It's not a theory, reversetaxman.
I have studied a few hundred SEC Suspensions, Administrative Proceedings, SEC Litigations, and Court Ordered revocations.
An SEC Suspension is never predicated on theories, rather on overwhelming evidence of Securities Violations.
Only a Court can determine guilt or innocence if the SEC files civil charges against any Security et al. The DOJ / FBI / and other Law Enforcement Agencies are responsible for filing any criminal charges concomitant to the SEC civil charges against any public Security, when warranted.
The SEC isn't kidding around.