# SEC AI washing enforcement: Delphia and Global Predictions pay $400,000 for AI claims they couldn't back

> The SEC's AI washing enforcement actions of 18 March 2024 fined two investment advisers a combined $400,000 — Delphia $225,000 and Global Predictions $175,000 — after finding their advertised artificial intelligence did not exist as claimed. Delphia's AI 'trained on client data' used no such data; Global Predictions couldn't substantiate 'first regulated AI financial advisor'. Both were censured and ordered to cease and desist.

- Verification status: verified
- Case type: deployment
- Provider: Delphia (USA) Inc. / Global Predictions, Inc. (each marketing its own purported AI)
- Client: Delphia (USA) Inc. / Global Predictions, Inc., Investment advisory — retail robo-advice marketed as AI-driven (named)
- Sector: investment advisory / United States / finance
- Verified on: 2026-08-02
- Canonical URL: https://theinternetninja.com/stories/sec-ai-washing-delphia-global-predictions-400k-civil-penalties-2024/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| SEC civil penalties for false AI claims |  |  |
| Delphia capability finding |  |  |
| Global Predictions claims findings |  |  |

## Verification method

Two signed SEC administrative orders (IA-6573 / IA-6574) fetched live, sha256-matched to March-2024 Wayback captures, quote-verified; SEC press release 2024-36 + two trade relays captured live and at CDX-confirmed Wayback timestamps

## Full case file

## The problem

AI washing — marketing an AI capability you do not actually have — met its regulator
on 18 March 2024. The SEC announced settled charges against two investment advisers,
Delphia (USA) Inc. and Global Predictions, Inc., "for making false and misleading
statements about their purported use of artificial intelligence (AI)." Delphia, a
Toronto-based firm, had told retail investors for four years that its artificial
intelligence got smarter on their data: it claimed it "put[s] collective data to work
to make our artificial intelligence smarter so it can predict which companies and
trends are about to make it big and invest in them before everyone else." San
Francisco-based Global Predictions marketed itself as the "first regulated AI
financial advisor" whose platform provided "[e]xpert AI-driven forecasts."

## What was built

Per the SEC's signed orders, less than advertised. The Delphia order (IA Release
No. 6573) finds: "From at least August 2019 to August 2023, Delphia represented that
it used artificial intelligence and machine learning to analyze its retail clients'
spending and social media data to inform its investment advice when, in fact, no such
data was being used in its investment process." Delphia admitted this to the SEC's
Division of Examinations in July 2021 and agreed to correct it — yet "additional false
and misleading statements concerning the use of its retail clients' data in the
investment process continued to be made through August 2023."

The Global Predictions order (IA Release No. 6574) itemizes four failures: the
"[e]xpert AI-driven forecasts" claim ("when in fact it did not" have them, per the
SEC's press release, which states the firm "misrepresented that its platform
provided" them); the "first regulated AI financial advisor" claim, for which it
"could not produce documents to substantiate this claim"; advertised tax-loss
harvesting "when it did not in fact offer any tax-loss harvesting services"; and a
claim of "more than $6 billion of assets on its platform, when in fact Global
Predictions does not have or report any regulatory assets under management on its
Form ADV."

## The outcome

Both firms settled without admitting or denying the findings. The price of the AI
washing: $400,000 in total civil penalties — Delphia $225,000, Global Predictions
$175,000 (the arithmetic sums exactly) — plus censure and cease-and-desist orders
under the Advisers Act. SEC Chair Gary Gensler, on the record: "Investment advisers
should not mislead the public by saying they are using an AI model when they are not.
Such AI washing hurts investors." Enforcement Director Gurbir S. Grewal: "if you
claim to use AI in your investment processes, you need to ensure that your
representations are not false or misleading."

Both order PDFs fetched for this case-file are byte-identical (sha256) to their
March 2024 Wayback captures — the artifacts are unchanged since publication.

Attribution limits, stated plainly: the SEC's own release never calls these its
"first" AI washing actions (that superlative is commentary-only and excluded here);
no fetched source quantifies investor losses; and the Delphia order's description of
the firm as "a former registered investment adviser" carries no on-record date or
cause of deregistration.

## Path to green

The critical claims rest on two signed administrative orders and the SEC's own
release — an independent regulator's record, not either firm's self-reported metric.
Remaining human steps: SEC Office of Public Affairs confirmation that IA-6573/IA-6574
remain final and unmodified, and whether both penalties were paid; a right-of-reply
to Global Predictions (PortfolioPilot); and the docket pages for File Nos. 3-21894 /
3-21895 as a second SEC artifact confirming finality.