SECURITIES AND EXCHANGE COMMISSION'S MOTION FOR ENTRY OF JUDGMENT AGAINST DEFENDANT DANIEL H. GLICK, DEFENDANT FINANCIAL MANAGEMENT STRATEGIES INC., AND RELIEF DEFENDANT GLICK ACCOUNTING SERVICES INC.

VIRGINIA M. KENDALL, District Judge.

The SEC respectfully moves for the entry of judgment against defendant Daniel Glick and his two companies, defendant Financial Management Strategies Inc. ("FMS") and relief defendant Glick Accounting Services Inc. In support of this motion, the SEC states as follows:

1. As previewed for the Court during the hearing on April 4, 2018, the SEC has reached a bifurcated settlement with Glick and his two companies. The settlement basically resolves everything as to those parties, except the monetary relief.

2. Glick, FMS, and Glick Accounting Services have consented to the entry of judgment against them. Exhibits 1-3 are executed copies of the consents. Exhibit 1 is the Consent of Defendant Daniel Glick. Exhibit 2 is the Consent of Defendant Financial Management Strategies Inc. Exhibit 3 is the Consent of Relief Defendant Glick Accounting Services Inc.

3. Exhibits 4-6 are the proposed judgments. Exhibit 4 is the Judgment as to Defendant Daniel Glick. Exhibit 5 is the Judgment as to Defendant Financial Management Strategies Inc. Exhibit 6 is the Judgment as to Relief Defendant Glick Accounting Services. Glick, FMS, and Glick Accounting Services have agreed to the proposed judgments. See Consent of Defendant Daniel Glick, at ¶ 3 (Ex. 1); Consent of Defendant Financial Management Strategies Inc., at ¶ 2 (Ex. 2); Consent of Relief Defendant Glick Accounting Services Inc., at ¶ 2 (Ex. 3).

4. Among other things, Glick and FMS have agreed to the entry of permanent injunctions restraining them from violating the federal securities laws. See, e.g., Consent of Defendant Daniel Glick, at ¶ 3 (Ex. 1); Judgment as to Defendant Daniel Glick, at §§ I-III (Ex. 4). There is no permanent injunction against Glick Accounting Services because it is a relief defendant, and thus was not charged with violating the federal securities laws.

5. Glick, FMS, and Glick Accounting Services also have agreed to repatriate foreign assets to the United States. See, e.g., Consent of Defendant Daniel Glick, at ¶ 16 (Ex. 1); Judgment as to Defendant Daniel Glick, at § V (Ex. 4). In particular, they have agreed to cooperate with the orderly liquidation, transfer, and repatriation of any foreign assets, including the Israeli investments identified in this action. All proposed sales would be subject to the approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.).

6. Glick, FMS, and Glick Accounting Services have agreed to the disgorgement of ill-gotten gains, as well as prejudgment interest. See, e.g., Consent of Defendant Daniel Glick, at ¶ 5 (Ex. 1); Judgment as to Defendant Daniel Glick, at § IV (Ex. 4). This Court will determine the amount of disgorgement and prejudgment interest at a later date, after the SEC files a motion. Id. In addition, Glick and FMS have agreed that the Court will decide the amount of any civil penalty (again, at a future time). Id.

7. The sentencing of Daniel Glick is currently scheduled for April 17, 2018. See United States v. Glick, 17-cr-739 (N.D. Ill.) (Gettleman, J.). The sentence may include a restitution order. After sentencing, the SEC will return to this Court and address the issue of monetary relief, the last remaining issue for Glick and his two companies.

8. Glick, FMS, and Glick Accounting Services agreed that the "Commission may present the Judgment to the Court for signature and entry without further notice." See Consent of Defendant Daniel Glick, at ¶ 17 (Ex. 1); Consent of Defendant Financial Management Strategies, at ¶ 15 (Ex. 2); Consent of Relief Defendant Glick Accounting Services, at ¶ 14 (Ex. 3).

WHEREFORE, the SEC respectfully moves for the entry of judgment against defendant Daniel Glick, defendant Financial Management Strategies Inc., and relief defendant Glick Accounting Services Inc.

EXHIBIT 1

CONSENT OF DEFENDANT DANIEL GLICK

1. Defendant Daniel H. Glick ("Defendant" or "Glick") acknowledges having been served with the summons and the Complaint in this action, enters a general appearance, and admits the Court's jurisdiction over Defendant and over the subject matter of this action.

2. Defendant has pleaded guilty to criminal conduct relating to certain matters alleged in the Complaint in this action. Specifically, in United States v. Daniel Glick, 17-cr-739 (N.D. Ill.), Defendant pleaded guilty to violations of Section 1343 of Title 8 of the U.S. Code. See 18 U.S.C. § 1343. In connection with that plea, Defendant admitted that he "is in fact guilty" of the charge, and admitted facts that "establish his guilt beyond a reasonable doubt." See Plea Agreement, at 2 (Dckt. No. 27). Among other things, Glick admitted the following facts:

(a) Defendant Glick was the President of three companies, which he owned and operated, namely: Financial Management Strategies, Inc.; Glick Accounting Services, Inc.; and Glick &Associates, Ltd. Through those companies, Glick provided accounting, tax, investment, and financial services to clients, which included preparing tax returns, providing financial advice, making investments, and paying bills for clients. At times during the scheme, Glick held himself out as an accountant and an investment adviser. See Plea Agreement, at 2.

(b) Beginning in or about no later than February 2011, and continuing until in or about at least April 2017, Glick devised, intended to devise, and participated in a scheme to defraud clients, and to obtain money and property from those clients by means of materially false and fraudulent pretenses, representations, and promises, and by concealment of material facts. Id. at 3.

