High Court proceedings have begun against an unauthorised investment firm and its sole director the Financial Conduct Authority (FCA) alleges took £2.8m from investors.
The regulator said the individual, Daniel Willis, was knowingly concerned in unlawful activity as the sole director of London-based Argento Wealth (AWL).
The FCA said the £2.8m may have been taken from victims as part of an unauthorised collective investment scheme and/or as deposits under loan.
Willis also allegedly unlawfully arranged investments in EMB Fund Limited totalling $9m (£7.5m) breached the restrictions around financial promotion.
"The FCA considers that AWL and Mr Willis have failed to produce credible evidence that AWL can repay the funds borrowed from both retail investors and EMB (plus the interest due), and AWL is therefore insolvent," it stated.
The remaining assets of both Willis and the firm have been frozen in order for the regulator to protect the 13 direct victims who lent money to AWL and "many others harmed by its unlawful investment promotion".
The FCA warned the 13 victims are "likely to suffer very significant losses" with AWL's remaining assets far below the amount needed to return all investors' money.
According to Companies House, Willis is currently a director at three unspecified firms which are all based in London.
The FCA register shows that he was formerly an appointed representative CF1 director at Hampshire-based non-life insurer Barclay Willis but is no longer a registered individual. Barclay Willis was dissolved in March 2020.
A date for the High Court trial concerning the restitution order has not yet been set.