District court properly instructed jury that investment adviser fraud only requires proof of intent to deceive. Defendant, a financial adviser, was found guilty by a jury of securities-related offenses including criminal violations of Section 206 of the Investment Advisers Act of 1940. On appeal, defendant contended that the district court erred in not instructing the jury that investment adviser fraud requires proof of intent to harm his clients. The Second Circuit disagreed and affirmed the conviction, determining that Section 206 does not require proof of intent to injure or actual injury to clients. The panel added that the district court properly instructed the jury that investment adviser fraud requires only intent to deceive. (5/4/2016) Tagliaferri.