UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 102142 / January 10, 2025
ADMINISTRATIVE PROCEEDING
File No. 3-22390
In the Matter of
Jonathan Mimun (a/k/a
Jonathan “Yoni” Maymon,
Yonatan Mimun and Jonatan
Mimun) and Ronn Ben Harav
(a/k/a Ronen Baharav),
Respondents.
ORDER INSTITUTING
ADMINISTRATIVE PROCEEDINGS
PURSUANT TO SECTION 15(b) OF
THE SECURITIES EXCHANGE ACT
OF 1934 AND NOTICE OF HEARING
I.
The Securities and Exchange Commission (“Commission”) deems it appropriate and in the
public interest that public administrative proceedings be, and hereby are, instituted pursuant to
Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) against Jonathan Mimun
(a/k/a Jonathan “Yoni” Maymon, Yonatan Mimun, and Jonatan Mimun) and Ronn Ben Harav
(a/k/a Ronen Baharav) (collectively, “Respondents”).
II.
After an investigation, the Division of Enforcement alleges that:
A. SUMMARY
1. From at least December 2014 through June 2017 (“Relevant Period”), Respondents
perpetrated a multi-million-dollar scheme to defraud retail investors in the United States through
the unregistered offer and sale of security-based binary options.
2. Respondents offered and sold these binary options through their ownership,
operation, and control of two internet-based brokers doing business under the names (a) Porter
Finance and (b) Dalton Finance (the “Porter Brokers”). The Porter Brokers were unincorporated 2
brand names that functioned through a combination of websites, call centers, and straw companies
that, among other things, held bank and credit-card-processing accounts used to facilitate their
operations.
3. Under the scheme, sales agents, acting at Respondents’ direction and while working
for call centers owned and controlled by Respondents, solicited investors by falsely representing
themselves as experienced market professionals providing expert binary options trading advice.
The sales agents further represented that their interests were aligned with the investors’ interests
because they made their money from an investor’s trades only when the investor made money. In
reality, the entities controlled by Respondents secretly made their money from investors’ losses—
they were the counterparty to investors’ trades—and, as described below, the scheme was rigged to
maximize the likelihood that investors lost their money trading binary options.
4. As a result of this conduct, Respondents violated Section 17(a) of the Securities Act
of 1933 (“Securities Act”) and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder,
aided and abetted the brokers’ and call centers’ violations of the same provisions of the Securities
Act and the Exchange Act, and obtained at least $25 million from investors located in the United
States through these securities law violations.
5. Based on Respondents’ securities laws violations, a United States district court
enjoined Respondents from engaging in certain conduct and practices in connection with the
purchase or sale of any security.
B. RESPONDENTS
6. Respondent Ronn Ben Harav is 44 years old, resides in Israel, and ran and
supervised operations at the Porter Brokers during the Relevant Period. On or about February 12,
2024, he changed his name with the Ministry of the Interior of Israel to Ronen Baharav.
7. Respondent Jonathan Mimun is 37 years old, resides in Israel and ran and
supervised operations at the Porter Brokers during the Relevant Period. He also has used various
other names, including “Yoni” Maymon, Yonatan Mimun, and Jonatan Mimun.
C. BACKGROUND
8. During the Relevant Period, Respondents controlled and operated the Porter
Brokers that collectively acted as brokers under the trade names Porter Finance and Dalton Finance
in the offer and sale of security-based binary options (hereinafter, the “Securities”). None of the
companies that comprised the Porter Brokers were registered with the Commission as a broker, and
none of the Securities were registered with the Commission.
9. As directed by Respondents, the Porter Brokers induced investors located in the
United States to open and fund binary options trading accounts and to frequently purchase for
those accounts Securities, which, among others, included binary options based on the price of the
common stocks of many companies traded on United States exchanges, such as Apple, Exxon, 3
Yahoo, IBM, McDonalds, Coca-Cola, and Citigroup, and binary options based on various indices
of securities, such as the NASDAQ Composite and the Dow Jones Industrial Average.
10. The primary company behind the Porter Brokers was JMRB Media, Ltd.
(“JMRB”), an Israeli-based company that ran boiler-room-like call centers to solicit investors to
purchase Securities. Throughout most of the Relevant Period, Respondent Ben Harav owned 50
percent of JMRB through a company called BenHarav Capital, Ltd., while Respondent Mimun,
owned the other 50 percent of JMRB through a company called JM Ventures, Ltd.