(c) Glick caused losses to clients of at least approximately $5.2 million. Id.

(d) Glick engaged in a fraudulent scheme designed to benefit himself and his companies to the financial detriment of clients. As part of his scheme, Glick misappropriated at least several million dollars of funds from clients, and lied to clients about the use, status, and safety of their invested funds. Most of the funds that Glick misappropriated belonged to elderly clients. In order to continue and conceal his scheme, Glick created and provided false and misleading account statements to clients and made Ponzi-type payments to clients. Id.

(e) False Representations: Glick obtained funds from clients by falsely representing that he would use clients' funds solely for their benefit, which included investing clients' funds on their behalf, and paying bills and expenses on their behalf. Glick also made false representations to clients concerning the status of the clients' funds and the way in which Glick actually used their funds. Contrary to these representations, Glick misappropriated a significant portion of clients' funds for his own benefit and the benefit of his business associates, and to make Ponzi-type payments to or for other clients. Id. at 3-4.

(f) Glick obtained funds from clients by making false representations concerning the safety of their funds, including that he would safeguard their funds, and that those funds would last for many years under his management. Id. at 4.

(g) In order to continue his scheme, and to conceal his misappropriation of funds, Glick intentionally created and provided false and misleading account statements to clients and their families, which contained false information concerning the clients' assets. Glick falsely inflated the amount of cash available, the amount of stock purchased for certain clients, and the amount of interest earned. Id.

(h) Glick purchased stock in certain Israeli companies using investors' funds. Because Glick placed the Israeli stock in his companies' names, the clients had no ownership interest in that stock and could not direct the Israeli companies to take any actions concerning the stock. Id.

(i) Glick convinced one group of clients, Ev.War.'s family, to pay him a huge fee for his services. Glick failed to disclose that he had misappropriated hundreds of thousands of dollars from that family prior to the date on which they agreed to pay the fee that he requested. Glick also failed to disclose that he had misappropriated more than $1 million from another family, Na.Haus.'s family, prior to that date. Id. at 5.

(j) Misappropriation of Clients' Funds: Glick misused and misappropriated millions of dollars that belonged to his clients, and used those funds for his own benefit, and for the benefit of his companies and his business associates. Glick's misappropriation of clients' funds included the following:

(i) Personal and Business Expenses: Glick misappropriated clients' funds to pay for personal expenses and business expenses, including the purchase of a Mercedes Benz, payment of his mortgage, and repayment of two business loans. Id. at 6-7.

(ii) Payments to a Business Associate: Glick misappropriated clients' funds to pay hundreds of thousands of dollars to a long-time business associate (Da.Slag.) and that individual's family. Glick failed to disclose to his clients the payments that Glick made to Da.Slag. using clients' funds. Id. at 7.

(iii) Payments to Another Business Associate: Glick paid at least approximately $1,000,000 to another associate (E.For.) and other people or entities for the benefit of E.For. A substantial portion of those funds belonged to Glick's clients. Glick failed to disclose those payments to his clients. Id.

(iv) Ponzi-type Payments: Glick misappropriated a portion of his clients' funds to make Ponzi-type payments, namely, to make payments to other clients. For example, Glick used other clients' funds to repay a client, Chr.Prim., who discovered that Glick had misappropriated and misused her funds to make payments to E.For. Id.

(v) Expenses: In order to conceal the scheme, Glick continued to pay bills and expenses on behalf of certain clients, even though Glick knew that those clients' funds were gone. For example, Glick used other clients' funds in a Ponzi-type manner to pay nursing home expenses for an elderly client, whose funds Glick had already depleted. Id.

This Consent shall remain in full force and effect regardless of the existence or outcome of any further proceedings in United States v. Daniel Glick, 17-cr-739(N.D. Ill.).

3. Defendant hereby consents to the entry of the Judgment as to Defendant Daniel Glick in the form attached hereto (the "Judgment")and incorporated by reference herein, which, among other things:

(a) permanently restrains and enjoins Defendant from violating 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;

(b) permanently restrains and enjoins Defendant from violating Section 17(a) of the Securities Act of 1933 ("Securities Act"), 15 U.S.C. § 77q(a);

(c) permanently restrains and enjoins Defendant from violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 ("Advisers Act"), 15 U.S.C. §§ 80b-6(1) and 80b-6(2); and

(d) provides that the Court shall order Defendant to pay disgorgement of ill-gotten gains, prejudgment interest thereon, and a civil penalty pursuant to Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3), Section 20(d) of the Securities Act, 15 U.S.C. § 77t(d), and Section 209(e) of the Advisers Act, 15 U.S.C. § 80b-9(e), in an amount determined by the Court upon motion of the Commission.

4. Defendant agrees that he shall not seek or accept, directly or indirectly, reimbursement or indemnification from any source, including but not limited to payment made pursuant to any insurance policy, with regard to any civil penalty amounts that Defendant pays pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof are added to a distribution fund or otherwise used for the benefit of investors. Defendant further agrees that he shall not claim, assert, or apply for a tax deduction or tax credit with regard to any federal, state, or local tax for any penalty amounts that Defendant pays pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof are added to a distribution fund or otherwise used for the benefit of investors.

