The Securities and Exchange Commission (SEC) filed a lawsuit against Shiloh Luckey, formerly known as Shiloh Johnson, CEO of tech startup ComplYant App, Inc.
The SEC complaint, seen by FX News Group, was filed in the Central District Court of California on October 20, 2025.
The complaint alleges that from or about October 2020 to September 2023, Luckey fraudulently raised more than $13 million from venture capital investors using false claims about both the commercial success of ComplYant’s software product and her own qualifications to lead the company.
ComplYant was an online technology company that offered an online software service to small business owners to track and manage their tax obligations. To lure investors into the fraudulent scheme, Luckey consistently and grossly overstated both ComplYant’s revenue and the number of subscribers to the company’s service.
Luckey also misrepresented herself to investors as a licensed Certified Public Accountant (“CPA”), with deep experience in tax management, oversight and accounting compliance, falsely increasing investors’ perception of her relevant expertise. However, Luckey was not a licensed CPA, nor are there any records to suggest that she ever had one.
Additionally, in addition to her salary from ComplYant, Luckey, for her own benefit, earned at least $2.2 million from the investor funds raised. Luckey used ComplYant funds for personal expenses including: trips to locations such as Aspen, Miami Beach, Turks and Caicos and Lisbon. Super Bowl Tickets. Luckey’s Caribbean destination wedding. and the purchase of a personal car and Luckey’s residence.
Luckey’s fraudulent scheme finally collapsed in mid-September 2023 when ComplYant ran out of cash and abruptly ceased operations, despite raising $750,000 from two new investors in June and September 2023.
SEC charges Luckey with violations of Section 17(a) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5].
The Commission seeks permanent injunctions barring future violations of the federal securities laws, an officer and director, and an order requiring defendant Luckey to disgorge her ill-gotten gains with prejudice thereto pursuant to Section 21(d)(5) of 21(d)(7) of the Exchange Act. [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)] and imposition of civil penalties under Section 21(d)(3) of the Exchange Act [15 U.S.C. §78u(d)(3)] and Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)].