Leor Moshe raised $47M promising MCA returns of up to 53%.

Leor Moshe of Toms River, New Jersey pleaded guilty on August 13, 2026 to wire fraud after raising roughly $47 million from at least 87 investors who were told the money would fund short-term business advances. Federal filings say Capital Funding ASAP LLC sent less than $230,000 to the one real cash-advance company named in the record over four years.

There is a number buried on page 23 of the SEC's complaint that should draw your attention.

Over roughly four years, Capital Funding ASAP LLC, the New Jersey company at the center of a $47 million fraud, sent less than $230,000 to the actual merchant cash advance company it claimed to be partnered with. It received back less than $730,000. Those are the entire documented dealings between the "short-term business lending operation" Leor Moshe sold to his neighbors and a legitimate MCA shop.

Meanwhile, $11 million went to gambling debts, credit cards, a personal crypto account, home renovations, and car payments.

Moshe pleaded guilty to one count of wire fraud on August 13, 2026, before U.S. District Judge Robert Kirsch in Trenton. The SEC filed a parallel civil complaint the same day against Moshe and two men who sold the investments for him. Sentencing is set for December 16, 2026.

This is not the first time our industry's name has been borrowed as a cover story, and it will not be the last. What makes this case worth your time isn't the size of it. It's how precisely the structure mirrored a real funding operation, right down to the commission split.

The business that wasn't

Moshe incorporated Capital Funding ASAP in January 2018 and opened a single bank account at a major national bank that same year. He was the only signatory on it until May 2023.

That detail does most of the work in this story. One account. One signatory. No segregation of investor funds, no separate deal-level accounting, no participation ledger, no third-party servicing. Everything anyone gave him landed in the same place, and he moved it wherever he wanted.

The pitch was straightforward and, to a broker's ear, almost boring. Capital Funding made short-term loans to small businesses. Investors would supply capital. Moshe would pick the borrowers, administer the paper, and run the operation. Investors would get a fixed return plus their principal back.

When one investor asked for a list of the borrowers, he was told that information was confidential.

The returns were where the story stopped being boring. On two- and three-month positions, investors were promised 9% to 10% at maturity. On one-year positions, where most of the money went, they were promised somewhere between 22% and 53% annually.

Anyone who has actually syndicated knows what's wrong with that shape. Participation income tracks deal performance. It moves with defaults, with early payoffs, with collection rates, with what the portfolio actually did that month. A guaranteed 53% coupon isn't an MCA return. It's a bond that no lending business on earth could service.

According to the SEC, the business generated at most a small fraction of what was paid out. Nearly every dollar that flowed into the account came from investors. There was no other meaningful source of income.

Where the money actually went

The complaint walks through the arithmetic in a way that leaves little room for interpretation.

On February 5, 2021, a $480,000 investment landed. The account had held about $35,000 before it. Three days later, with no other deposits, $88,000 moved to Moshe's personal cryptocurrency account.

On January 18 and 19, 2023, $350,000 came in from two investors. On those same two days, $262,223 went out to three earlier investors. Without the new money, the account held about $155,755, not enough to cover the payments.

On February 10, 2023, a $2 million investment arrived. Over the following three days, $820,938 went out to five earlier investors. Without that $2 million, the balance was roughly $349,000.

That last one is the transaction the criminal charge was built on. The Information filed in Trenton charges a single wire, the interstate transfer of approximately $2 million on February 10, 2023, as the executing act of the scheme.

All in: more than $11 million diverted to personal use, and more than $850,000 in payments to earlier investors funded by later ones.

The forged funder letter

Here is the part that belongs to this industry specifically, and the part almost no coverage has picked up.

To land that $2 million investor, Moshe told them Capital Funding had partnered with a legitimate New Jersey cash advance company to write tens of millions of dollars in advances to merchants. The real numbers, per the SEC: under $230,000 out, under $730,000 back, across the entire period.

So he built the paper trail he needed.

In March 2023 he incorporated a second entity, Iruka Funding LLC, with a name chosen to resemble the real cash advance company's. He opened a bank account for it and told the bank it shared the real company's legal address. He then forged an Iruka Funding bank statement for February 2023 showing $26.1 million in deposits and $26.7 million in withdrawals. Both figures were invented. He sent it to the investor.

Then he forged a letter, dated March 1, 2023, purportedly signed by the president of the real cash advance company, stating that Capital Funding had $21.5 million invested in cash advance deals with it.

That investor put in more than $3.5 million between November 2022 and April 2023.

Sit with that for a moment. Somewhere in New Jersey is a funder who did a couple of small deals with a company they probably barely remember, and whose president's signature ended up on a forged letter used to pull millions out of a family. That funder is not accused of anything. They were the credibility, and they never knew they'd been spent.

If you fund, this is your exposure. Not the fraud itself, the use of your name as collateral for someone else's.

The comp structure will look familiar

Starting around August 2021, Moshe brought in two men from his own community to sell the deal: Isaac Odes and Jacob Goldman. Neither had ever been a registered broker-dealer or associated with one. Between them they brought in at least 25 investors and more than $23 million.

They were paid on transaction volume. Odes drew commissions ranging from 5% to 25% per investment and received more than $1.7 million from Capital Funding. Goldman received more than $7 million.

The SEC quotes Goldman explaining the economics to an investor he was trying to recruit as a sub-agent: offer people 25%, keep 10% for yourself, and if a prospect holds out for 30%, that extra five points comes out of your own cut.