5. Defendant agrees that the Court shall order Defendant to pay disgorgement of ill-gotten gains, prejudgment interest thereon, and a civil penalty pursuant to Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3), Section 20(d) of the Securities Act, 15 U.S.C. § 77t(d), and Section 209(e) of the Advisers Act, 15 U.S.C. § 80b-9(e). Defendant further agrees that the amounts of the disgorgement and civil penalty shall be determined by the Court upon motion of the Commission, and that prejudgment interest shall be calculated from July 31, 2015, based on the rate of interest used by the Internal Revenue Service for the underpayment of federal income tax as set forth in 26 U.S.C. § 6621(a)(2). Defendant further agrees that in connection with the Commission's motion for disgorgement and/or civil penalties, and at any hearing held on such a motion:(a) Defendant will be precluded from arguing that he did not violate the federal securities laws as alleged in the Complaint;(b) Defendant may not challenge the validity of this Consent or the Judgment;(c)for the purposes of such motion, the allegations of the Complaint shall be accepted as and deemed true by the Court; and (d)the Court may determine the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn deposition or investigative testimony, and documentary evidence, without regard to the standards for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure. In connection with the Commission's motion for disgorgement and/or civil penalties, the parties may take discovery, including discovery from appropriate non-parties.

6. Defendant waives the entry of findings of fact and conclusions of law pursuant to Rule 52 of the Federal Rules of Civil Procedure.

7. Defendant waives the right, if any, to a jury trial and to appeal from the entry of the Judgment.

8. Defendant enters into this Consent voluntarily and represents that no threats, offers, promises, or inducements of any kind have been made by the Commission or any member, officer, employee, agent, or representative of the Commission to induce Defendant to enter into this Consent.

9. Defendant agrees that this Consent shall be incorporated into the Judgment and any subsequent Final Judgment with the same force and effect as if fully set forth therein.

10. Defendant will not oppose the enforcement of the Judgment and any subsequent Final Judgment on the ground, if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil Procedure, and hereby waives any objection based thereon.

11. Defendant waives service of the Judgment and any subsequent Final Judgment, and agrees that entry of the Judgment and the Final Judgment by the Court and filing with the Clerk of the Court will constitute notice to Defendant of its terms and conditions. Defendant further agrees to provide counsel for the Commission, within thirty days after the Judgment and any subsequent Final Judgment is filed with the Clerk of the Court, with an affidavit or declaration stating that Defendant has received and read a copy of the Judgment and/or Final Judgment.

12. Consistent with 17 C.F.R. § 202.5(f), this Consent resolves only the claims asserted against Defendant in this civil proceeding. Defendant acknowledges that no promise or representation has been made by the Commission or any member, officer, employee, agent, or representative of the Commission with regard to any criminal liability that may have arisen or may arise from the facts underlying this action or immunity from any such criminal liability. Defendant waives any claim of Double Jeopardy based upon the settlement of this proceeding, including the imposition of any remedy or civil penalty herein. Defendant further acknowledges that the Court's entry of a permanent injunction may have collateral consequences under federal or state law and the rules and regulations of self-regulatory organizations, licensing boards, and other regulatory organizations. Such collateral consequences include, but are not limited to, a statutory disqualification with respect to membership or participation in, or association with a member of, a self-regulatory organization. This statutory disqualification has consequences that are separate from any sanction imposed in an administrative proceeding. In addition, in any disciplinary proceeding before the Commission based on the entry of the injunction in this action, Defendant understands that he shall not be permitted to contest the factual allegations of the Complaint in this action.

13. Defendant understands and agrees to comply with the terms of 17 C.F.R. § 202.5(e), which provides in part that it is the Commission's policy "not to permit a defendant or respondent to consent to a judgment or order that imposes a sanction while denying the allegations in the complaint or order for proceedings." As part of Defendant's agreement to comply with the terms of Section 202.5(e), Defendant acknowledges the guilty plea for related conduct described in paragraph 2 above, and: (i) will not take any action or make or permit to be made any public statement denying, directly or indirectly, any allegation in the Complaint or creating the impression that the Complaint is without factual basis; (ii) will not make or permit to be made any public statement to the effect that Defendant does not admit the allegations of the Complaint, or that this Consent contains no admission of the allegations; (iii) upon the filing of this Consent, Defendant hereby withdraws any papers filed in this action to the extent that they deny any allegation in the Complaint; and (iv) stipulates for purposes of exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. § 523, that the allegations in the Complaint are true, and further, that any debt for disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under the Final Judgment or any other judgment, order, consent order, decree or settlement agreement entered in connection with this proceeding, is a debt for the violation by Defendant of the federal securities laws or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19). If Defendant breaches this agreement, the Commission may petition the Court to vacate the Judgment and/or any subsequent Final Judgment and restore this action to its active docket. Nothing in this paragraph affects Defendant's:(i) testimonial obligations; or (ii) right to take legal or factual positions in litigation or other legal proceedings in which the Commission is not a party.

14. Defendant hereby waives any rights under the Equal Access to Justice Act, the Small Business Regulatory Enforcement Fairness Act of 1996, or any other provision of law to seek from the United States, or any agency, or any official of the United States acting in his or her official capacity, directly or indirectly, reimbursement of attorney's fees or other fees, expenses, or costs expended by Defendant to defend against this action. For these purposes, Defendant agrees that Defendant is not the prevailing party in this action since the parties have reached a good faith settlement.

15. In connection with this action and any related judicial or administrative proceeding or investigation commenced by the Commission or to which the Commission is a party, Defendant (i) agrees to appear and be interviewed by Commission staff at such times and places as the staff requests upon reasonable notice; (ii) will accept service by mail or facsimile transmission of notices or subpoenas issued by the Commission for documents or testimony at depositions, hearings, or trials, or in connection with any related investigation by Commission staff; (iii) with respect to such notices and subpoenas, waives the territorial limits on service contained in Rule 45 of the Federal Rules of Civil Procedure and any applicable local rules, provided that the party requesting the testimony reimburses Defendant's travel, lodging, and subsistence expenses at the then-prevailing U.S. Government per diem rates; and (iv) consents to personal jurisdiction over Defendant in any United States District Court for purposes of enforcing any such subpoena.

