While the pace of special purpose acquisition company (“SPAC”) transactions and related enforcement activity decreased significantly after a peak in 2021, SPAC activity resumed meaningfully in 2024 and 2025, and SEC enforcement actions have followed. In November 2025, in a litigated case, the SEC charged Srinivas Koneru for allegedly engaging in a fraudulent scheme in connection with the November 2020 business combination of Koneru’s then-private company, Triterras Fintech Pte. Ltd. (“Triterras Fintech”), with Netfin Acquisition Corp. (“Netfin”), a Nasdaq-listed SPAC. According to the SEC’s complaint, Triterras Fintech’s principal asset was an online physical commodities trade and trade finance platform called “Kratos.” Koneru was the founder and owner of the firm and allegedly made highly misleading statements about the Kratos platform to persuade Netfin's shareholders to vote in favor of the business combination and accept the exchange of their Netfin securities for securities to be issued by the surviving public company (rather than redeem them at a price of around $10 per share). Koneru allegedly portrayed Kratos as transforming the industry with its two modules on which it charged fees: a “Trade Discovery” module that allowed traders to conduct and document trades, and a “Trade Finance” module that delivered access to trade financing for traders from lenders on the platform. The complaint alleges that Koneru held out Kratos’ Trade Finance module as a solution for a claimed $1.5 trillion annual shortfall in trade finance funding for traders, a key feature of Kratos and a focus point for investors. Koneru allegedly represented, through communications with investors and his approval of public filings, that by August 2020, Kratos had onboarded ten lending funds to the Trade Finance module of its platform and that the volume of financing by lenders in the module totaled $1.1 billion. In reality, as the complaint alleges, only around 10% of the reported Trade Finance module volume and associated revenue involved the ten lending funds, and the limited financing by those funds involved entities majority-owned by Koneru. Koneru allegedly also directed that some of these loans be added to Kratos after the fact, creating the false impression that those loans originated on the platform. According to the complaint, based on this false picture of Triterras Fintech’s business, Netfin’s shareholders overwhelmingly voted to approve the business combination, and less than 3% of Netfin’s public shares were submitted for redemption, which resulted in Koneru’s receipt of $60 million in cash, a controlling equity stake in the surviving public company, Triterras, Inc. (Triterras), and Koneru becoming Triterras’s CEO and Executive Chairman. Following final rulemaking in 2024 (see our prior summary), imposing additional disclosure and other obligations in SPAC and de-SPAC transactions, further SEC enforcement activity could be forthcoming.