Simply running a "passthrough" company doesn't mean the SEC won't be able to mess with you if they feel like it.
On the other hand, a company that's actually not run in the U.S at all probably doesn't have much to worry about. Look at the Kim Dotcom situation - the US tried to prosecute him, but the problem is he's not American, not based in the U.S and doesn't even do any business here, so how can he be prosecuted in the US?
The idea with SOPA was that the US government would be able to just block sites that didn't follow U.S. law, like China. We can see how that went...
He is being investigated. I just got off the phone with a SEC specialist. He said that OP was indeed breaking the law and would be dealt with post haste. Oh yeah, he also said OP was a big, fat liar and to never accept a word out of his mouth as being true.
If you don't believe me ask them here https://tts.sec.gov/oiea/QuestionsAndComments.html they called me back.
LOL.