16. Defendant agrees to repatriate, and take such steps as are necessary to repatriate, to the territory of the United States of America, any and all funds and assets, held by or in the name of Defendant, or in which Defendant, directly or indirectly, has or had any beneficial interest, or over which Defendant maintained or maintains or exercised or exercises control. Such funds or assets include, without limitation, any and all funds and assets, held by or in the name of Financial Management Strategies Inc., Glick Accounting Services Inc., or any other entity owned by or affiliated with Glick (collectively, the "Defendant Glick entities"), or in which any of the Defendant Glick entities, directly or indirectly, has or had any beneficial interest, or over which any of the Defendant Glick entities maintained or maintains or exercised or exercises control. Defendant agrees to cooperate to locate and facilitate the orderly liquidation, transfer, and repatriation to the territory of the United States of any such assets, as this Court or the Court in United States v. Glick, 17-cr-739(N.D. Ill.), may deem necessary and appropriate. Among other things, Defendant agrees to request, obtain, and provide all requisite information to the SEC, and shall execute all requisite documentation to facilitate the liquidation, transfer, and repatriation to the territory of the United States of any such assets. All proposed sales or liquidations shall be subject to the review and approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). Defendant agrees not to sell, liquidate, transfer, dissipate, or encumber any such assets unless and until ordered to do so by this Court or by the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). This paragraph applies to, without limitation, the investments in the Israeli companies previously identified in the SEC's memoranda and supporting papers in this action.

17. Defendant agrees that the Commission may present the Judgment to the Court for signature and entry without further notice.

18. Defendant agrees that this Court shall retain jurisdiction over this matter for the purpose of enforcing the terms of the Final Judgment.

On April 5th, 2018, Daniel Glick, a person known to me, personally appeared before me and acknowledged executing the foregoing Consent.

EXHIBIT 2

CONSENT OF DEFENDANT FINANCIAL MANAGEMENT STRATEGIES INC.

1. Defendant Financial Management Strategies Inc. ("Defendant") acknowledges having been served with the summons and the Complaint in this action, enters a general appearance, and admits the Court's jurisdiction over Defendant and over the subject matter of this action.

2. Defendant hereby consents to the entry of the Judgment as to Defendant Financial Management Strategies Inc. in the form attached hereto (the "Judgment") and incorporated by reference herein, which, among other things:

(a) permanently restrains and enjoins Defendant from violating 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;

(b) permanently restrains and enjoins Defendant from violating Section 17(a) of the Securities Act of 1933 ("Securities Act"), 15 U.S.C. § 77q(a);

(c) permanently restrains and enjoins Defendant from violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 ("Advisers Act"), 15 U.S.C. §§ 80b-6(1) and 80b-6(2); and

(d) provides that the Court shall order Defendant to pay disgorgement of ill-gotten gains, prejudgment interest thereon, and a civil penalty pursuant to Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3), Section 20(d)of the Securities Act, 15 U.S.C. § 77t(d), and Section 209(e)of the Advisers Act, 15 U.S.C. § 80b-9(e), in an amount determined by the Court upon motion of the Commission.

3. Defendant agrees that it shall not seek or accept, directly or indirectly, reimbursement or indemnification from any source, including but not limited to payment made pursuant to any insurance policy, with regard to any civil penalty amounts that Defendant pays pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof are added to a distribution fund or otherwise used for the benefit of investors. Defendant further agrees that it shall not claim, assert, or apply for a tax deduction or tax credit with regard to any federal, state, or local tax for any penalty amounts that Defendant pays pursuant to the Final Judgment, regardless of whether such penalty amounts or any part thereof are added to a distribution fund or otherwise used for the benefit of investors.

4. Defendant agrees that the Court shall order Defendant to pay disgorgement of ill-gotten gains, prejudgment interest thereon, and a civil penalty pursuant to Section 21(d)(3) of the Exchange Act, 15 U.S.C. § 78u(d)(3), Section 20(d) of the Securities Act, 15 U.S.C. § 77t(d), and Section 209(e) of the Advisers Act, 15 U.S.C. § 80b-9(e). Defendant further agrees that the amounts of the disgorgement and civil penalty shall be determined by the Court upon motion of the Commission, and that prejudgment interest shall be calculated from July 31, 2015, based on the rate of interest used by the Internal Revenue Service for the underpayment of federal income tax as set forth in 26 U.S.C. § 6621(a)(2). Defendant further agrees that in connection with the Commission's motion for disgorgement and/or civil penalties, and at any hearing held on such a motion: (a) Defendant will be precluded from arguing that it did not violate the federal securities laws as alleged in the Complaint; (b) Defendant may not challenge the validity of this Consent or the Judgment; (c) for the purposes of such motion, the allegations of the Complaint shall be accepted as and deemed true by the Court; and (d)the Court may determine the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn deposition or investigative testimony, and documentary evidence, without regard to the standards for summary judgment contained in Rule 56(c)of the Federal Rules of Civil Procedure. In connection with the Commission's motion for disgorgement and/or civil penalties, the parties may take discovery, including discovery from appropriate non-parties.

5. Defendant waives the entry of findings of fact and conclusions of law pursuant to Rule 52 of the Federal Rules of Civil Procedure.

6. Defendant waives the right, if any, to a jury trial and to appeal from the entry of the Judgment.

7. Defendant enters into this Consent voluntarily and represents that no threats, offers, promises, or inducements of any kind have been made by the Commission or any member, officer, employee, agent, or representative of the Commission to induce Defendant to enter into this Consent.

