Yes, and they all got investigated-shut down post closing of these deals from what I can gather here. If he continues to deal with them after all this, I’d say yes, we have a problem.
You will also note the SEC suspension order for AXMP included doubt about financials for the end of March 31st. Those financials were signed off on by Arcaro with mention of Bauman as lawyer and were prior to any mention of Palewater or Milost. The Palewater Milost PRs didn't come out until July.
Arcaro and Bauman are in the SEC sights now. Registered or not.