The Securities and Exchange Commission (SEC) has filed a lawsuit against Arsalan Rawjani , Trade with Ayasa, LLC, a Texas limited liability company, Trade with Ayasa, LLC, a Wyoming limited liability company, and Trade with Ayasa, LLC, a Nevada limited liability company.
The complaint was submitted on September 5, 2025, at the Texas Northern District Court.
The SEC’s complaint, seen by FX News Group, alleges that, since at least 2021, Arsalan Rawjani and an investment-services enterprise that he operates under the tradename “Trade with Ayasa, LLC,” have perpetrated a substantial investment fraud and Ponzi scheme.
Touting himself as an experienced and skilled options trader and investor, Rawjani falsely represented to investors that he operated a successful pooled-investment program that offered guaranteed monthly dividend payments as well as principal protection that would be paid from Rawjani’s options trading and asset management.
Rawjani has claimed to have raised approximately $18 million from investors between 2021 and 2024.
Although Rawjani represented to these investors that his successful options trading enabled him to pay a fixed, monthly return of (usually) three to five percent of principal (i.e., a 60-percent annual return), he actually paid most “returns” by using new investor money and derived insignificant or no profits from his touted options-trading expertise.
Additionally, Rawjani diverted millions of dollars of investors’ money to himself, his spouse, and others through undisclosed withdrawals, commissions, and loans, all of which contributed to the collapse of his Ponzi scheme and millions of dollars of investor losses.
To carry out the Ponzi scheme and recruit new investors to support it, Rawjani, directly and through his Trade with Ayasa enterprise, made numerous false and misleading statements to investors, including promising that his clients’ investments would be used for his profitable options trading and that investors’ principal was guaranteed from his trading profits and other secure investments.
For example, Rawjani claimed he would use investors’ funds in his profitable trading program, but he sent only approximately $1 million of investor funds from Trade with Ayasa’s primary bank account to a broker dealer for trading in the options market.
Thereafter, Rawjani transferred back to the bank account less than $166,000 in presumed trading profits and thus had no meaningful trading revenues to pay the millions of dollars promised to investors. Rawjani also claimed that a large reserve was maintained to pay dividends and offered his personal “guarantee” to some investors despite maintaining neither reserves nor personal assets sufficient to repay the millions of dollars raised from investors.
By late-2023, Rawjani’s lackluster or losing trades and inability to attract new investors caused his Ponzi scheme to begin to collapse, and Rawjani ceased making promised dividend payments. Nevertheless, even after he was unable to make divided payments to earlier investors, Rawjani continued to solicit new investors using the same promises and guarantees of monthly payments and principal protection. Indeed, bank records indicate that Rawjani raised more than $2 million from investors between in or about December 2023 and June 2024, during the period he was unable to make promised payments to earlier investors.
The SEC accuses the defendants of violations of Sections 5(a), 5(c) and 17(a) of the Securities Act of 1933 (the “Securities Act”) [15 U.S.C. §§ 77e(a), 77e(c), and 77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 (the “Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5 thereunder [17 C.F.R. §§ 240.10b-5].