8. Defendant agrees that this Consent shall be incorporated into the Judgment and any subsequent Final Judgment with the same force and effect as if fully set forth therein.

9. Defendant will not oppose the enforcement of the Judgment and any subsequent Final Judgment on the ground, if any exists, that it fails to comply with Rule 65(d)of the Federal Rules of Civil Procedure, and hereby waives any objection based thereon.

10. Defendant waives service of the Judgment and any subsequent Final Judgment, and agrees that entry of the Judgment and the Final Judgment by the Court and filing with the Clerk of the Court will constitute notice to Defendant of its terms and conditions. Defendant further agrees to provide counsel for the Commission, within thirty days after the Judgment and any subsequent Final Judgment is filed with the Clerk of the Court, with an affidavit or declaration stating that Defendant has received and read a copy of the Judgment and/or Final Judgment.

11. Consistent with 17 C.F.R. § 202.5(f), this Consent resolves only the claims asserted against Defendant in this civil proceeding. Defendant acknowledges that no promise or representation has been made by the Commission or any member, officer, employee, agent, or representative of the Commission with regard to any criminal liability that may have arisen or may arise from the facts underlying this action or immunity from any such criminal liability. Defendant waives any claim of Double Jeopardy based upon the settlement of this proceeding, including the imposition of any remedy or civil penalty herein. Defendant further acknowledges that the Court's entry of a permanent injunction may have collateral consequences under federal or state law and the rules and regulations of self-regulatory organizations, licensing boards, and other regulatory organizations. Such collateral consequences include, but are not limited to, a statutory disqualification with respect to membership or participation in, or association with a member of, a self-regulatory organization. This statutory disqualification has consequences that are separate from any sanction imposed in an administrative proceeding. In addition, in any disciplinary proceeding before the Commission based on the entry of the injunction in this action, Defendant understands that it shall not be permitted to contest the factual allegations of the Complaint in this action.

12. Defendant understands and agrees to comply with the terms of 17 C.F.R. § 202.5(e), which provides in part that it is the Commission's policy "not to permit a defendant or respondent to consent to a judgment or order that imposes a sanction while denying the allegations in the complaint or order for proceedings." As part of Defendant's agreement to comply with the terms of Section 202.5(e), Defendant: (i) will not take any action or make or permit to be made any public statement denying, directly or indirectly, any allegation in the Complaint or creating the impression that the Complaint is without factual basis; (ii) will not make or permit to be made any public statement to the effect that Defendant does not admit the allegations of the Complaint, or that this Consent contains no admission of the allegations; and (iii) upon the filing of this Consent, Defendant hereby withdraws any papers filed in this action to the extent that they deny any allegation in the Complaint. If Defendant breaches this agreement, the Commission may petition the Court to vacate the Judgment and/or any subsequent Final Judgment and restore this action to its active docket. Nothing in this paragraph affects Defendant's: (i) testimonial obligations; or (ii) right to take legal or factual positions in litigation or other legal proceedings in which the Commission is not a party.

13. Defendant hereby waives any rights under the Equal Access to Justice Act, the Small Business Regulatory Enforcement Fairness Act of 1996, or any other provision of law to seek from the United States, or any agency, or any official of the United States acting in his or her official capacity, directly or indirectly, reimbursement of attorney's fees or other fees, expenses, or costs expended by Defendant to defend against this action. For these purposes, Defendant agrees that Defendant is not the prevailing party in this action since the parties have reached a good faith settlement.

14. Defendant agrees to repatriate, and take such steps as are necessary to repatriate, to the territory of the United States of America, any and all funds and assets, held by or in the name of Defendant, or in which Defendant, directly or indirectly, has or had any beneficial interest, or over which Defendant maintained or maintains or exercised or exercises control. Defendant agrees to cooperate to locate and facilitate the orderly liquidation, transfer, and repatriation to the territory of the United States of any such assets, as this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.), may deem necessary and appropriate. Among other things, Defendant agrees to request, obtain, and provide all requisite information to the SEC, and shall execute all requisite documentation to facilitate the liquidation, transfer, and repatriation to the territory of the United States of any such assets. All proposed sales or liquidations shall be subject to the review and approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). Defendant agrees not to sell, liquidate, transfer, dissipate, or encumber any such assets unless and until ordered to do so by this Court or by the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). This paragraph applies to, without limitation, the investments in the Israeli companies previously identified in the SEC's memoranda and supporting papers in this action.

15. Defendant agrees that the Commission may present the Judgment to the Court for signature and entry without further notice.

16. Defendant agrees that this Court shall retain jurisdiction over this matter for the purpose of enforcing the terms of the Final Judgment.

On April 5th, 2018, Daniel Glick, a person known to me, personally appeared before me and acknowledged executing the foregoing Consent with full authority to do so on behalf of Financial Management Strategies Inc. as its President.

EXHIBIT 3

CONSENT OF RELIEF DEFENDANT GLICK ACCOUNTING SERVICES INC.

1. Relief Defendant Glick Accounting Services Inc.("Relief Defendant") acknowledges having been served with the summons and the Complaint in this action, enters a general appearance, and admits the Court's jurisdiction over Relief Defendant and over the subject matter of this action.

2. Relief Defendant hereby consents to the entry of the Judgment as to Relief Defendant Glick Accounting Services Inc. in the form attached hereto (the "Judgment") and incorporated by reference herein, which, among other things:

(a) provides that the Court shall order Relief Defendant to pay disgorgement of ill-gotten gains, including prejudgment interest thereon.