11. JMRB designed email advertising campaigns and websites through which investors
accessed an internet-based trading platform. JMRB controlled other companies including Oracle
Stone, Ltd.; Sky Runway, Ltd.; Sky Runway Investments, Ltd.; and Riverrun Partners, Ltd. These
companies (which, again, along with Porter Finance, Dalton Finance, and JMRB, we collectively
refer to as the “Porter Brokers”) owned the bank accounts into which investor funds were
deposited and contracted with advertisers, credit card processors, a trading-platform provider, and
other vendors required to operate and sell binary options online.
12. Respondent Ben Harav managed and controlled the Porter Brokers through his
control of its finances, including the bank and credit card processing accounts. Ben Harav also
managed and controlled the Porter Brokers through his selection of marketing vendors and
approval of marketing campaigns. The marketing campaigns that the Porter Brokers used, with
Ben Harav’s knowledge and approval, promised investors access to secret or proprietary systems
for trading binary options that had supposedly generated huge returns for other investors, but the
systems advertised did not exist and most investors lost the amounts they deposited with the Porter
Brokers.
13. Respondent Jonathan Mimun managed and controlled the Porter Brokers through
his day-to-day supervision of the JMRB call centers, including his hiring, training, and supervising
of call center employees. Mimun trained call center employees to make fraudulent representations
to investors and, among other things, to falsely tell investors that the employees were experienced
market professionals providing expert trading advice and that their purpose was to assist an
investor in creating a custom trading program that was profitable and would meet the investor’s
specific needs. In reality, the employees of the call centers generally had no specialized
knowledge, financial training, or background. Their purpose was not to help investors profit from
trading, but to induce investors to deposit money and lose it all trading.
14. Respondents each directed the Porter Brokers’ activities in various other ways.
Among other things, Respondents jointly established the win/loss payout ratios for the trading
platform, which made it likely that investors trading over time would lose all of their deposits.
15. The Porter Brokers acted as brokers within the meaning of Section 3(a)(4)(A) of the
Exchange Act [15 U.S.C. § 78c(a)(4)(A)] during the Relevant Period because they were engaged in
the business of effecting transactions in securities for the account of others. Among other things:
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(a) the Porter Brokers actively sought out investors through marketing campaigns
that directed investors to websites from which investors accessed the provided trading
platform.
(b) Through advertisements, websites, and call center employees, the Porter
Brokers held themselves out as Porter Finance and Dalton Finance, which were referred
to as “brokers.” Call center employees, for example, often referred to themselves as
“brokers” or “traders” in communications with investors. Also, the trading platform
embedded in the websites created the appearance of actual, market-oriented trading that
looked similar to what an investor would see on a registered broker’s website. It
allowed investors to place “trades,” see “live” market quotes, make deposits, and track
trades and balances. The trading platform referred to binary options positions as
“assets” or “investments” and, in the case of security-based options, sometimes
displayed the logos of the referenced companies.
(c) The Porter Brokers advised investors on the purported merits of trading the
Securities. The Porter Brokers sent investors “welcome” emails promising that the
Porter Brokers would provide investors “with all the tools necessary for successful
trading,” included an investor “education” section on the Porter Brokers’ websites that
included a “trading guide,” and trained call center employees to tell investors that they
were experienced market professionals providing expert binary options trading advice.
(d) Investor funds were deposited into accounts ultimately (and secretly) controlled
by the Porter Brokers, and the Porter Brokers’ call center employees were paid a
commission based on the amount of deposits they induced investors to make.
16. Respondents were persons associated with a broker, specifically, the Porter
Brokers, within the meaning of Section 3(a)(18) of the Exchange Act [15 U.S.C. § 78c(a)(18)]
during the Relevant Period. Respondents also controlled the Porter Brokers within the meaning of
Section 20(a) of the Exchange Act [15 U.S.C. § 78t(a)].
