Loans, not grants. Every dollar repaid.

Gregory Keough owes nothing on his case, which involved SBA loans, not grants, and every dollar was repaid. In November 2023 he pleaded guilty to wire fraud and money laundering in connection with those loans. The $1,922,355 in restitution was paid in full before he was sentenced, as the court’s judgment records, and he served his sentence. Eight months before any charge, he had already paid $500,000 to the Small Business Administration. The government took no forfeiture, and the SEC has confirmed in writing that his file is closed and fully paid.

  • Restitution: $1,922,355, recorded in the judgment as paid in full before sentencing (Judgment, DE 60).
  • Paid before any charge: $500,000 to the SBA on 19 December 2022, as personal guarantor of the loan. The complaint came eight months later.
  • Forfeiture: none. The United States filed notice on 15 May 2024 that it was not pursuing forfeiture against him (DE 65).
  • SEC: paid in full. The SEC has confirmed in writing that his file is closed and marked as fully paid. He owes the SEC nothing. The attorney did not pay his own separate share, about $3.4 million, and a federal court ordered him to pay it.
  • Sentence: 30 months, the bottom of the guideline range. No prior record.
  • Pretrial: “has met all conditions of pretrial release,” in the court’s own words (Order, DE 47).
  • Today: the court granted his motion to live with his family in El Salvador (Order, DE 76).

SEC: paid in full, nothing owed

The SEC’s 2021 order was a settled administrative order, which Gregory Keough consented to without admitting or denying its findings. The order itself records that the company “Paid Investors All Principal and Interest Owed.” Every dollar he owed under the Order has been paid. The SEC has confirmed in writing that his file is closed and marked as fully paid. More than $10 million has been paid under the Order.

Gregory Keough paid his share in full and owes the SEC nothing. In the SEC’s own words, in its letter of October 6, 2026: “This fully satisfies your financial obligations to the Commission,” and “you do not owe any debt to the Commission” (read the letter). The attorney was separately ordered to pay about $3.4 million of his own ($3,265,238 plus a $125,000 penalty). He did not pay it, and the SEC took him to federal court, which ordered him to pay the full amount with interest (the court’s judgment against the attorney, published by the U.S. Government Publishing Office).

The order’s registration finding turned on a legal question: whether the offering had to be registered with the SEC or qualified for an exemption. The order records that the other founder, who owned the other 50%, was the Chief Legal Officer of the founders’ Florida finance company (SEC order, paragraphs 9 and 10).

Questions and answers

Did Gregory Keough keep any of the money?

No. These were SBA loans, not grants, and every dollar was paid back. The government’s own sentencing announcement says $309,555 of the loan proceeds went to him. Eight months before any charge, on 19 December 2022, he paid $500,000 to the Small Business Administration, more than the government says he received. The court then recorded the full $1,922,355 in restitution as paid in full before he was sentenced. Nothing was forfeited and nothing is owed.

Was Gregory Keough’s restitution paid?

Yes, in full, before sentencing. Before sentencing, his counsel told the court in writing: “KEOUGH has already paid his responsibility for restitution without the need for any further litigation regarding same” (Amended Sentencing Memorandum, DE 56, p. 9). The judgment entered at sentencing then recorded the $1,922,355 as paid in full (Judgment, DE 60, on CourtListener). The Department of Justice’s sentencing announcement states that “restitution was paid in full.”

Does Gregory Keough owe anything to the United States?

No. The judgment records the restitution as paid in full, no forfeiture was taken from him, and the special assessment was paid.

Does Gregory Keough owe anything to the SEC?

No. He paid in full. The SEC has confirmed in writing that his file is closed and marked as fully paid (SEC letter, October 6, 2026). The attorney was separately ordered to pay about $3.4 million of his own ($3,265,238 plus a $125,000 penalty). He did not pay it, and the SEC took him to federal court, which ordered him to pay the full amount with interest.

How much did Gregory Keough repay before charges were filed?

$500,000. As personal guarantor of the company’s loan, he paid the full $500,000 principal to the Small Business Administration on 19 December 2022, eight months before the complaint was filed. The SBA records that loan as paid in full (SBA payment confirmation, 19 December 2022).

Was anything forfeited from Gregory Keough?

No. The United States filed notice on 15 May 2024 that it was not pursuing forfeiture against him (Notice on Forfeiture, DE 65, on CourtListener).

What sentence did Gregory Keough receive?

30 months, the bottom of the guideline range. He had no prior record. The government’s own sentencing filing commended his CIA service: it “commends [Gregory Keough] for his then commitment to the United States and for his acts which earned him the Intelligence Star.”

Did Gregory Keough serve in the CIA?

Yes. He served as a covert operations officer in the CIA’s Directorate of Operations and received the Intelligence Star. Three former CIA officers who served with him confirmed his service in letters filed in his federal court case, read what they wrote. Forbes reported his CIA service in May 1999 (Zina Moukheiber, “Three Men and a Web Idea,” 17 May 1999).

