February 11, 2011

Mark Cahn, Esq.

General Counsel
Office of General Counsel
Securities and Exchange Commission
100 F. Street NE
Washington, D.C., 20549

Re: Administrative Claim for Losses Incurred in the Stanford

Financial Group Ponzi Scheme

Dear Mr. Cahn:

Pursuant to the Federal Tort Claims Act, 28 U.S.C. § 2671 et seq. (“FTCA”), I
submit this administrative claim (“claim”) for payment of damages suffered in the
amount of [200,710.15 $]1 as a result of the Securities and Exchange Commission’s
(“SEC”) negligent acts associated with the Stanford Financial Group (“SFG”) Ponzi
scheme. I expressly reserve the right to supplement and/or amend this claim in
the future for any reason.

In [05 2006], I became a SFG customer and SFG representative [Stanford

Group Venezuela Asesores de Inversión, C.A.] sold me fictitious
Certificates of Deposit from Stanford International Bank, Ltd. (“SIB”) in Antigua.

Prior to February 17, 2009, I was unaware of my losses or that SFG and SIB
were part of a “massive, ongoing fraud” as accused by the SEC in its civil complaint
against Stanford International Bank, et al.2

Account balance reflected on Stanford International Bank statement as of February 17,

2009 and additional expenses incurred as a result of SIB CD losses.
2

United States Securities and Exchange Commission vs. Stanford International Bank, Ltd.,
et al; February 16, 2009; United States District Court, Northern District of Texas, Dallas
 Upon the public release of the SEC Office of the Inspector General’s Report
on Investigation3 on April 16, 2010, I became aware of the impermissible and non-
discretionary acts and omissions giving rise to this administrative claim. The basis
for this claim is as follows:

SEC employees in the Fort Worth Regional Office (“FWRO”), the Denver
Regional Office and in Washington, D.C. brazenly, and with no regard for
investors, engaged in repeated negligent acts and material omissions that directly
contributed to SFG’s exponential growth from 1996-2009 as well as SIB’s
legitimacy and safety. The SEC staff abandoned its federal mandate to protect
investors as they knowingly watched from the sidelines as the size of the Stanford
Ponzi scheme grew by an average of $1 billion a year from 2001 through 2007 and
by $2 billion—primarily from U.S. investors—in 2008.

SEC employees in the Fort Worth, Denver, and in Washington, D.C. violated
the Commission’s legal mandate to enforce U.S. securities laws as well as other
applicable rules and regulations, including those related to the agency’s oversight
of and plenary authority over FINRA and SIPC.

The SEC violated its mandate under Section 15 of the Securities Act of 1934
by allowing SGC to hold active Broker Dealer and Investment Advisor licenses with
no restrictions despite known foreign financial regulatory violations, including
revocation of license and practicing without a license.

The SEC violated its mandate under Section 7 of the Investment Company
Act of 1940 by allowing SGC to sell SIB CDs without registration.

Division, Case No.: 3:09-cv-0298-N

3

United States Securities and Exchange Commission Office of the Inspector General
Report on Investigation, “Investigation of the SEC’s Response to Concerns Regarding
Robert Allen Stanford’s Alleged Ponzi Scheme,” Case No. OIG-526, March 31, 2010
 The SEC has no discretion not to act when it becomes aware of a fraudulent
or illegal securities scheme being perpetrated in the United States, and the SEC’s
refusal to act in the Stanford case contravened the very purpose for which the SEC
was established: investor protection.

Furthermore, the SEC violated its mandate established by Section 78eee(a)

(1) of the Securities Investor Protection Act of 1970 (“SIPA”) when the SEC failed
to alert SIPC when it became aware SGC was in financial difficulty (if not totally
insolvent) as early as 2004.

I hereby request the SEC consider, ascertain, adjust, and determine the
claim set forth herein and pay damages in the total amount of [200,710.15 $

Signed:

________________________ February 14,2011

Giovanni Vito Lo Russo DATE

GIOVANNI VITO LO RUSSO SANTORO

AVENIDA DE MALLORCA Nº 23 LAS ROZAS
MADRID, 28290 SPAIN

AS BENEFICIAL OWNER OF: STANFORD INTERNATIONAL BANK, LTD.

ACCOUNT NUMBER147525/147285

Allegations are detailed in relevant part in the following public records:

(i) United States Securities and Exchange Commission vs. Stanford

International Bank, et al, February 16, 2009; United States District Court,
Northern District of Texas, Dallas Division, Case No.: 3:09-cv-0298-N
 (ii) United States Securities and Exchange Commission Office of Inspector
General Report on Investigation, “Fort Worth Regional Office’s Conduct of the
Stanford Investigation,” Case No. OIG-516, June 19, 2009.

(iii) United States Securities and Exchange Commission Office of Inspector

General Report on Investigation, “Investigation of the SEC’s Response to Concerns
Regarding Robert Allen Stanford’s Alleged Ponzi Scheme,” Case No. OIG-526,
March 31, 2010.

(iv) Financial Industry Regulator Authority “Report of the 2009 Special

Review Committee on FINRA’s Examination Program in Light of the Stanford and
Madoff Schemes,” September 2009.