3. Relief Defendant agrees that the Court shall order Relief Defendant to pay disgorgement of ill-gotten gains, including prejudgment interest thereon. Relief Defendant further agrees that the amount of the disgorgement shall be determined by the Court upon motion of the Commission, and that prejudgment interest shall be calculated from July 31, 2015, based on the rate of interest used by the Internal Revenue Service for the underpayment of federal income tax as set forth in 26 U.S.C. § 6621(a)(2). Relief Defendant further agrees that in connection with the Commission's motion for disgorgement, and at any hearing held on such a motion: (a) Relief Defendant may not challenge the validity of this Consent or the Judgment; (b) for the purposes of such motion, the allegations of the Complaint shall be accepted as and deemed true by the Court; and (c) the Court may determine the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn deposition or investigative testimony, and documentary evidence, without regard to the standards for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure. In connection with the Commission's motion for disgorgement, the parties may take discovery, including discovery from appropriate non-parties.

4. Relief Defendant waives the entry of findings of fact and conclusions of law pursuant to Rule 52 of the Federal Rules of Civil Procedure.

5. Relief Defendant waives the right, if any, to a jury trial and to appeal from the entry of the Judgment.

6. Relief Defendant enters into this Consent voluntarily and represents that no threats, offers, promises, or inducements of any kind have been made by the Commission or any member, officer, employee, agent, or representative of the Commission to induce Relief Defendant to enter into this Consent.

7. Relief Defendant agrees that this Consent shall be incorporated into the Judgment and any subsequent Final Judgment with the same force and effect as if fully set forth therein.

8. Relief Defendant will not oppose the enforcement of the Judgment and any subsequent Final Judgment on the ground, if any exists, that it fails to comply with Rule 65(d) of the Federal Rules of Civil Procedure, and hereby waives any objection based thereon.

9. Relief Defendant waives service of the Judgment and any subsequent Final Judgment, and agrees that entry of the Judgment and the Final Judgment by the Court and filing with the Clerk of the Court will constitute notice to Relief Defendant of its terms and conditions. Relief Defendant further agrees to provide counsel for the Commission, within thirty days after the Judgment and any subsequent Final Judgment is filed with the Clerk of the Court, with an affidavit or declaration stating that Relief Defendant has received and read a copy of the Judgment and/or Final Judgment.

10. Consistent with 17 C.F.R. § 202.5(f), this Consent resolves only the claims asserted against Relief Defendant in this civil proceeding. Relief Defendant acknowledges that no promise or representation has been made by the Commission or any member, officer, employee, agent, or representative of the Commission with regard to any criminal liability that may have arisen or may arise from the facts underlying this action or immunity from any such criminal liability. Relief Defendant waives any claim of Double Jeopardy based upon the settlement of this proceeding, including the imposition of any remedy or civil penalty herein.

11. Relief Defendant understands and agrees to comply with the terms of 17 C.F.R. § 202.5(e), which provides in part that it is the Commission's policy "not to permit a defendant or respondent to consent to a judgment or order that imposes a sanction while denying the allegations in the complaint or order for proceedings." As part of Relief Defendant's agreement to comply with the terms of Section 202.5(e), Relief Defendant: (i) will not take any action or make or permit to be made any public statement denying, directly or indirectly, any allegation in the Complaint or creating the impression that the Complaint is without factual basis; (ii) will not make or permit to be made any public statement to the effect that Relief Defendant does not admit the allegations of the Complaint, or that this Consent contains no admission of the allegations; and (iii) upon the filing of this Consent, Relief Defendant hereby withdraws any papers filed in this action to the extent that they deny any allegation in the Complaint. If Relief Defendant breaches this agreement, the Commission may petition the Court to vacate the Judgment and/or any subsequent Final Judgment and restore this action to its active docket. Nothing in this paragraph affects Relief Defendant's: (i) testimonial obligations; or (ii) right to take legal or factual positions in litigation or other legal proceedings in which the Commission is not a party.

12. Relief Defendant hereby waives any rights under the Equal Access to Justice Act, the Small Business Regulatory Enforcement Fairness Act of 1996, or any other provision of law to seek from the United States, or any agency, or any official of the United States acting in his or her official capacity, directly or indirectly, reimbursement of attorney's fees or other fees, expenses, or costs expended by Relief Defendant to defend against this action. For these purposes, Relief Defendant agrees that Relief Defendant is not the prevailing party in this action since the parties have reached a good faith settlement.

13. Relief Defendant agrees to repatriate, and take such steps as are necessary to repatriate, to the territory of the United States of America, any and all funds and assets, held by or in the name of Relief Defendant, or in which Relief Defendant, directly or indirectly, has or had any beneficial interest, or over which Relief Defendant maintained or maintains or exercised or exercises control. Relief Defendant agrees to cooperate to locate and facilitate the orderly liquidation, transfer, and repatriation to the territory of the United States of any such assets, as this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.), may deem necessary and appropriate. Among other things, Relief Defendant agrees to request, obtain, and provide all requisite information to the SEC, and shall execute all requisite documentation to facilitate the liquidation, transfer, and repatriation to the territory of the United States of any such assets. All proposed sales or liquidations shall be subject to the review and approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). Relief Defendant agrees not to sell, liquidate, transfer, dissipate, or encumber any such assets unless and until ordered to do so by this Court or by the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). This paragraph applies to, without limitation, the investments in the Israeli companies previously identified in the SEC's memoranda and supporting papers in this action.

14. Relief Defendant agrees that the Commission may present the Judgment to the Court for signature and entry without further notice.

15. Relief Defendant agrees that this Court shall retain jurisdiction over this matter for the purpose of enforcing the terms of the Final Judgment.

On April 5th, 2018, Daniel Glick, a person known to me, personally appeared before me and acknowledged executing the foregoing Consent with full authority to do so on behalf of Glick Accounting Services President.