17. While associated with the Porter Brokers during the Relevant Period, Respondents
engaged in misconduct by:
(a) knowingly or recklessly employing devices, schemes, and artifices to defraud
and engaging in acts, practices, and courses of business which operated as a fraud or
deceit on persons through the instrumentalities of interstate commerce in connection
with the purchase and sale of securities in violation of Section 10(b) of the Exchange
Act and Rule 10b-5(a) and (c) thereunder;
(b) knowingly, recklessly, or negligently employing devices, schemes, and artifices
to defraud and engaging in transactions, practices, and courses of business which
operated as a fraud or deceit on securities purchasers through the instrumentalities of
interstate commerce in connection with the offer and sale of securities in violation of
Sections 17(a)(1) and (3) of the Securities Act; 5
(c) offering and selling unregistered securities in violation of Section 5 of the
Securities Act; and
(d) aiding and abetting violations of Section 17(a) of the Securities Act and Section
10(b) of the Exchange Act and Rule 10b-5 thereunder.
D. THE JUDGMENT AND ENTRY OF AN INJUNCTION
18. On April 26, 2024, an amended final judgment (the “Judgment”) was entered
against Respondents filed at Docket No. 22 in the civil action entitled Securities and Exchange
Commission v. Jonathan Mimun et al., Case Number 2:21-cv-01314-ART-MDC, in the United
States District Court for the District of Nevada.
19. The Judgment found Respondents jointly and severally liable for disgorgement of
$25,777,909.10 and prejudgment interest of $7,324,621.53 and found each Respondent
individually liable for a civil penalty in the amount of $12,888,954.00. The Judgment furthermore
permanently enjoined Respondents from violating Sections 5 and 17(a) of the Securities Act and
Sections 10(b) of the Exchange Act and Rule 10b-5 thereunder and from violating Section 15(a)(1)
of the Exchange Act through the control of any broker or dealer.
20. The Judgment also included an injunction of the type described in Section
15(b)(4)(C) of the Exchange Act [15 U.S.C. § 78o]; more particularly, the Judgment enjoined
Respondents from:
(a) directly or indirectly, inducing or attempting to induce the purchase or sale of binary
options, security-based swaps, or other securities over the Internet, via email or other
forms of electronic communication; (b) directly or indirectly causing any person or entity
to engage in any activity that is for the purpose of inducing or attempting to induce the
purchase or sale of binary options, security-based swaps, or other securities over the
Internet, via email or other forms of electronic communication; (c) deriving
compensation from any activity inducing or attempting to induce the purchase or sale of
binary options, security-based swaps, or other securities over the Internet, via email or
other forms of electronic communication; but (d) not from buying or selling securities for
their own personal accounts.
III.
In view of the allegations made by the Division of Enforcement, the Commission deems it
necessary and appropriate in the public interest that public administrative proceedings be instituted
to determine:
A. Whether the allegations set forth in Section II hereof are true and, in connection
therewith, to afford Respondent an opportunity to establish any defenses to such allegations; and
6
B. What, if any, remedial action is appropriate in the public interest against Respondent
pursuant to Section 15(b) of the Exchange Act.
IV.
IT IS ORDERED that a public hearing before the Commission for the purpose of taking
evidence on the questions set forth in Section III hereof shall be convened at a time and place to be
fixed by further order of the Commission, pursuant to Rule 110 of the Commission’s Rules of
Practice, 17 C.F.R. § 201.110.
IT IS FURTHER ORDERED that Respondent shall file an Answer to the allegations
contained in this Order within twenty (20) days after service of this Order, as provided by Rule
220(b) of the Commission’s Rules of Practice, 17 C.F.R. § 201.220(b).
IT IS FURTHER ORDERED that the Division of Enforcement and Respondent shall
conduct a prehearing conference pursuant to Rule 221 of the Commission’s Rules of Practice, 17
C.F.R. § 201.221, within fourteen (14) days of service of the Answer. The parties may meet in
person or participate by telephone or other remote means; following the conference, they shall file
a statement with the Office of the Secretary advising the Commission of any agreements reached at
said conference. If a prehearing conference was not held, a statement shall be filed with the Office
of the Secretary advising the Commission of that fact and of the efforts made to meet and confer.
