Eastern Vanguard Forex, Ltd. v. Ariz. Corp. Comm'n

In Eastern Vanguard Forex, Ltd. v. Ariz. Corp. Comm'n, 206 Ariz. 399, 410 36, 79 P.3d 86, 97 (App. 2003), the evidence supported the Commission's finding that the individual directors were control persons of the corporation that was primarily liable for A.R.S. 44-1991 violations. Id. at 411-1241, 79 P.3d at 98-99. The individuals' status as corporate officers and sole directors who lent the corporation nearly all its operating expenses evidenced was "consistent involvement in the corporation's management and its financial operations." Id. at 412-1343, 79 P.3d at 99-100. Similarly, the evidence supported a finding that a third individual was liable vis-a-vis another corporate violator of A.R.S. 44-1991 because of his status as a sole shareholder and director, his role as co-signor on all the corporate bank accounts, and his preparation of agreements with investors. Id. at 41345, 79 P.3d at 100.