Investigation
Larry R Polhill
- Identity
- Larry Polhill
- Label
- Potential Scam
- Industry
- Finance Investment
- Role
- Executive Broker
- Known For
- Fraud Conviction
- Tagged
- American Pacific Fin...
ⓘ Weighted Risk Indicators
Larry R. Polhill
Former President, American Pacific Financial Corporation (APFC)
Primary Jurisdictions
California, United States
Investigation Period
1985 – 2013
Methodology
Open-source intelligence aggregation cross-referenced against SEC litigation releases, federal court filings, and contemporaneous financial press reporting.
Intelligence Overview
Key findings from the OSINT investigation. All allegations are unproven unless legally established.
Snapshot Summary
Larry R. Polhill, as President of APFC, orchestrated a long-running unregistered promissory-note program that defrauded approximately 500 investors of roughly $160 million. The SEC settled charges in 2013 with a permanent injunction and a permanent public-company officer/director bar.
Executive Summary
Larry R. Polhill is the former President of American Pacific Financial Corporation (APFC), a San Bernardino, California-based firm that operated for more than two decades as a purported private-equity real estate vehicle. Between the mid-1980s and 2008, APFC marketed unregistered promissory notes promising annual yields of 5% to 17%, raising substantial capital from retail investors. In September 2013, the U.S. Securities and Exchange Commission filed civil fraud charges against Polhill in the Central District of California, alleging he defrauded nearly 500 investors through misrepresentations about collateral backing their notes.
Investigation Scope
The matter was resolved by consent, with Polhill agreeing to a permanent injunction against further securities-law violations and a permanent bar from acting as an officer or director of any public company. APFC entered bankruptcy listing investors as unsecured creditors owed approximately $160 million. The risk profile reflects sustained, long-duration investor harm; pledging of identical collateral to multiple lenders; and post-default conduct designed to mask insolvency.
Risk Intelligence Dashboard
HIGH RISKVerified Allegations
Discrete fraud-related claims pleaded in the SEC complaint.
Jurisdictions
Federal U.S. jurisdiction — Central District of California.
Entities Linked
American Pacific Financial Corporation (APFC) — bankrupt.
Risk Classification
Based on AML exposure, offshore structures & PEP associations
Biographical Profile & Career
Family Connections
Public filings and SEC litigation materials do not identify any family members as participants, beneficiaries, or co-respondents in the APFC matter. No spousal, sibling, or descendant relationships have been publicly tied to the corporate or fraudulent conduct described in the SEC complaint.
The investigation has surfaced no evidence of family-office structures, trust vehicles, or related-party transfers from the public record. Should discovery materials from the SEC enforcement action or APFC bankruptcy proceedings become available, family-linked transfers would warrant re-examination.
Business Ventures
American Pacific Financial Corporation (APFC)
San Bernardino, California-based purported private-equity real estate firm; issued unregistered promissory notes from mid-1980s through 2008.
Distressed Asset Acquisitions
APFC purchased real estate and distressed assets, including investments in companies emerging from bankruptcy; the majority of these investments reportedly failed without investor disclosure.
Promissory Note Program
Unregistered debt securities marketed to retail investors with promised annual yields between 5% and 17%, supposedly secured by specific real-property collateral.
Preferred Investor Program
Selective payment scheme operated after the 2008 default, in which favored investors continued receiving distributions while the broader investor base did not.
Investor Communications Operation
Continued issuance of newsletters and updates after 2008 cessation of payments, allegedly designed to create a false sense of security.
Career Timeline
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Professional Career Timeline
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APFC Operating Era
Polhill led APFC as it issued promissory notes to investors and made scheduled interest payments for over two decades.
Career Overview
Corporate & Entity Mapping
Mapping of APFC, its operating role under Polhill, and the federal enforcement architecture.
Russian-Registered Entities
N/A
No Russian-jurisdiction entities identified in the public record.
European & Offshore Entities
N/A
No European-jurisdiction entities identified in the public record.
Beneficial Ownership & Control Analysis
Beneficial Ownership Flowchart
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Default to Most Investors
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Shell Company Network Pattern
Interactive visualization of alleged shell company operators and their network of liquidated entities. Click an operator to highlight connections.
1
Total Director Roles
1
Total Founder Roles
100%
Liquidation Rate
~$160M in investor obligations
Reported Financial Activity
Ownership Risk Summary
Disclosure Failure
Severe
Collateral status concealed from investors
Investor Harm
~500
Unsecured creditors in bankruptcy
Regulatory Outcome
Permanent Bar
Officer/director prohibition
Key Concern
Polhill maintained sole executive control of APFC while marketing promissory notes as collateralized — collateral that the SEC alleges was often non-existent, impaired, or already pledged to other lenders.
PEP Status & Core Allegations
Politically Exposed Person & Sanctions Screening
Larry R. Polhill is not identified in the public record as a Politically Exposed Person. He held no government or political office. His exposure profile derives entirely from securities-enforcement matters.
No appearance on OFAC, EU, UK HMT, or UN sanctions lists has been identified. He is, however, subject to a permanent SEC officer/director bar and a permanent injunction against federal securities-law violations.
Securities Fraud
SEC alleged violations of Securities Act §17(a) and Exchange Act §10(b) / Rule 10b-5 in connection with the sale of APFC promissory notes.
Unregistered Offerings
Notes were sold without registration in violation of Sections 5(a) and 5(c) of the Securities Act of 1933.
