute
California Corporations Code Section 25401 prohibits fraudulent conduct in connection with the offer, sale, or purchase of securities. Key advantages include:
- Broad liability: Extends beyond the seller to “every person who materially aids” the fraud
- Joint and several liability: All participants in the fraud can be held fully liable
- Right to rescission: Investors can seek to unwind the transaction entirely
- Attorney’s fees: Prevailing plaintiffs may recover attorney’s fees and costs
Four-Year Statute of Limitations
California provides a four-year limitations period for securities fraud claims under Corporations Code Section 25506, providing more time to discover fraud and file claims compared to some federal claims.
Consumer Protection Laws
California’s Unfair Competition Law (UCL) and Consumer Legal Remedies Act (CLRA) provide additional theories of liability for deceptive ESG marketing practices.
Strong Public Policy
California courts have historically interpreted securities laws broadly to protect investors, recognizing that securities fraud undermines market integrity and investor confidence.
Building a Strong ESG Greenwashing Case
Successful ESG fraud cases require thorough preparation and compelling evidence. Here’s what strengthens a claim:
Documentary Evidence
- Marketing materials: Brochures, presentations, websites making ESG claims
- Account statements: Showing investments in the greenwashed fund
- Fund documents: Prospectuses, SAIs, annual reports, shareholder letters
- Form ADV: For investment advisers, showing disclosed ESG practices
- Communications: Emails, letters, or recorded calls discussing ESG features
- Regulatory filings: SEC disclosures that contradict marketing claims
Portfolio Analysis
- Holdings comparison: Comparing actual holdings to ESG representations
- ESG scoring: Third-party ESG ratings of portfolio companies
- Peer comparison: How the fund compares to legitimate ESG funds
- Exclusion analysis: Whether fund held companies it claimed to exclude
Expert Testimony
- ESG methodology expert: To explain industry standards and identify deviations
- Securities expert: To opine on materiality of misrepresentations
- Damages expert: To calculate financial harm
Witness Testimony
- Financial advisors: Who sold the investment and made representations
- Portfolio managers: Who made investment decisions
- Marketing personnel: Who created ESG-themed materials
- Compliance officers: Who reviewed ESG representations
Gary Varnavides: The Insider Advantage in ESG Cases
Attorney Gary Varnavides brings a unique perspective to ESG greenwashing cases. For 10 years, he defended broker-dealers and investment firms at Sichenzia Ross Ference LLP, one of the nation’s leading securities defense firms. This experience provides critical advantages:
Understanding the Playbook
Having defended financial institutions, Gary understands:
- How firms structure ESG marketing to maximize appeal while minimizing legal risk
- Common defense strategies in greenwashing cases
- Where documentation weaknesses typically exist
- How compliance departments review (or fail to review) ESG claims
Anticipating Defenses
Gary can predict and counter common defense arguments:
- “ESG is subjective”—showing specific false statements
- “Investor was sophisticated”—proving materiality regardless
- “No intent to deceive”—demonstrating recklessness or willful blindness
- “Losses from market conditions”—establishing loss causation
Named a Super Lawyers Rising Star from 2015-2023 (recognizing the top 2.5% of attorneys in the New York Metro area), Gary combines his defense-side experience with aggressive advocacy for investors. Licensed in California and New York, he represents clients nationwide in ESG fraud cases.
Damages, Recovery Options, and Future Outlook
Damages in ESG Greenwashing Cases
Investors who prevail in ESG fraud cases may recover various forms of damages:
Compensatory Damages
- Out-of-pocket losses: The difference between what you paid and the actual value at the time of purchase
- Benefit-of-the-bargain damages: The difference between what was promised and what was delivered
- Consequential damages: Additional losses flowing from the fraud
- Lost opportunity costs: Returns you could have earned in alternative investments
Rescission
In some cases, investors can seek rescission—unwinding the transaction entirely and recovering their full investment, minus any distributions received.
Interest
Prejudgment and post-judgment interest compensate for the time value of money from the date of loss through payment.
Attorney’s Fees and Costs
California securities law and certain federal statutes allow prevailing plaintiffs to recover attorney’s fees and litigation costs, making it economically feasible to pursue smaller claims.
Punitive Damages
In cases involving fraud, oppression, or malice, California law permits punitive damages to punish egregious conduct and deter future violations.
No Recovery, No Attorney Fees: We handle most ESG greenwashing cases on a contingency fee basis, meaning we only get paid if we recover money for you. Fee percentage is discussed during your free consultation. You remain responsible for case costs such as filing fees, expert witnesses, and deposition transcripts. We can discuss cost estimates and payment arrangements during your consultation.
