APOLLO GLOBAL MANAGEMENT INC CLASS

Apollo owns Atlas Air through its PE portfolio. During the Gaza conflict, Atlas Air transported weapons shipments from the US to Israel, creating one degree of separation between Apollo and arms supply to an active occupation. The nexus is indirect but documented.

In August 2016, the SEC charged four Apollo Global Management private equity fund advisers with misleading fund investors about fees, a loan agreement, and failure to supervise a senior partner. The resulting $52.7 million settlement was the largest SEC penalty against a private equity firm at the time (SEC Press Release 2016-165).

Apollo had 10-year monitoring agreements with its portfolio companies. When a portfolio company experienced a liquidity event such as a sale or IPO, Apollo accelerated the remaining monitoring fees into a lump-sum payment. While Apollo disclosed the existence of monitoring fees, it did not adequately disclose its practice of accelerating them — extracting years of future fees at once to the detriment of fund investors. Separately, the SEC found that Apollo failed to disclose certain interest payments on a loan between an affiliated general partner and five funds. A then-senior partner was twice caught improperly charging personal expenses to Apollo-advised funds and portfolio companies; Apollo's response was limited to verbal reprimands and requiring repayment, with no further disciplinary steps. The settlement included $37.5 million in disgorgement, $2.7 million in interest, and a $12.5 million penalty.