If Respondent fails to file the directed Answer, or fails to appear at a hearing or conference
after being duly notified, the Respondent may be deemed in default and the proceedings may be
determined against him upon consideration of this Order, the allegations of which may be deemed
to be true as provided by Rules 155(a), 220(f), 221(f) and 310 of the Commission’s Rules of
Practice, 17 C.F.R. §§ 201.155(a), 201.220(f), 201.221(f), and 201.310.
This Order shall be served upon Respondents as provided for in Rule 141(a)(2)(iv) of the
Commission’s Rules of Practice, 17 C.F.R. § 201.141(a)(2)(iv).
The Commission finds that it would serve the interests of justice and not result in prejudice
to any party to provide, pursuant to Rule 100(c) of the Commission’s Rules of Practice, 17 C.F.R.
§ 201.100(c), that notwithstanding any contrary reference in the Rules of Practice to service of
paper copies, service to the Division of Enforcement of all opinions, orders, and decisions
described in Rule 141, 17 C.F.R. § 201.141, and all papers described in Rule 150(a), 17 C.F.R. §
201.150(a), in these proceedings shall be by email to the attorneys who enter an appearance on
behalf of the Division, and not by paper service.
Attention is called to Rule 151(a), (b) and (c) of the Commission’s Rules of Practice, 17
C.F.R. § 201.151(a), (b) and (c), providing that when, as here, a proceeding is set before the
Commission, all papers (including those listed in the following paragraph) shall be filed
electronically in administrative proceedings using the Commission’s Electronic Filings in
Administrative Proceedings (eFAP) system access through the Commission’s website,
www.sec.gov, at http://www.sec.gov/eFAP. Respondent also must serve and accept service of 7
documents electronically. All motions, objections, or applications will be decided by the
Commission.
The Commission finds that it would serve the interests of justice and not result in prejudice
to any party to provide, pursuant to Rule 100(c) of the Commission’s Rules of Practice, 17 C.F.R.
§ 201.100(c), that notwithstanding any contrary reference in the Rules of Practice to filing with or
disposition by a hearing officer, all filings, including those under Rules 210, 221, 222, 230, 231,
232, 233, and 250 of the Commission’s Rules of Practice, 17 C.F.R. §§ 201.210, 221, 222, 230,
231, 232, 233, and 250, shall be directed to and, as appropriate, decided by the Commission. This
proceeding shall be deemed to be one under the 75-day timeframe specified in Rule of Practice
360(a)(2)(i), 17 C.F.R. § 201.360(a)(2)(i), for the purposes of applying Rules of Practice 233 and
250, 17 C.F.R. §§ 201.233 and 250.
The Commission finds that it would serve the interests of justice and not result in prejudice
to any party to provide, pursuant to Rule 100(c) of the Commission’s Rules of Practice, 17 C.F.R.
§ 201.100(c), that the Commission shall issue a decision on the basis of the record in this
proceeding, which shall consist of the items listed at Rule 350(a) of the Commission’s Rules of
Practice, 17 C.F.R. § 201.350(a), and any other document or item filed with the Office of the
Secretary and accepted into the record by the Commission. The provisions of Rule 351 of the
Commission’s Rules of Practice, 17 C.F.R. § 201.351, relating to preparation and certification of a
record index by the Office of the Secretary or the hearing officer are not applicable to this
proceeding.
The Commission will issue a final order resolving the proceeding after one of the
following: (A) The completion of post-hearing briefing in a proceeding where the public hearing
has been completed; (B) The completion of briefing on a motion for a ruling on the pleadings or a
motion for summary disposition pursuant to Rule 250 of the Commission’s Rules of Practice, 17
C.F.R. § 201.250, where the Commission has determined that no public hearing is necessary; or
(C) The determination that a party is deemed to be in default under Rule 155 of the Commission’s
Rules of Practice, 17 C.F.R. § 201.155, and no public hearing is necessary.
In the absence of an appropriate waiver, no officer or employee of the Commission engaged
in the performance of investigative or prosecuting functions in this or any factually related
proceeding will be permitted to participate or advise in the decision of this matter, except as witness
or counsel in proceedings held pursuant to notice. Since this proceeding is not “rule making” within
the meaning of Section 551 of the Administrative Procedure Act, it is not deemed subject to the
provisions of Section 553 delaying the effective date of any final Commission action.
For the Commission, by its Secretary, pursuant to delegated authority.
Vanessa A. Countryman
Secretary
