Sand went to Prison in the vicinity those transactions
It was unclear who was the CI in some of these transactions. Sand bribed an FBI agent (MS) to buy Ingen Stock and paid kickbacks to him. Sand was during that time taking his salary in stock and selling it in those wrap agreements. The wraps and JSJ weren't Ribotstky's deal. The wraps were all Sand and Sand was crying like a baby to roll on Ribotsky.
In the end the SEC forgave Sand's fine so he rolled on somebody. NIR was still owed $2 million, after more than $2 million paid. Recently PWC settled with a "third party" who assumed Ingen's debt (for free????) for a few hundred grand.
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