Any ISO principal reading that just recognized their own comp plan.

That's the uncomfortable insight in this case. A merchant-side channel, house rate, agent split, negotiate off your own points, is a perfectly legitimate structure for selling commercial financing to businesses. Bolt that same structure onto the sale of passive investment positions to retail individuals and you have built an unregistered broker-dealer network. The SEC charged Goldman and Odes under Exchange Act Section 15(a) for exactly that. Both have been charged civilly only; neither has been convicted of any crime.

Why these were securities, and why that matters to you

Moshe papered the deals three different ways: investor agreements, a promissory note, and Heter Iska agreements, an instrument rooted in Jewish law that restructures what would otherwise be an impermissible interest-bearing loan into a profit-sharing partnership. Some investors got two documents. Some got one. Some got nothing but a phone call.

The SEC's position is that it didn't matter which one you held. Every position was a security.

The reasoning is the standard investment-contract analysis, and it's worth internalizing because it maps directly onto how participation capital gets raised in this business. Investors put money into a common pool. The funds weren't segregated, everything sat in the one account. Investors had no role in selecting borrowers, structuring deals, or managing the business. Every investor's outcome rode on the same thing: whether Moshe's enterprise worked. Profits were expected to come entirely from his efforts.

That is an investment contract, regardless of what the document at the top calls the parties.

The distinction that saves a legitimate syndication program is real participation. A syndicate partner who reviews the file, approves or declines the deal, takes a defined share of an identified receivable, and gets deal-level reporting is in a different position than someone who wires money into a pooled account and waits for a coupon. The further you drift toward pooled, passive, and fixed-return, the closer you are to selling a security, and the more you need securities counsel before, not after.

The other rule this case underlines: paying someone transaction-based compensation to bring you investor capital, when they aren't registered, is its own violation. It doesn't require fraud. Goldman and Odes are charged with the registration failure independently of Moshe's alleged deception.

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Not a new story

Anyone who has been in this industry a decade has watched this movie before, at least three times.

1 Global Capital, out of Hallandale Beach, raised more than $287 million from over 3,400 retail investors between 2014 and its July 2018 bankruptcy, sold through a network that included barred brokers and unregistered sales agents across at least 25 states. 1 Global actually wrote a substantial MCA book; the fraud was in what it told investors and where the money went. Chairman Carl Ruderman pleaded guilty in October 2023 and was sentenced in January 2024 to five years, with a forfeiture judgment of $285,599,532. Four co-conspirators, including two attorneys who supplied legal cover, drew sentences from eight months to five years. We covered Ruderman's sentencing when it came down.

MJ Capital Funding, out of Pompano Beach, raised approximately $190.7 million between October 2020 and August 2021, from thousands of investors, promised 120% annually, through recruiters paid roughly 10% of what they raised. Johanna Michely Garcia, whose company website described her as being called "Mother Teresa" in her community, was sentenced in December 2024 to 20 years, the maximum on the count she pleaded to. Investors lost close to $90 million. Her co-defendant Pavel Ramon Ruiz Hernandez got 110 months. Notably, after the FBI and SEC shut MJ Capital down in 2021, prosecutors say Garcia started a nearly identical scheme and kept running it, including from custody.

And more recently, E-Card Lending: Pablo Silverio Rebollido of Miami, presenting a thriving MCA operation to investors while funding no advances at all, sentenced to more than 19 years on a roughly $40 million scheme. Same shape. We also covered an SEC complaint against Joel Natario and Patch Baker over MCA purchase agreements sold as investments where no funding to small businesses ever occurred, and the Disruptive MCA collapse in Miami.

Line them up and the blueprint is identical every time. Promise a fixed return. Attribute it to an MCA book. Pay commissions to unlicensed recruiters. Pool everything into one account. Pay old investors with new money until the inflow stops.

The MCA business is the costume. It gets chosen because it's genuinely high-yield, genuinely short-duration, and genuinely opaque to outsiders, which means a double-digit promised return sounds plausible to someone who doesn't know the space, and "the portfolio is proprietary" sounds like a reasonable answer when they ask for detail.

What this costs the rest of us

Every one of these cases makes capital more expensive and more suspicious for legitimate funders.

Family offices that read a CNBC story about a 120% MCA Ponzi don't distinguish between MJ Capital and your platform with a real underwriting team and a five-year loss curve. Banks tighten. Regulators file it under "small business finance." Disclosure regimes get written by legislators whose only exposure to this industry is a fraud headline. And the funder whose name got forged onto a letter spends the next year answering questions.

The practical takeaways are unglamorous and worth writing down anyway.

If you raise participation capital, get securities counsel to look at your structure before you scale it, specifically at whether your participants are passive, whether the returns are fixed, and whether funds are pooled or deal-specific. If you pay anyone to bring you investor money, understand that transaction-based compensation to an unregistered person is a standalone violation. Segregate participant funds and give deal-level reporting; the single commingled account is the common thread in every case above.

And check the background of anyone offering you a position at Investor.gov; Moshe, Goldman, and Odes had never been registered with the SEC in any capacity.

If you're a funder, know that your name has value to people who want to borrow it. Verify partnership claims made in your name when you hear about them, and be deliberate about what you put on letterhead.

And if someone offers you a guaranteed 53% return on an MCA book, the correct response is the one the SEC's Thomas P. Smith Jr. gave in announcing the case: it falls squarely in the category of things that sound too good to be true.