Former Deputy Director, National Clandestine Service

26 years at the CIA · Three-time Chief of Station · Distinguished Career Intelligence Medal, Intelligence Medal of Merit, Donovan Award

“I came to know Mr. Keough very early in my career at CIA, when we were classmates during the… Career Trainee training program we both successfully completed to start our careers. During such an intensive course, one comes to know one’s classmates very well… I can gladly confirm that Mr. Keough was an Operations Officer with the Directorate of Operations, the clandestine arm of the CIA, and served his country with distinction. I can further confirm that while on assignment abroad Mr. Keough received the CIA’s Intelligence Star – one of the Agency’s highest awards for service and rarely awarded – for his actions when he went to the rescue of a fellow officer… Mr. Keough’s actions on that day were in the finest tradition of CIA officers’ bravery and selflessness. I recall the message sent out to all CIA Stations citing and lauding Mr. Keough’s efforts on that day. While he saved an officer’s life that day, another officer involved in the rescue perished… (Mr. Keough’s name is omitted from the citation, due to the fact that Mr. Keough was under cover at that time.)”

A former three-time Chief of Station and Deputy Director of the National Clandestine Service · Letter filed with the U.S. District Court, Southern District of Florida

Former CIA officer and office mate

13 years at the CIA · Final post: counter-proliferation of weapons of mass destruction, Middle East and South Asia

“I served abroad with Greg Keough in the Directorate of Operations, the clandestine arm of the Central Intelligence Agency… We have known Greg and his family for over 30 years… I was Greg’s office mate and I can confirm his former employment and honorable service with CIA. Greg is one of the few living recipients of the Intelligence Star due to his actions in rescuing a fellow officer… The other CIA officer who died in the rescue… is memorialized by one of the stars on the CIA’s wall, of which there are roughly one hundred. One detail which I think is significant regarding this rescue is the fact that Greg, after having safely extracted the other officer at risk, went back into harm’s way when no one else would, to recover the body… to prevent his corpse from being lost… I continue to consider Greg a loyal and trustworthy friend, who can always be counted on to do the right thing.”

A former CIA officer of thirteen years who shared an office with him · Letter filed with the U.S. District Court, Southern District of Florida

Retired CIA Chief of Station, classmate and roommate

25+ years at the CIA · Multiple tours as Chief of Station · Fellow graduate of the CIA’s selective Career Trainee program

“…I write to you as someone who has known Greg Keough and considered him a friend for over 30 years. We first met as classmates in a U.S. government agency training program, one which is highly selective and screens candidates for many characteristics including honesty, trustworthiness and overall character. Such characteristics are considered essential to suitability for employment by this U.S. government agency, given the sensitive duties and responsibilities that it entrusts to its officers… While Greg could have sought a comfortable assignment in a stable country, this would not have been in keeping with his motivation for serving our country. Instead, he sought out the most challenging hazardous duty assignment available to him, combatting the threat of an armed communist insurgency, one in which a number of U.S. military and U.S. government civilians had been killed. While serving honorably on this assignment, Greg further demonstrated selfless courage when he saved a fellow officer… In recognition of his heroic action, Greg was awarded one of the agency’s highest decorations for bravery.”

A retired Chief of Station with more than 25 years at the CIA, a classmate from the CIA’s selective training programme, who shared an apartment with him in Washington before they deployed · Letter filed with the U.S. District Court, Southern District of Florida

Where does Gregory Keough live now?

In El Salvador, with his wife and children. After he served his sentence, the court granted his motion to return to them (Order, DE 76).

What did the attorney admit in his separate case?

Gregory Keough’s business partner, an attorney who was Chief Operating Officer and General Counsel of the company that took the loans, was charged over the same company loans in a separate case (No. 22-cr-80157). Gregory Keough was not a defendant in that case. In his signed Stipulated Factual Basis the attorney admits that he submitted a PPP application as General Counsel, that bank statements he provided in support of a PPP loan application were falsified, and that he retained approximately $869,682.83 for his personal use. He pleaded guilty to conspiracy to commit wire fraud and was sentenced to 41 months (Stipulated Factual Basis; plea agreement; judgment).

The two cases, side by side

Gregory Keough The attorney
Bond set by the court $3,000,000 (DE 28, DE 29) $500,000 (DE 8)
Release conditions before trial Home detention with GPS monitoring. The court recorded that he “has met all conditions of pretrial release” (DE 47) No home detention, no GPS monitoring, no curfew (DE 8)
Loan money for personal use $309,555, per the government’s announcement, and he paid $500,000 to the SBA before any charge $869,682.83, per his own signed admission (DE 12)
Forfeiture None pursued (DE 65) $869,682.83 ordered (DE 27)
SEC Paid in full, confirmed by the SEC in writing About $3.4 million ordered and not paid; a federal court ordered him to pay it

Leer en español: El expediente

Primary documents

The court record behind this page.

The attorney’s separate case, No. 22-cr-80157. These documents are from the separate case against the attorney who co-founded DeFi Money Market and owned 50% of Blockchain Credit Partners, and who at the time was Chief Legal Officer of the Florida finance company, Chief Operating Officer of National Financial Holdings, Inc. and of National Financial Holdings Technology LLC, Managing Member of NFH Florida LLC, and General Counsel. In them, “the defendant” means that attorney. Gregory Keough was not a defendant in that case; his own case is No. 23-cr-80154.

Sources: Judgment DE 60 · Notice on Forfeiture DE 65 · Order DE 47 · Order DE 76 · Government’s sentencing response DE 57 · SEC letter confirming payment in full · SBA payment confirmation, 19 December 2022