Litigation Releases (Robert D. Welsh and Caedrynn E. Conner)

U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 26668 / October 7, 2026

Securities and Exchange Commission v. Kenneth W. Alexander II, et al., No. 4:25-cv-00446-JCB (E.D. Tex. filed Apr. 29, 2025)

SEC Obtains Final Consent Judgments as to Two DFW Residents Charged in Alleged Ponzi Scheme

On September 28, 2026, the United States District Court for the Eastern District of Texas entered final judgments by consent as to Robert D. Welsh and Caedrynn E. Conner, whom the SEC previously charged with operating a Ponzi scheme.

According to the SEC's complaint, between May 2021 and February 2024, Kenneth W. Alexander II and Welsh orchestrated a Ponzi scheme, with Conner's substantial assistance and participation, that raised at least $91 million from more than 200 investors. The complaint alleged that Alexander and Welsh operated the scheme, which they called the Vanguard JV Cash Program, through Vanguard Holdings Group Irrevocable Trust (VHG). The complaint further alleged that Alexander and Welsh falsely promoted VHG as a highly-profitable international bond trading business, but, in reality, VHG used investor funds to make Ponzi payments to investors. According to the complaint, in July 2022, Conner created the Benchmark JV Cash Program, an investment program he used to pool funds to invest in the Vanguard JV Cash Program. The complaint alleged that, by the end of 2022, Conner knew, or was severely reckless in not knowing, multiple facts indicating the fraudulent nature of the Vanguard JV Cash Program and, by extension, the Benchmark JV Cash Program.

Without admitting the allegations in the complaint, Welsh and Conner consented to the entry of final judgments that permanently enjoin them from violating Sections 5 and 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder. The final judgments also permanently enjoin them from participating in the issuance, purchase, offer, or sale of any security except for purchases or sales of securities for their own personal accounts. In addition, the final judgment as to Welsh orders him to pay disgorgement in the amount of $1,062,069, prejudgment interest in the amount of $168,077, and a civil penalty in the amount of $450,000. And the final judgment as to Conner orders him to pay disgorgement in the amount of $8,575,250, prejudgment interest in the amount of $1,357,072, and a civil penalty in the amount of $500,000.

The SEC's litigation is led by Jason Rose and supervised by Keefe Bernstein of the SEC's Fort Worth Regional Office.