waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and executing BD's/MM's in the Opco complaint? ALSO well known to the SEC: MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this ongoing conspiracy has not yet occurred. Chris From: Chris Dilorio Sent: Wednesday, April 29, 2020 7:56 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used my information to bring AND obstruct complaints. The 2 SEC Commissioners dissent in granting Oppenheimer waivers after this egregious activity https://www.sec.gov/news/statement/dissenting-statement-oppenheimer-inc.html SEC.gov I Dissenting Statement In the Matter of Oppenheimer & Co., Inc. Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and Commissioner Kara M. Stein, February 4, 2015 www.sec.gov In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar complaint. WHO was the SEC protecting with its complaint then waivers? The smoking gun which I have provided to the SEC on several e mails: Which came in an SEC reviewed CGFIA 10O https://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi 10q.htm cgfi_10q.htm - SEC Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. www.sec.gov EFTA00083433

pg 27 "Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)" "On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the "Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC, Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action." Of Course, I have hard copies if you prefer. ex clearing: The illegal SEC/DTCC Obligation Warehouse. This is CLEAR,IREEFUTABLE,INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the executing BD's/MM's? WHO were the customers? The veracity of my information is also irrefutable and incontrovertible. Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME). The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al. IN FURTHERANCE OF THE CONSPIRACY Cheers! Christopher.' Dilorio Whistleblower From: Chris Dilorio Sent: Tuesday, April 28, 2020 7:24 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT (and AQR) money laundering shells. The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information https://www.sec.gov/litigation/complaints/2019/comp24403.pdf Marc P Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place 200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN EFTA00083434

DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL, 3 5. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead attempted to disguise as an asset sale transaction. vo.vvy sec g ov https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773_sc I 3g.htm www.sec.gov (i) Sole power to vote or to direct the vote . The information required by Item 4(c)(i) is set forth in Row 5 of the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting Person. MG Partners Ltd: Abitebol But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol As with Opco/GIBRALTAR, who is the SEC protecting? AND, per my extensive correspondence with the SEC re my TCR's: The SEC is ALSO grossly under estimating the criminal activity in NITE/Magna/NewLead SEC: Criminals bailing out/actively facilitating criminals/criminal activity. soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct complaints/deny whistleblower rightful compensation. Cheers! Christopher Dilorio Whistleblower From: Chris Dilorio Sent: Tuesday, April 28, 2020 6:43 AM Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix More evidence of SEC fraud on the court in Gibraltar. It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action. The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity? EFTA00083435

The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed a fraud on the court in Gibraltar. Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011. https://www.prcom/press-release/355246 Gibraltar Global Securities Now Offering Offshore Brokerage Accounts - PR.com Nassau, Bahamas, The, September 22, 2011 Gibraltar Global Securities is now offering offshore brokerage accounts in addition to their broad array of financial services.Gibraltar Global ... www.pr.com https://www.pr.com/press-release/355247 GGSI Bahamas is Now Offering Pink Sheet Clearance Offshore Broker Adds to Buying and Selling Services www.prcom htips://www.pr.corn/press-release/369649 GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions and Communication GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures designed to protect their client’s personal data, and to secure electronic communication. www.pr.com The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT. Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS. 2 criminal entities bailed out by the SEC. Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015- 016: "The investigators never saw the claimants information". WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on the OWB itself. More criminal activity. Criminals bailing out criminals while denying Whistleblowers due process and compensation. Cheers! Christopher Dilorio Whistleblower EFTA00083436