Class Actions vs. Individual Claims
ESG greenwashing cases can proceed as class actions or individual claims. Each approach has advantages:
| Factor | Class Action | Individual Claim |
|---|---|---|
| Who it’s for | Many investors with similar claims | Individual investors or small groups |
| Control | Limited—class representatives and counsel control litigation | Full—you direct the strategy and decisions |
| Recovery | Typically smaller per-person but aggregated damages | Potentially larger individual recovery |
| Timeline | Longer—years to resolve | Shorter—especially in FINRA arbitration |
| Costs | Shared among class members | Individual responsibility |
| Arbitration | May be unavailable due to arbitration agreements | Can proceed in FINRA arbitration |
Many investors with arbitration agreements cannot participate in class actions and must pursue individual claims. We can evaluate which approach makes sense for your situation.
The Future of ESG Enforcement
ESG enforcement is evolving rapidly. Understanding coming trends helps investors protect themselves:
Regulatory Developments
- Enhanced disclosure rules: The SEC continues to develop rules requiring more detailed ESG disclosures
- Climate disclosure mandates: Requirements for climate-related financial disclosures are being implemented globally
- ESG fund classification: Regulators are working to create standardized ESG fund categories
- Third-party oversight: Increased scrutiny of ESG rating agencies and data providers
International Coordination
The UK’s Competition and Markets Authority announced large-scale public enforcement of its Green Claims Code beginning in autumn 2025. European regulators have brought major actions, including the €25 million DWS fine by German prosecutors. This international coordination strengthens the case for U.S. enforcement.
Private Litigation Expansion
With over 2,700 ESG-related lawsuits filed globally as of early 2025—more than double the number in 2020—private litigation is rapidly expanding. Plaintiffs’ attorneys are developing expertise in ESG cases, and courts are becoming more familiar with ESG fraud theories.
Whistleblower Reports
The DWS case was triggered by a whistleblower report from the company’s former sustainability chief. The SEC’s whistleblower program provides financial incentives for insiders to report ESG fraud, likely leading to more enforcement actions.
Steps to Take If You Suspect ESG Greenwashing
If you believe you’ve been deceived by false ESG claims, take these steps to protect your rights:
- Document everything: Gather all account statements, marketing materials, prospectuses, emails, and communications relating to the investment
- Preserve evidence: Save electronic files and make copies of all documents before they disappear
- Stop further investments: Do not invest additional money in the greenwashed fund
- Do not accept “switches”: Be wary if your advisor offers to move you to a different fund to “solve the problem”
- Do not sign releases: Never sign documents releasing claims without consulting an attorney
- Consult an attorney quickly: Time limits apply to securities fraud claims—delay can forfeit your rights
- Consider regulatory complaints: You can file complaints with the SEC or FINRA even while pursuing a civil claim
Do Not Delay: Statutes of limitations are strict in securities cases. Federal claims must generally be brought within five years of the violation or two years of discovery. California provides a four-year statute of limitations. Once the deadline passes, you lose your right to recover damages, regardless of the merit of your claim.
Working with Varnavides Law and FAQs
What to Expect When You Contact Us
When you reach out to Varnavides Law about an ESG greenwashing claim, here’s what happens:
Free Initial Consultation
We offer a free, confidential consultation to evaluate your case. During this meeting, we will:
- Review the investments at issue and the ESG representations made
- Examine your account statements and documents
- Assess the strength of potential claims
- Explain your legal options (FINRA arbitration, court litigation, class action)
- Discuss timelines and what to expect
- Explain our fee structure (contingency fee percentage discussed during consultation)
- Answer all your questions about the process
Case Investigation
If we take your case, we conduct a thorough investigation:
- Analyze the fund’s holdings and compare them to ESG representations
- Review all marketing materials and regulatory disclosures
- Research similar complaints or regulatory actions involving the same fund or firm
- Consult ESG methodology experts as needed
- Calculate your damages
- Identify all potentially liable parties
Demand and Negotiation
We typically begin with a demand letter to the responsible parties, seeking negotiated resolution. Many cases settle at this stage without the need for formal proceedings.
FINRA Arbitration or Litigation
If settlement is not achievable, we file either a FINRA arbitration claim or a court lawsuit, depending on your situation. We handle all aspects of the case, keeping you informed at every stage.
Frequently Asked Questions
How do I know if my ESG fund is engaging in greenwashing?
Red flags include vague ESG terminology, lack of specific ESG criteria in fund documents, holdings that contradict ESG claims (such as fossil fuel companies in a “green” fund), recent rebranding with ESG terms without changes to investment strategy, and absence of third-party ESG verification. Compare the fund’s actual holdings to its marketing representations. If there’s a significant disconnect, greenwashing may be present.
