The establishment of a registered legal entity, and the investment of at least a small amount of capital, denotes a level of commitment and permanence that a rep office does not.

FORBES: Staking Out Your Market Position In China: Part II

Furthermore, a financial entity registered by CONSOB must have first invested at least 5% in an offering for it to qualify to be crowd funded for equity.

FORBES: Italy Leads The U.S. -- In Equity Crowdfunding

The SEC alleges that JMA is not registered or licensed as an accounting firm, and that its website was paid for by a Murray-controlled entity.

FORBES: In New SEC Fraud Case, Wall Street Seems Lined With Potemkin Villages