The lawyer representing Mr. Correia in his criminal case, William J. Harrington, said Mr. Correia was in final stages of settling the case with the S.E.C. As part of his guilty plea in the criminal case, Mr. Correia agreed to forfeit the $43,650 that the government said he had gained from the operation.

Mr. Parnas had been a fixture in Trump donor circles, and was a central player in Mr. Giuliani’s Ukrainian dirt-digging campaign. Over the course of several months while working with Mr. Giuliani in late 2018 and 2019, Mr. Parnas traveled to Kyiv to press Ukrainian officials to investigate Hunter Biden, the son of President Biden, who was then a candidate.

But Mr. Parnas was arrested in October 2019 and charged with campaign finance violations, including misrepresenting the source of a $325,000 donation to a pro-Trump fund-raising committee. After Mr. Parnas’s arrest, he broke with Mr. Giuliani, Mr. Trump’s personal lawyer, and sought to assist House investigators in the first impeachment of Mr. Trump.

Separate from the Ukraine efforts, Mr. Parnas had turned to Mr. Giuliani for help with Fraud Guarantee.

Mr. Giuliani had endorsed LifeLock, a company that offered identity theft protection, and Mr. Parnas and Mr. Correia had hoped he could do the same for Fraud Guarantee. After pitching the company to Mr. Giuliani, Mr. Parnas agreed to make an initial payment of $500,000 to Mr. Giuliani’s consulting firm.

Mr. Parnas and Mr. Correia then touted Mr. Giuliani’s involvement to investors. And, according to the S.E.C., they told potential investors that they had raised millions of dollars from other investors and that they had personally pumped hundreds of thousands of dollars of their own money into the company.

In fact, the S.E.C. said, they “only raised less than half of the funds they told investors they had raised, none of which they themselves had invested.”

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