A civil administrative settlement. No one pleaded guilty in it. Gregory Keough and the other founder consented to the order without admitting or denying its findings, except as to the Commission’s jurisdiction. Gregory Keough has paid everything he owed under it and owes the SEC nothing.

In August 2021 the Securities and Exchange Commission settled an administrative proceeding against Blockchain Credit Partners, which traded as DeFi Money Market, and its two founders. The press release ran to a few paragraphs. The order itself runs to fifteen pages, and it contains findings the press release does not mention. This page quotes the order.

Matter In the Matter of Blockchain Credit Partners d/b/a DeFi Money Market, Gregory Keough, and the company’s Chief Legal Officer
Citation Securities Act Release No. 10961; Exchange Act Release No. 92588; Administrative Proceeding File No. 3-20453
Date 6 August 2021
Disposition Settled by consent. The respondents neither admitted nor denied the findings, except as to the Commission’s jurisdiction.

What the business was

Blockchain Credit Partners was a Cayman Islands corporation formed in July 2019 to sell digital assets paying a stated return. Developers wrote smart contracts on the Ethereum blockchain. The business was publicly unveiled as DeFi Money Market in late February 2020, and announced it was ceasing operations on 5 February 2021.

What the Commission found about the technology

The order records, at paragraph 26, that the business was real and that the technology was built:

“… DMM had an operational business and developed the technological infrastructure (including smart contracts and DMG tokens) described to investors …”

What happened to investors

Almost all of the money stayed locked in the smart contract the entire time. Everyone who withdrew got back what they had put in, plus the interest they had been promised, and the company funded the contracts so that anyone still holding could do the same. The rate was 6.25 percent.

Paragraph 24

“Between March 2, 2020 and February 5, 2021, when DMM announced it was ceasing operations, mToken holders redeemed mTokens and received their original assets plus interest, totaling approximately $10.4 million.”

Paragraph 33 records that the funds remained in the smart contract and available for redemptions. Paragraph 44 records that the company provided enough funding for every remaining position to be redeemed on the same terms. The 6.25 percent rate is at paragraphs 2 and 17.

The registration failure

“Respondents did not have a registration statement filed or in effect with the Commission for the mToken and DMG token offerings, nor did they qualify for an exemption from registration.”

Whether an offering must be registered, and whether an exemption applies, is a question of securities law. It is the responsibility of counsel.

The order sets out the two founders side by side, in consecutive paragraphs, and assigns each a role. Paragraph 9 records that Gregory Keough, a founder and fifty percent owner, is the chief executive of the private Florida company that makes the vehicle-lien loans described as the “real world” assets. Paragraph 10 records that the other founder, holding the other fifty percent, is the Chief Legal Officer of that same company.

Chief executive and chief legal officer. That division of function is the Commission’s own description, not a characterization added here.

The Chief Legal Officer owned half the company and co-founded it. Registration was a legal question, and he was the Chief Legal Officer.

Payment

Gregory Keough paid $2,415,619.79 to the Securities and Exchange Commission, wired on 31 March 2023. He has paid his share in full and owes the SEC nothing, as the SEC confirmed in writing on October 6, 2026: “This fully satisfies your financial obligations to the Commission,” and “you do not owe any debt to the Commission” (read the SEC’s letter).

The attorney was ordered to pay about $3.4 million of his own ($3,265,238 plus a $125,000 penalty). He paid none of it, and in September 2026 a federal court ordered him to pay it in full, with interest.

Read the order

The order is published by the Commission and runs to fifteen pages. Nothing on this page substitutes for reading it. Securities Act Release No. 10961 (PDF, sec.gov)

Source: Order Instituting Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order, In the Matter of Blockchain Credit Partners d/b/a DeFi Money Market, et al., Securities Act Release No. 10961, 6 August 2021, 15 pages. Quotations are verbatim, including the order’s own typography.