From the SEC complaint:
"Pursuant to a secret agreement, 21st Century sold stock to Compass Capital and its affiliates at a discount to market prices, and Compass Capital and its affiliates quickly resold that stock to public investors without disclosing these transactions."
"During the same period, Defendants Romney, Dumble, and Traveller were also responsible for the publication of materially false and misleading statements in 21st Century’s periodic filings, and Dahl, Dumble, and Traveller aided and abetted 21st Century’s reporting, record-keeping and internal controls violations of the Securities Exchange Act of 1934."
"Unless enjoined, these Defendants are likely to commit similar violations in the future. Accordingly, the Commission seeks an order enjoining Defendants; requiring
disgorgement of ill-gotten gains and unjust enrichment by defendants Compass Capital, Lefkowitz, Hopf and Traveller; civil monetary penalties from all Defendants; officer and director bars against Dumble, Romney, and Traveller; and penny stock bars against Lefkowitz, Dumble, Romney, Traveller, Dahl, and Hopf."