If a microcap fraud like PTOI can still survive for years after two regulatory fraud actions were taken against them, and to do so through continued reliance on the same fraudulent acts for which they were taken to task, something needs a bit of tweaking.

Perhaps a weakness in the settlements of these microcap fraud cases is the asymmetry of the boilerplate language of the Final Judgement and Consent.

I think it's fine to have the standard "Without admitting or denying the allegations in the Commission’s complaint ". It gives fraudsters an exit that doesn't require them to agree to anything that could be used against them in future civil and criminal litigation. That's a powerful incentive for fraudsters to agree to a settlement that's cost-saving for taxpayers. However, I believe it would be a strong improvement if a statement were also included to the effect that neither does the SEC acknowledge any change in their position on the facts of their case.

The SEC should also advertise front and center on their website that a settlement never means, unless otherwise stated, that they changed their position on the facts in their case against the defendant.