EXHIBIT 4

JUDGMENT AS TO DEFENDANT DANIEL GLICK

The Securities and Exchange Commission having filed a Complaint, and Defendant Daniel Glick ("Defendant") having (1) entered a general appearance; (2) consented to the Court's jurisdiction over Defendant and the subject matter of this action; (3) consented to entry of this Judgment; (4) waived findings of fact and conclusions of law; and (5) waived any right to appeal from this Judgment:

I.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the Securities Exchange Act of 1934 (the "Exchange Act") [15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of interstate commerce, or of the mails, or of any facility of any national securities exchange, in connection with the purchase or sale of any security:

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or participation with Defendant or with anyone described in (a).

II.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating Section 17(a) of the Securities Act of 1933 (the "Securities Act") [15 U.S.C. § 77q(a)] in the offer or sale of any security by the use of any means or instruments of transportation or communication in interstate commerce or by use of the mails, directly or indirectly:

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or participation with Defendant or with anyone described in (a).

III.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating, directly or indirectly, Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 (the "Advisers Act") [15 U.S.C. §§ 80b-6(1), (2)] by use of the mails or any means or instrumentality of interstate commerce:

A. to employ any device, scheme, or artifice to defraud any client or prospective client; or

B. to engage in any transaction, practice, or course of business which operates as a fraud or deceit upon any client or prospective client.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or participation with Defendant or with anyone described in (a).

IV.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant shall pay disgorgement of ill-gotten gains, prejudgment interest thereon, and a civil penalty pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)], Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)], and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)]. The Court shall determine the amounts of the disgorgement and civil penalty upon motion of the Commission. Prejudgment interest shall be calculated from July 31, 2015, based on the rate of interest used by the Internal Revenue Service for the underpayment of federal income tax as set forth in 26 U.S.C. § 6621(a)(2). In connection with the Commission's motion for disgorgement and/or civil penalties, and at any hearing held on such a motion: (a) Defendant will be precluded from arguing that he did not violate the federal securities laws as alleged in the Complaint; (b) Defendant may not challenge the validity of the Consent or this Judgment; (c) for the purposes of such motion, the allegations of the Complaint shall be accepted as and deemed true by the Court; and (d) the Court may determine the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn deposition or investigative testimony, and documentary evidence, without regard to the standards for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure. In connection with the Commission's motion for disgorgement and/or civil penalties, the parties may take discovery, including discovery from appropriate non-parties.

V.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant shall repatriate, and take such steps as are necessary to repatriate, to the territory of the United States of America, any and all funds and assets, held by or in the name of Defendant, or in which Defendant, directly or indirectly, has or had any beneficial interest, or over which Defendant maintained or maintains or exercised or exercises control. Such funds or assets include, without limitation, any and all funds and assets held by or in the name of Financial Management Strategies Inc., Glick Accounting Services Inc., or any other entity owned by or affiliated with Glick (collectively, the "Defendant Glick entities"), or in which any of the Defendant Glick entities, directly or indirectly, has or had any beneficial interest, or over which any of the Defendant Glick entities maintained or maintains or exercised or exercises control. Defendant shall cooperate to locate and facilitate the orderly liquidation, transfer, and repatriation to the territory of the United States of any such assets, as this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.), may deem necessary and appropriate. Among other things, Defendant shall request, obtain, and provide all requisite information to the SEC, and shall execute all requisite documentation to facilitate the liquidation, transfer, and repatriation to the territory of the United States of any such assets. All proposed sales or liquidations shall be subject to the review and approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). Defendant shall not sell, liquidate, transfer, dissipate, or encumber any such assets unless and until ordered to do so by this Court or by the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). This paragraph applies to, without limitation, the investments in the Israeli companies previously identified in the SEC's memoranda and supporting papers in this action.

VI.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is incorporated herein with the same force and effect as if fully set forth herein, and that Defendant shall comply with all of the undertakings and agreements set forth therein.

VII.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, for purposes of exceptions to discharge set forth in Section 523 of the Bankruptcy Code, 11 U.S.C. § 523, the allegations in the Complaint are true and admitted by Defendant, and further, any debt for disgorgement, prejudgment interest, civil penalty or other amounts due by Defendant under this Judgment or any other judgment, order, consent order, decree or settlement agreement entered in connection with this proceeding, is a debt for the violation by Defendant of the federal securities laws or any regulation or order issued under such laws, as set forth in Section 523(a)(19) of the Bankruptcy Code, 11 U.S.C. § 523(a)(19).

EXHIBIT 5

JUDGMENT AS TO DEFENDANT FINANCIAL MANAGEMENT STRATEGIES INC.

The Securities and Exchange Commission having filed a Complaint, and Defendant Financial Management Strategies Inc. ("Defendant") having (1) entered a general appearance; (2) consented to the Court's jurisdiction over Defendant and the subject matter of this action; (3) consented to entry of this Judgment; (4) waived findings of fact and conclusions of law; and (5) waived any right to appeal from this Judgment:

I.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating, directly or indirectly, Section 10(b) of the Securities Exchange Act of 1934 (the "Exchange Act") [15 U.S.C. § 78j(b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-5], by using any means or instrumentality of interstate commerce, or of the mails, or of any facility of any national securities exchange, in connection with the purchase or sale of any security:

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or participation with Defendant or with anyone described in (a).

II.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating Section 17(a) of the Securities Act of 1933 (the "Securities Act") [15 U.S.C. § 77q(a)] in the offer or sale of any security by the use of any means or instruments of transportation or communication in interstate commerce or by use of the mails, directly or indirectly:

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or participation with Defendant or with anyone described in (a).