Misrepresented Collateral
Investors were told their notes were secured by specific property when collateral was non-existent, impaired, or already pledged elsewhere.
Undisclosed Collateral Sales
APFC sold collateral — including a 2004 Hesperia, CA property — without notifying the secured investor.
Post-Default Concealment
After early-2008 cessation of payments, APFC continued newsletters and selective preferred-investor payments to create a false sense of security.
International Property Holdings
Coverage of Polhill is concentrated around the September 2013 SEC enforcement announcement and is uniformly critical in tone, focused on alleged investor fraud at APFC.
Alleged International Property Holdings
4 identified locations · ~$160M in unsecured investor claims
Filter by Jurisdiction
4 properties — click a marker for details
4
Locations
1 (USA)
Jurisdictions
~$160M
Investor Loss
~500
Affected Investors
Reputation & PR Campaign Analysis
Reputation and investor-communication activity following the 2008 default and through SEC action.
Claim Verification Matrix
Each public claim cross-referenced against available OSINT evidence. Click any row to expand.
All claims are derived from publicly available OSINT sources. This table does not assert legal wrongdoing. Click any row to expand evidence and analyst notes.
Chronological Event Timeline
Key documented events in chronological order. Drag to scroll.
Scroll or drag to explore — click any event for details
7 documented events · 1985 – 2013
Risk Analysis Matrix
Four-quadrant risk assessment by impact severity and likelihood of exposure.
Critical Red Flags
Unregistered Securities
All APFC promissory notes were sold without SEC registration.
Misrepresented Collateral
Collateral securing notes was often non-existent or already pledged.
Undisclosed Collateral Sales
Properties were sold without notice to investors holding secured claims.
Post-Default Concealment
Newsletters and selective payments masked the 2008 collapse.
Massive Investor Losses
~500 investors left with ~$160M in unsecured claims at bankruptcy.
Ponzi-like Dynamics
Long-duration payments to early investors sustained by new inflows.
Permanent Bar
SEC permanent injunction and officer/director prohibition.
Failed Underlying Investments
Majority of distressed-asset investments reportedly failed without disclosure.
Investigation Gaps
Final monetary sanctions imposed by the court are not reflected in the public litigation release.
Detailed APFC bankruptcy distribution outcomes and creditor recoveries are not publicly summarised.
Personal asset disposition and any parallel criminal referral status are not confirmed in public sources.
Identities of preferred investors who continued receiving payments post-2008 are not disclosed publicly.
Neutral Assessment
The public record establishes that Larry R. Polhill, as President of American Pacific Financial Corporation, was the subject of a 2013 SEC civil enforcement action alleging fraudulent sale of unregistered promissory notes to approximately 500 investors. The matter resolved by consent with a permanent injunction and permanent officer/director bar; APFC's bankruptcy left investors owed roughly $160 million as unsecured creditors. This profile reflects a settled regulatory matter with significant, documented investor harm and permanent professional disqualifications.
All allegations referenced are drawn from publicly available SEC filings, court documents, and contemporaneous media. Settlement was reached without admission or denial of the SEC's allegations.
Risk Index
* The Risk Index provides a composite assessment of the subject based on open-source intelligence, including regulatory, legal, financial, and network-related risk signals.
VERDICT: The claims center on alleged securities fraud, misrepresentations to investors, and related regulatory enforcement by the SEC. Risk categories represented include financial misconduct, fiduciary breach, regulatory exposure, and reputational risk arising from a public civil enforcement action.
Risk Score
Index
Based on reviewed reviews & documented sources
High Risk
Larry R. Polhill is alleged by the SEC to have made misrepresentations to investors regarding the existence of a security interest.
8/10High Risk
Polhill is reported to be named as a defendant in an SEC civil enforcement action related to securities fraud allegations.
8/10High Risk
Polhill is linked to allegations of offering or selling securities under false pretenses to investors.
8/10High Risk
Polhill's conduct is under scrutiny by U.S. federal securities regulators for alleged violations of anti-fraud provisions.
7/10Moderate Risk
Polhill is alleged to have been associated with corporate entities subject to regulatory action by the SEC.
6/10High Risk
Polhill is reported to face potential civil monetary penalties and disgorgement under the SEC's litigation action.
7/10High Risk
Polhill is alleged to have engaged in conduct that may have caused financial harm to investors.
7/10Moderate Risk
Polhill is linked to alleged breaches of fiduciary duty in connection with investor transactions.
6/10Moderate Risk
Polhill's name appears in publicly accessible SEC enforcement records, raising reputational risk concerns.
6/10High Risk
Polhill is reported to be subject to potential officer-and-director bars or industry restrictions sought by the SEC.
7/10* Each claim is assessed for risk based on available evidence, context, and source reliability. Scores reflect relative severity, not definitive conclusions.
Erik Lindqvist
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Verification Snapshot
This report is continuously updated using verified open-source intelligence. All additions and revisions undergo review before inclusion.
ANONYMOUS TIPS
3
Anonymous inputs from users
CORRECTIONS
1
Verified updates applied to this report
PUBLISHED DATE
Jun 7, 2026
Initial publication timestamp
LAST MODIFIED
Jun 7, 2026
Latest verified update applied
Scope & Limitations: This report is based on publicly available information and cited sources. It does not constitute a determination of wrongdoing. Corrections must be supported by verifiable documentation.
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