The U.S. attorney's office also promised not to seek fines or forfeitures; instead, it would focus on a "restitution order for the [alien] victims". Since the U.S. attorney's press release speaks of losses of $110 million, $85 million, and $8 million, the restitution might reach as much as $203 million; that's more than a fifth of a billion dollars. In earlier rounds of punishments, the SEC laid down a 10-year-long banishment from the securities business (not just the EB-5 trade, but stocks and bonds as well) on Quiros' son-in-law, Joel Burnstein. The latter was an account executive at Raymond James, the big brokerage outfit where some of Quiros' ill-gotten gains were parked. Ten years is a long time. Still earlier, Raymond James agreed to pay $150 million to get out of their involvement in the case. I have studied this matter rather carefully and cannot possibly see how the brokerage firm could have made a fraction of the $150 million.