Let's say these guys do move to Panama and have servers in Panama. They are registered in Panama but not for US securities.
What exactly can the SEC do if Panama doesn't cooperate with SEC? Seems like they can't do shit. Please enlighten me.
First off, IANAL. However, I've worked at a global financial institution so I've seen a fair bit of compliance and enforcement action in my time.
The US authorities (SEC, FBI, etc) all work with their local counterparts in countries around the world with the goal of protecting American citizens from 'harm.' In the case of a firm selling unregistered securities to Americans, US laws are certainly being broken - the question is whether or not Panamanian authorities would care. My guess is that the answer would be yes, since Panama and America work closely together, have extradition treaties, etc.
In order for Havelock to steer clear, they're going to at least need to do a minimal amount of effort such as restricting US IP addresses. Whether they have to go through the full effort of verifying addresses and whatnot is going to depend upon Panama securities laws, something which I'm not familiar with.
Just remember - the reach of US law enforcement is global. Short of running a trading operation in North Korea, Iran, China, Russia, etc there needs to be at least partial compliance with US law and full compliance with local law.