Coxon

*976 MEMORANDUM **

Petitioners Terence Coxon and World Money Managers (“WMM”) appeal the final order of the Security and Exchange Commission (“Commission”) entered on August 25, 2003. We affirm.

A disgorgement calculation requires only a “reasonable approximation of profits causally connected to the violation.” SEC v. First Pac. Bancorp, 142 F.3d 1186 , 1192 (9th Cir.1998) (citation omitted). Any doubts regarding the amount to disgorge are resolved against the petitioners as any “risk of uncertainty should fall on the wrongdoer whose illegal conduct created that uncertainty.” SEC v. First City Fin. Corp., 890 F.2d 1215, 1232 (D.C.Cir.1989). Relying on expert testimony, the Commission properly found that only $100,000 was necessary to capitalize World Money Securities (“WMS”) and operate it for the benefit of the Permanent Portfolio. Because WMS was instead capitalized with $950,000, the Commission reasonably concluded that $850,000 was being improperly diverted to WMS by the petitioners. There was also sufficient evidence that WMS was established and used by the petitioners to channel funds from the Permanent Portfolio to other business ventures to the benefit of the…