Follow the share issuances. Once you follow the shares issuances, you follow the trading activities. It really will not be that hard to track most of the money. The SEC doesn't necessarily have to find every penny, but if they can find an approximation of how much money made, that is where the order of disgorgement will come in.
Also Patchman, look at the records yourself. It says that SPNG had about 1.2 billion shares outstanding at the time they claimed to have 722 million. At this stated time the share price was below $.04, and hadn't been much above that price. However, every other share increase was after the share price was above $.04 which means that it is likely that 1.8ish billion shares were sold at prices higher than $.04... which is a lot more money than the couple million they spent on half of their advertising bills...