In late 2009, MOORE partnered with Renwick Haddow, who is also a British citizen, to sell investments in a hotel scheme in which investors lost money.  Haddow had been disqualified as a director of any U.K. company for eight years, and later sued by the Financial Conduct Authority, a British regulator, for operating investment schemes through misrepresentations that lost investors substantially all of their money.  These sanctions and lawsuit were publicized extensively online.

Beginning in 2015, MOORE chose to partner with Haddow again, this time to solicit investments into Bar Works through material misrepresentations concerning, among other things, the identity of Bar Works' management and the financial condition of that company. 

In order to conceal his role at Bar Works because of the negative publicity on the internet related to past investment schemes and government sanctions in the United Kingdom, Haddow adopted the alias "Jonathan Black."  Notwithstanding Haddow's control over Bar Works, Moore and others knowingly distributed the Bar Works offering materials listing Black as the chief executive officer of Bar Works and claiming that Black had an extensive background in finance and past success with start-up companies.  As MOORE well knew, "Jonathan Black," was an entirely fictitious person, created to mask Haddow's control of Bar Works. 

Among other things, MOORE helped devise and distribute pitch materials that contained the misrepresentations.  MOORE and an affiliated Spanish-based company, United Property Group, coordinated a substantial sales force to recruit investors knowing that the materials contained the falsehood.  MOORE advised Haddow as to how to continue to conceal the truth concerning the identity of "Jonathan Black," and affirmatively represented to potential sales partners that he was communicating with CEO "Jonathan Black."  MOORE also advised Haddow how to evade foreign law enforcement authorities.  MOORE personally received approximately $1.6 million from Bar Works before helping to launch a competing co-working space investment project. 

MOORE repeatedly lied to the United States Securities Exchange Commission (SEC) and federal law enforcement agents to cover up his role in the Bar Works scheme. On August 11, 2016 - while the Bar Works scheme was still operating - MOORE participated in a recorded phone interview with the SEC and reiterated that Jonathan Black was a real person who he understood to be the CEO of Bar Works, notwithstanding knowing that Black was fake. MOORE claimed that he never asked to speak to Jonathan Black, even though in the prior months, MOORE had been misrepresented to multiple agents that he was working closely with Black.

On February 15, 2017, MOORE was interviewed by Internal Revenue Service (IRS) agents following his arrest for a separate investment scheme in connection with a development project he was promoting in Florida. In a videotaped interview, MOORE lied and told agents he had not done anything for money since 2010, even though he had gotten approximately $1.6 million from Bar Works alone.

Moore's conviction is his second federal felony conviction related to property investments.  He was previously convicted in 2018 of misprision of a felony for his role in a property investment fraud in Florida, for which he was sentenced to 18 months in prison.

In addition to the prison term, MOORE, 60, was sentenced to 3 years of supervised release.  MOORE was also ordered to pay restitution of $57,579,790.00, forfeiture of $1,599,257.46, and a fine of $50,000.

Renwick Haddow, 53, pled guilty on May 23, 2019, to one count each of wire fraud and wire fraud conspiracy relating to the Bar Works scheme, and one count each of wire fraud and wire fraud conspiracy relating to a separate investment scheme involving Bitcoins.  Haddow's sentencing is scheduled for April 8, 2022.

Savraj Gata-Aura, 35, pled guilty on November 18, 2019, to one count of wire fraud conspiracy for his participation in the scheme, and was sentenced to 48 months in prison on July 27, 2020, by Judge Jed. S. Rakoff.

[F]rom December 2017 through at least July 2021, Safeguard and Santulan acted as investment advisers and persuaded investors to sell their existing securities, transfer the proceeds into self-directed Individual Retirement Accounts, and invest the proceeds into gold and silver coins by making false and misleading statements about the safety and liquidity of the investors' securities investments, Safeguard's business, and its compensation.

As alleged, Safeguard fraudulently marketed itself as a full-service investment firm with offices in London, New York City, and Beverly Hills that employed prominent individuals in the securities industry and had $11 billion in assets under management. In reality, Santulan allegedly operated the company from a small leased space in a Woodland Hills, Calif. office building using sales agents. The complaint further alleges that Safeguard's sales agents used prepared scripts, some written by Santulan, that were filled with false and misleading statements about how the market was going to crash and how their retirement accounts would be frozen under a new 'unpublicized' law.

. . .

Safeguard and Santulan also allegedly misled investors about Safeguard's commissions and markups on the coins, charging average markups of approximately 64% on its sales of silver coins, instead of the 4% to 33% markups that they disclosed to investors. According to the complaint, Safeguard obtained approximately $67 million from the sale of coins to more than 450 mostly elderly, retail investors, and kept approximately $25.5 million in mark ups.