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Nobody refutes my facts on Armstrong.

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Martin A. Armstrong, the founder, chairman, and owner of Princeton Economics
International Ltd (”Princeton Economics”), an unregistered investment adviser, appeals from the
decision of an administrative law judge. The law judge barred Armstrong from association with
any investment adviser based on Armstrong’s conviction on a single count of conspiracy to
commit securities fraud, wire fraud, and commodities fraud and his injunction from violation of
antifraud provisions of the federal securities laws. We base our findings on an independent
review of the record, except with respect to those findings not challenged on appeal.
II.
On August 17, 2006, Armstrong, then fifty-six years old, pled guilty to one count of
conspiracy to commit securities fraud, wire fraud, and commodities fraud.1 The district court
sentenced Armstrong to sixty months’ imprisonment and three years supervised release, and
ordered him to pay $80,000,001 in restitution to sixty defrauded customers.2
As part of his guilty plea, Armstrong entered a sworn allocution admitting to and
describing his crime. In his allocution, Armstrong admitted that between 1992 and 1999, he sold
promissory notes issued by Princeton Economics subsidiaries (”Princeton Notes”) to investors,
mostly Japanese corporations. Armstrong, through his agents, represented to the investors that
the proceeds from the sale of the Princeton Notes would be held in accounts at Republic New
York Securities (”Republic”) and that those accounts “would be separate and segregated from
Republic’s own accounts and would not be available to Republic for its own benefit.”
According to Armstrong’s allocution, after he suffered “some millions of dollars of
trading losses,” he decided “not to disclose to investors that . . . substantial losses had been
experienced in this trading of futures. And we did not disclose it.” Armstrong also admitted that
his concealment of his losses went beyond non-disclosure: “letters were sent by my company to
investors concerning how much money was in fact in the accounts assigned to them. I . . . did
send out those letters, even though . . . I knew the amounts in the accounts were less than the letters claimed
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