Whether the SEC's civil enforcement action against Stanford International Bank, Ltd. in Antigua violated the claimant's due-process rights

QUESTIONS PRESENTED This case involves an extraordinary, extra-statutory overreach of the Securities and Exchange Commission (SEC); a civil enforcement action taken by that agency that effectively obliterated a global financial services company and brought great financial harm to its owner, the Petitioner, as well as thousands of his clients around the world...coupled with the SEC's decade-long efforts to avoid accountability via an (ad hoc) application of the sovereign immunity doctrine that was never considered by Congress when enacting the Federal Tort Claim Act (28 U.S.C. 1346, 26712680) and its exceptions. The questions presented are: 1. Whether, in the absence of a "security" as defined by 15 U.S.C. 78c(a)(10), or any "in connection with the domestic purchase or sale of any security registered on a national exchange", the SEC's civil enforcement action charging securities violations against Stanford International Bank, Ltd. in Antigua, under 15 U.S.C.78j(b) (Exchange Act 10(b) and Rule 10b-5), in the preDodd Frank era 929P(b), 124 Stat. 1376 (15 U.S.C. 77v(c) with no extraterritorial application of law, and in violation of this Court's statute-clarifying decision in Morrison v. National Australia Bank, Lid. 561 U.S. 247 a violation of the claimant's rights to Due Process under the Fifth Amendment. 2 And if so, whether the Court of Appeals erred in preserving the SEC's immunity in this enforcement action which violated a legal mandate and the U.S. Constitution, finding that it was nevertheless protected by the "discretionary function shield" in 28 U.S.C. 2680(a), in violation of Berkovitz v. United States, 486 U.S. 531, 536 (1988) and its progeny. 2. Whether, after filing a civil enforcement action against a foreign bank (with no U.S. employees or office), the SEC's use of a court-appointed Receiver to search and seize certain electronically stored privacy law-protected customer account data, located outside the United States and beyond their territorial reach...constitutes an "unlawful, unreasonable, and arbitrary" investigatory search in violation of the Fourth Amendment, and Heck v. Humphrey, 512 U.S. 477 (1994), and an unlawful "interdependence" between the SEC and court-appointed Receiver, in violation of Burton v. Wilmington Parking Authority, 365 U.S. 715 (1961). And if so, whether the Court of Appeals erred in its ‘tort law analysis’ of this circumvention of United States and foreign law, an action designed to exceed the territorial scope of 15 U.S.C. 78u(b) by using a Receiver as a "state actor" proxy to engage in investigative or law enforcement , a non-discretionary and unconstitutional ‘abuse of process’ not protected by the “discretionary function exception" in 28 U.S.C. 2680(a), or "law enforcement proviso" in 28 USS.C. 2680(h), in violation of Millbrook v. United States, 569 U.S. 50 (2013). 3 .