The Whelans were responsible for the sanctions and financial fines. However, it is the BIEL shareholder equity that will likely pay the six-figure fine. It was due December of 2019 and is sitting on the BIEL balance sheet as a payable.
I'll keep raising awareness that KW nad PW has ill-gotten notes that can dilute the value of holdings by nearly 67%. Who wants to invest money that can shrink overnight by 67%. KW and PW can do the right thing and deal with the notes in a way that is shareholder-friendly.