It's not just Big Apple. CLDR/GESM has diclosed that it issued the unregistered shares as free trading when they should have been resticted.
Big Apple is already being sued for selling unregistered shares of CKYS as well as helping to perpetuate the fraud.
The CKYS CEO was prosecuted for criminal fraud ans is in prison for over 8 years. So far BAC's principals are not under any criminal indictment, so the criminal aspect was blamed on the CEO.
It's shocking BAC was so bold as to continue selling unregistered shares of CLDR/GESM, SSPT, GRBG when they were under investigation and then while being sued. They tried using bogus 504 exemptions with all 3 of those companies. It's odd that the other two companies haven't had any action against them... at least so far.
Because Lovatt lives in England, I don't know if there's much chance he'd ever go to prison even if he committed fraud.
I believe that Brian Barrett and Tammy Posten, the former officers of GESM are likely being investigated as well. They brought in BAC and filed the Form D 504 share offering.
Barrett is more culpable in the BAC issue than Lovatt IMO, However, I think they're both scammy CEOs who use stock as an ATM.