III.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant is permanently restrained and enjoined from violating, directly or indirectly, Sections 206(1) and 206(2) of the Investment Advisers Act of 1940 (the "Advisers Act") [15 U.S.C. §§ 80b-6(1), (2)] by use of the mails or any means or instrumentality of interstate commerce:

A. to employ any device, scheme, or artifice to defraud any client or prospective client; or

B. to engage in any transaction, practice, or course of business which operates as a fraud or deceit upon any client or prospective client.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that, as provided in Federal Rule of Civil Procedure 65(d)(2), the foregoing paragraph also binds the following who receive actual notice of this Judgment by personal service or otherwise: (a) Defendant's officers, agents, servants, employees, and attorneys; and (b) other persons in active concert or participation with Defendant or with anyone described in (a).

IV.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant shall pay disgorgement of ill-gotten gains, prejudgment interest thereon, and a civil penalty pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)], Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)], and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)]. The Court shall determine the amounts of the disgorgement and civil penalty upon motion of the Commission. Prejudgment interest shall be calculated from July 31, 2015, based on the rate of interest used by the Internal Revenue Service for the underpayment of federal income tax as set forth in 26 U.S.C. § 6621(a)(2). In connection with the Commission's motion for disgorgement and/or civil penalties, and at any hearing held on such a motion: (a) Defendant will be precluded from arguing that it did not violate the federal securities laws as alleged in the Complaint; (b) Defendant may not challenge the validity of the Consent or this Judgment; (c) for the purposes of such motion, the allegations of the Complaint shall be accepted as and deemed true by the Court; and (d) the Court may determine the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn deposition or investigative testimony, and documentary evidence, without regard to the standards for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure. In connection with the Commission's motion for disgorgement and/or civil penalties, the parties may take discovery, including discovery from appropriate non-parties.

V.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Defendant shall repatriate, and take such steps as are necessary to repatriate, to the territory of the United States of America, any and all funds and assets, held by or in the name of Defendant, or in which Defendant, directly or indirectly, has or had any beneficial interest, or over which Defendant maintained or maintains or exercised or exercises control. Defendant shall cooperate to locate and facilitate the orderly liquidation, transfer, and repatriation to the territory of the United States of any such assets, as this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.), may deem necessary and appropriate. Among other things, Defendant shall request, obtain, and provide all requisite information to the SEC, and shall execute all requisite documentation to facilitate the liquidation, transfer, and repatriation to the territory of the United States of any such assets. All proposed sales or liquidations shall be subject to the review and approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). Defendant shall not sell, liquidate, transfer, dissipate, or encumber any such assets unless and until ordered to do so by this Court or by the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). This paragraph applies to, without limitation, the investments in the Israeli companies previously identified in the SEC's memoranda and supporting papers in this action.

VI.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is incorporated herein with the same force and effect as if fully set forth herein, and that Defendant shall comply with all of the undertakings and agreements set forth therein.

EXHIBIT 6

JUDGMENT AS TO RELIEF DEFENDANT GLICK ACCOUNTING SERVICES INC.

The Securities and Exchange Commission having filed a Complaint, and Relief Defendant Glick Accounting Services Inc. ("Relief Defendant") having (1) entered a general appearance; (2) consented to the Court's jurisdiction over Relief Defendant and the subject matter of this action; (3) consented to entry of this Judgment; (4) waived findings of fact and conclusions of law; and (5) waived any right to appeal from this Judgment:

I.

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Relief Defendant shall pay disgorgement of ill-gotten gains and prejudgment interest thereon. The Court shall determine the amount of the disgorgement upon motion of the Commission. Prejudgment interest shall be calculated from July 31, 2015, based on the rate of interest used by the Internal Revenue Service for the underpayment of federal income tax as set forth in 26 U.S.C. § 6621(a)(2). In connection with the Commission's motion for disgorgement, and at any hearing held on such a motion: (a) Relief Defendant may not challenge the validity of the Consent or this Judgment; (b) for the purposes of such motion, the allegations of the Complaint shall be accepted as and deemed true by the Court; and (c) the Court may determine the issues raised in the motion on the basis of affidavits, declarations, excerpts of sworn deposition or investigative testimony, and documentary evidence, without regard to the standards for summary judgment contained in Rule 56(c) of the Federal Rules of Civil Procedure. In connection with the Commission's motion for disgorgement, the parties may take discovery, including discovery from appropriate non-parties.

II.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that Relief Defendant shall repatriate, and take such steps as are necessary to repatriate, to the territory of the United States of America, any and all funds and assets, held by or in the name of Relief Defendant, or in which Relief Defendant, directly or indirectly, has or had any beneficial interest, or over which Relief Defendant maintained or maintains or exercised or exercises control. Relief Defendant shall cooperate to locate and facilitate the orderly liquidation, transfer, and repatriation to the territory of the United States of any such assets, as this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.), may deem necessary and appropriate. Among other things, Relief Defendant shall request, obtain, and provide all requisite information to the SEC, and shall execute all requisite documentation to facilitate the liquidation, transfer, and repatriation to the territory of the United States of any such assets. All proposed sales or liquidations shall be subject to the review and approval of this Court or the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). Relief Defendant shall not sell, liquidate, transfer, dissipate, or encumber any such assets unless and until ordered to do so by this Court or by the Court in United States v. Glick, 17-cr-739 (N.D. Ill.). This paragraph applies to, without limitation, the investments in the Israeli companies previously identified in the SEC's memoranda and supporting papers in this action.

III.

IT IS FURTHER ORDERED, ADJUDGED, AND DECREED that the Consent is incorporated herein with the same force and effect as if fully set forth herein, and that Relief Defendant shall comply with all of the undertakings and agreements set forth therein.