SEC wins judgment barring Bluesky Eagle from Exempt Reporting Adviser Form ADV filings

Effective February 11, the U.S. District Court for the Southern District of New York entered a final judgment by default against Bluesky Eagle Capital Management Ltd. in an enforcement action brought by the U.S. Securities and Exchange Commission; the SEC disclosed the judgment in Litigation Release No. 26484, published February 19.

The SEC complaint, filed November 13, 2025, alleged that Bluesky Eagle made material misrepresentations and unsubstantiated statements in its December 2023 Form ADV, including claims that it was an Exempt Reporting Adviser, a public company operating from New York City office space, and that it managed $10 million in U.S. assets and advised a private fund for which another registered investment adviser reported information on its own Form ADV. The SEC said the complaint alleged those claims were contradicted by information including that the real estate manager of the stated New York office space had no knowledge of the firm or its purported executives, that the separate RIA had not reported information about the purported private fund, that the Commission found no other SEC filings reporting information about the private fund, and that a search of the SEC’s public company database yielded no information on Bluesky Eagle. The SEC also alleged the firm failed to respond to a request by SEC attorneys for records to substantiate the Form ADV statements.

The judgment permanently enjoins Bluesky Eagle from future violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940 and permanently enjoins Bluesky Eagle, its owners, and its executive officers from filing Form ADV as an Exempt Reporting Adviser, and orders a civil penalty of $1,182,254, the SEC said. The SEC stated the litigation was conducted by staff in its Boston Regional Office and that it appreciated assistance from the Financial Industry Regulatory Authority (FINRA).