The SEC Acts Independently
Here is the basic reality. No matter who alerted the SEC to issues with BGMO the way their process works is to conduct an investigation without anyone's knowledge; go look on their website. This is always the case. Hence, an inference about insiders trading is meaningless as insiders wouldn't know the SEC is looking.
Next, the SEC will look to see if an issuer is filing audited financial statements. BGMO manifestly failed to do this. Again, look at what they said when they suspended the stock, look at the laws that empower them, etc. This is why documents from the likes of HSBC are totally irrelevant other than for assisting in performing an audit.
As to a PR that says HH has left the country to get required documents. This is also irrelevant, and to be honest a little silly. First off, who knows where he is and when he's there. Remember what the SEC wants, which are audited financials. If this is what BGMO is doing then the press release should clearly state this and identify the audit firm. Any restoration from the grey market will require audited financials as a first step.
It is very unlikely an audit firm will touch this knowing the history with the SEC due to perceived liability. If one does take it on it will take them many months of work to prepare audited financials; assuming BGMO's books are in order.
Most likely the SEC will either do nothing or file administrative charges. Either can take time and they will not tell you what they are doing.
There is a chance they will file civil or criminal fraud charges if they find evidence that HH/SP/others improperly traded the stock. Again, only time will tell.
The net/net of all this is the stock is worthless and may never trade again.