What damages can I recover in an ESG greenwashing case?
You may recover the difference between what you paid and the actual value of the investment (out-of-pocket losses), lost opportunity costs from alternative investments you could have made, interest from the date of your loss through judgment, and in some cases punitive damages if the conduct was particularly egregious. California law also allows recovery of attorney’s fees and costs for prevailing plaintiffs in securities fraud cases. In cases where rescission is available, you may be able to unwind the transaction entirely and recover your full investment minus any distributions received.
How long do I have to file an ESG fraud claim?
Federal securities fraud claims generally must be filed within five years of the violation or two years after discovery of the fraud, whichever comes first. California securities fraud claims have a four-year statute of limitations. FINRA arbitration claims have a six-year eligibility rule. Because these deadlines are strict and can be complicated, it’s essential to consult an attorney as soon as you suspect fraud. Waiting too long can permanently bar your claim.
Do I have to go to court, or can my case be handled through arbitration?
Most brokerage account agreements contain mandatory arbitration clauses requiring disputes to be resolved through FINRA arbitration rather than court litigation. FINRA arbitration is typically faster and less expensive than court proceedings, with cases resolving in 12-18 months compared to 3-5 years in court. However, if your situation doesn’t involve a broker-dealer account with an arbitration agreement, or if you’re pursuing a class action claim, court litigation may be the appropriate venue. We’ll review your account agreements to determine which forum applies to your case.
What is Gary Varnavides’s experience with ESG greenwashing cases?
Gary Varnavides spent 10 years at Sichenzia Ross Ference LLP, one of the nation’s leading securities defense firms, defending broker-dealers and investment firms against investor claims. This defense-side experience gives him unique insight into how financial institutions structure ESG marketing, what compliance procedures they follow (or fail to follow), and what defense strategies they employ. Named a Super Lawyers Rising Star from 2015-2023, recognizing the top 2.5% of attorneys in the New York Metro area, Gary now uses his insider knowledge to hold wrongdoers accountable when they deceive investors with false ESG claims.
How much does it cost to hire a lawyer for an ESG greenwashing case?
We handle most ESG greenwashing cases on a contingency fee basis, which means you pay no upfront attorney fees. We only get paid if we recover money for you. The fee percentage is discussed during your free consultation. You remain responsible for case costs, which may include filing fees, expert witness fees, and deposition transcripts. We can provide cost estimates and discuss payment arrangements during your consultation. This fee structure makes it economically feasible for investors to pursue valid claims without assuming the financial risk of hourly legal fees.
Can I join a class action lawsuit for ESG greenwashing?
Class actions are available for some ESG greenwashing cases, particularly where many investors were harmed by the same misconduct. However, if you have an arbitration agreement in your brokerage account (which most accounts include), you typically cannot participate in a class action and must pursue an individual FINRA arbitration claim. Class actions can take several years to resolve and often result in smaller per-person recoveries, but they allow investors to pool resources. Individual claims provide more control over the litigation strategy and potentially larger recoveries but require individual participation. We can evaluate which approach makes sense for your situation during your consultation.
What evidence do I need to prove ESG greenwashing?
Strong ESG greenwashing cases require documentary evidence showing the disconnect between ESG representations and reality. This includes marketing materials making ESG claims, fund prospectuses and disclosure documents, account statements showing your investment, communications with your financial advisor discussing ESG features, and the fund’s actual holdings list. We’ll also obtain third-party ESG ratings of the fund’s portfolio companies, compare the fund to legitimate ESG peers, and analyze whether holdings contradict stated ESG principles. Expert testimony from ESG methodology specialists is often critical to establishing that the fund’s practices fell below industry standards.
Contact an ESG Greenwashing Fraud Lawyer
ESG investing was supposed to align your portfolio with your values while generating competitive returns. When investment firms misrepresent their ESG credentials to capture your assets, they commit fraud. You don’t have to accept those losses.
At Varnavides Law, PC, we represent investors nationwide who have been harmed by ESG greenwashing. Attorney Gary Varnavides uses his 10 years of experience defending broker-dealers to build aggressive cases for investors. Licensed in California and New York, we handle cases throughout the United States.
Schedule Your Free Consultation
If you invested in a fund based on ESG representations that turned out to be false, contact us for a free, confidential case evaluation. We’ll review your situation, explain your options, and help you understand your rights.
Varnavides Law, PC represents investors in securities litigation and FINRA arbitration throughout California and nationwide. Our practice focuses on investment fraud, broker misconduct, and violations of securities laws.
