The Securities and Exchange Commission (SEC) has filed a lawsuit against Shiloh Luckey, formerly known as Shiloh Johnson, CEO of technology startup ComplYant App, Inc.
The SEC’s complaint, seen by FX News Group, was submitted at the California Central District Court on October 20, 2025.
The complaint alleges that since in or about October 2020 through September 2023, Luckey fraudulently raised over $13 million from venture capital investors using false claims about both the commercial success of ComplYant’s software product as well as her own qualifications to lead the company.
ComplYant was an online technology company that offered an online software service for small business owners to track and manage their tax obligations. To lure investors into the fraudulent scheme, Luckey consistently and vastly 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, supervision, and accounting compliance, falsely heightening investors’ perception of her relevant expertise. However, Luckey was not a licensed CPA, nor do any records suggest she ever was licensed.
In addition, on top of her salary from ComplYant, Luckey, for her own benefit, profited by at least $2.2 million of the investor funds raised. Luckey used ComplYant’s funds for personal expenses including: travel to locations such as Aspen, Miami Beach, Turks and Caicos, and Lisbon; Super Bowl tickets; Luckey’s destination wedding in the Caribbean; and the purchase of a personal car and Luckey’s residence.
Luckey’s fraudulent scheme eventually 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 of 2023.
The SEC accuses Luckey of 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 prohibiting future violations of the federal securities laws, an officer and director bar, and an order requiring defendant Luckey to disgorge her ill-gotten gains with prejudgment interest thereon in accordance with Section 21(d)(5) of 21(d)(7) of the Exchange Act [15 U.S.C. §§ 78u(d)(5) and 78u(d)(7)] and imposing 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)].
