From the sec complaint > Defendants at all relevant times were investment advisers within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80

From the sec complaint > Defendants at all relevant times were investment advisers within the meaning of Section 202(a)(11) of the Advisers Act [15 U.S.C. § 80b-2(a)(11)]. My personal guess: that law makes various actions (self-dealing, lying about what investment funds are being used for, non-arms-length transactions, etc) crimes instead of civil torts. Plus, you know, just plain fraud.