The man who submitted and signed the loan applications, who kept $869,682.83 of the proceeds, and who has paid the Securities and Exchange Commission nothing to date, was the company’s chief operating officer and chief legal officer, a Florida attorney admitted to the Bar in 2002. The attorney was charged with one count. Gregory Keough, who the bankruptcy trustee testified had never prepared, reviewed, signed, submitted or seen the documents, and whose restitution the judgment records as paid in full before sentencing, was charged with eleven.
| Gregory Keough | The attorney | |
|---|---|---|
| Submitted and signed the loan applications | No. The bankruptcy trustee, an adverse witness, testified she had no evidence Keough prepared, reviewed, signed, submitted or had ever seen them. | Yes. Admitted under oath in his own signed factual basis, October 2022, including one application submitted in his capacity as General Counsel. |
| How each was charged | Indicted on eleven counts, August 2023. | Charged by negotiated Information on a single count, 27 September 2022, eleven months earlier. |
| Loan proceeds kept | The United States sought no forfeiture. | $869,682.83, taken as a forfeiture money judgment. |
| Paid to the Securities and Exchange Commission | $2,415,619.79, wired 31 March 2023. | Nothing to date. |
| Still owed to the Securities and Exchange Commission | Nothing. | $4,337,991, outstanding as of 20 August 2026. |
| Assets concealed from the bankruptcy estate | The related bankruptcy claims against Keough were dismissed with prejudice. | A seven-carat diamond bought with company money and left off the schedules. The court granted the trustee’s motion for contempt. The attorney was never charged with it. |
| Recorded as paid to the United States | $2,415,619.79 wired to the Securities and Exchange Commission on 31 March 2023, and $1,922,355 restitution recorded in the judgment as paid in full, both before sentencing. | Nothing to date. $4,337,991 remains outstanding to the Securities and Exchange Commission. |
A man with no criminal history, who had paid more than four million dollars to the United States and repaid every dollar before he was sentenced, asked to go home to his wife and five children. The government fought it.
Sources: Judgment DE 60 · DE 65 · DE 57 · DE 73 · DE 76 · Menotte deposition, 18 Jan 2023 · United States v. Acree, 9:22-cr-80157-AHS, DE 12, Stipulated Factual Basis, 11 October 2022 · SEC v. Keough, et al., 9:26-mc-80318, DE 1 · GAO-18-203
The full account of the case, with the court record behind each figure above: What actually happened in the Gregory Keough case?