Sphinx Investments LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
6662061
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CURTIS, JOSHUA, STEVE
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
03/25/2026
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
STATE CORPORATION COMMISSION - RICHMOND, VIRGINIA, CASE NO. SEC-2025-00013
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
SPHINX INVESTMENTS LLC
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
SINCE AT LEAST AUGUST 2023, CURTIS HAS PROVIDED INVESTMENT ADVISORY SERVICES TO AT LEAST 16 CLIENTS ON BEHALF OF SPHINX FROM ITS
OFFICE IN RICHMOND, VIRGINIA BY ASSISTING IN MANAGING CLIENT PORTFOLIOS AND IN CERTAIN CASES OFFERING FINANCIAL ADVICE. ALTHOUGH
SPHINX WAS REGISTERED WITH THE SEC, THE DIVISION ALLEGES THAT FROM MAY 1, 2024 TO THE PRESENT DATE, CURTIS TRANSACTED BUSINESS IN

THIS COMMONWEALTH AS AN IAR FOR SPHINX WHEN HE WAS NOT REGISTERED WITH THE DIVISION OR EXEMPT FROM REGISTRATION UNDER THE ACT,
DESPITE BEING REQUIRED TO DO SO, IN VIOLATION OF § 13.1­504 A OF THE ACT. ADDITIONALLY, THE DIVISION ALLEGES THAT BETWEEN SEPTEMBER
18, 2023 AND FEBRUARY 12, 2024, CURTIS WAS REGISTERED AS AN IAR WITH TWO UNRELATED FEDERAL COVERED ADVISORS, FOUNDATIONS AND
SPHINX IN VIOLATION OF § 13.1­504 C OF THE ACT.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
03/25/2026
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 7,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
$7000 PENALTY WAS PAID ON 03/26/2026
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
(1) THE DEFENDANT, IN HIS CAPACITY AS AN INVESTMENT ADVISOR REPRESENTATIVE TRANSACTING BUSINESS IN THIS COMMONWEALTH ON BEHALF
OF SPHINX, WILL HAVE NO MORE THAN FIVE (5) CLIENTS UNLESS: (I) HE REGISTERS WITH THE DIVISION AS AN INVESTMENT ADVISOR
REPRESENTATIVE FOR SPHINX OR ANOTHER INVESTMENT ADVISER REGISTERED UNDER THE ACT OR WITH THE SEC; OR (II) HE COMPLIES WITH RULE
21 VAC 5-80-250, IF HE IS EMPLOYED BY MORE THAN ONE INVESTMENT ADVISOR OR FEDERAL COVERED ADVISOR. (2) THE DEFENDANT WILL PAY TO
THE TREASURER OF VIRGINIA, A TOTAL AMOUNT OF SEVEN THOUSAND ($7,000) IN CIVIL PENALTIES, WITH ONE THOUSAND ($1,000) DUE AT SIGNING,
AND THE BALANCE TO BE PAID ON OR BEFORE MAY 1, 2027. (3) THE DEFENDANT WILL PAY TO THE TREASURER OF VIRGINIA THE AMOUNT OF ONE
THOUSAND ($1,000) TO DEFRAY THE COSTS OF INVESTIGATION, TO BE PAID ON OR BEFORE MAY 1, 2027; (4)THE DEFENDANT AGREES TO COMPLY
WITH THE ACT IN THE FUTURE.