Fourteen front-running records, and four are front running

Of 14 records tagged front running on 2026-09-29, 4 hold up against their primary documents: Motazedi, Gibson, Billimek and Williams, and Polevikov. Seven were tagged from a word in a policy, guidance list or footnote, two charge misuse of customer order information without trading ahead, one is a different case. The post first counted 7; Monness was reclassified after a second reading.

Published 2026-09-29 · updated 2026-10-03 · 8 min read

On 2026-09-29, searching this library for front running returned 14 case records. This piece read what each one’s primary document says. Its first version counted seven that held up; a second reading, prompted by one of the seven, brought that to four.

Update, 2026-10-03: the library now tags five records front running, the four counted here and the Classic Energy and Webb matter; Toronto-Dominion lost the tag. Update, 2026-10-02: the first version of this piece said seven of the fourteen records hold up. After publication, an audit found that one of the seven, Monness, Crespi, Hardt & Co., is a failure-to-enforce-policies case whose order finds no one front ran anything, and a second reading of the others removed two CFTC matters (EOX and Classic Energy) whose releases charge misuse of customer order information without describing trading ahead. The count that holds up is now four. Two smaller errors, a loss figure and some claims about detection, are also corrected. The page address still says “seven” because links depend on it.

Seven of the fourteen were tagged from a single word appearing somewhere other than in a finding against the respondent. The Securities and Exchange Commission’s cease-and-desist orders against Deutsche Bank Securities Inc. and Mizuho Securities USA are both about equity research analysts leaking unpublished views to favoured clients — a real technique this library already tracks as newsletter scalping — and both orders cite the same 1988 congressional record noting that Section 15(g) of the Exchange Act “was intended to include a broad range of market abuses, such as insider trading, scalping, and front running.” That sentence is legislative history explaining what the statute covers in general. Neither order alleges that Deutsche Bank or Mizuho front ran anyone. The Deutsche Bank record also carried the wrong penalty: its case page stated $100,000, which is the individual penalty a separate order imposed on the analyst Charles Grom in an unrelated proceeding cited in a footnote. The order actually before DBSI imposed a $9.5 million penalty on the firm.

The pattern repeats outside the SEC. ASIC’s 2017 infringement notices against UBS Securities concern incorrect disclosures about a crossing system and about trading as principal — UBS paid AUD $280,000 to close out two infringement notices, which under the regime is explicitly not an admission of a contravention. The release mentions front running exactly once, describing what the disclosure requirement is for: warning clients about “the risk of ‘front running’ by the participant.” That is a description of the harm a disclosure rule prevents, not a finding that UBS front ran a client. A fourth, the SEC’s administrative proceeding against Judy K. Wolf, is a books-and-records case about an altered compliance file; “Front Running report” there is the name of an internal surveillance report she used, not conduct she was found to have engaged in. Two Ontario settlements, with Royal Bank of Canada and with Toronto-Dominion Bank, list front running among the kinds of misconduct that FX desk supervision is meant to prevent, in settlements for weak supervision and controls; Ontario Securities Commission Staff did not allege those kinds of conduct against either bank. The seventh is Monness, below.

One record has the wrong case attached. The SEC’s litigation release against Sean Wygovsky and Christopher Matthaei charges insider trading in advance of SPAC merger announcements — Wygovsky allegedly tipped Matthaei to nonpublic deal information, not to his employer’s pending orders. The release does mention front running, once, in a single sentence: “The SEC previously charged Wygovsky with perpetrating a lucrative front running scheme, and Wygovsky consented to a bifurcated settlement in that matter as well.” That prior matter is a different SEC action against Wygovsky alone, and it is not in this library. The record this library held was the wrong one to carry the tag, and the tag has since been removed.

And one record has the outcome backwards. The Sergei Polevikov record was marked dismissed (it now says judgment). Reading the SEC’s litigation release shows a final judgment entered against Polevikov himself on July 29, 2022 — enjoining him from further violations and holding him liable for disgorgement — and a parallel criminal conviction: Polevikov pleaded guilty and was sentenced to 33 months in prison. What the court dismissed, the same day and with the SEC’s consent, was a separate claim against a relief defendant, Polevikov’s wife, who had been named only for the purpose of recovering trading proceeds routed through her account. A dismissal of a relief defendant is not a dismissal of the case. This library’s own priority for corrections puts an inaccurate defendant outcome first for a reason, and this is that error, in the other direction: a conviction recorded as though the defendant had walked.

A tag from a word in a policy

The first version of this piece did not catch its own instance of the problem. Monness, Crespi, Hardt & Co. is a research broker, and the SEC’s August 2014 order against the firm was counted here as a verified case of employees front running the firm’s own research. It is not. The order is a Section 15(g) case: it finds that from 2006 to early 2012 the firm did not enforce two written procedures, a restricted list and the reporting of employees’ own securities trades, and had no written procedures for its idea dinners and corporate access services. The penalty is $150,000. The phrase “research front running” appears once, in a description of what the firm’s own restricted-list policy was for: to avoid “the risk of trading ahead of a research report (research front running),” analysts and others aware of an upcoming report were not to trade the issuer. The order does not say any employee did. It says the firm could not adequately review employee trading for misuse, and a footnote adds that Section 15(g) has no requirement of an underlying violation. The SEC’s 2011 examination of the firm is what first identified the gaps. The first version also described a “CIBRS Front Running report” that the firm kept; that name does not appear in the order and belongs to no finding about this firm.

That is this piece’s own thesis happening to the piece. A word that describes a risk, a policy or a category of misconduct is not a finding that the respondent engaged in it, and the tag that follows the word is the library’s, not the regulator’s. The record’s tags were removed.

The four that hold up

Four records remain, each confirmed against the regulator’s own order, complaint or litigation release. All four are the same relationship: someone with advance knowledge of an employer’s or a fund’s own pending trades who traded ahead of them.

Arya Motazedi, a gasoline and crude oil futures trader, placed orders for personal accounts ahead of the orders he placed for his employer’s account on at least 12 occasions between September and November 2013, using his knowledge of when, how much and at what price the employer intended to trade. The CFTC’s order, which Motazedi settled, also finds that he noncompetitively prearranged at least 34 trades between the employer’s account and his own at prices that disadvantaged the employer, a separate offence from front running. It puts the employer’s losses from all of his trading activity at $216,955.80 and imposes a $100,000 penalty, restitution of the same loss and a permanent ban. The 12 front-running occasions are named in the release; it does not split the loss between the two kinds of conduct.

Christopher Gibson advised a private fund, and the SEC’s 2016 order alleges two episodes. In September 2011, before liquidating the fund’s roughly 3.7 million shares of one holding, he sold his own and two controlled accounts’ shares; the order calls this “front-running.” In late October and early November 2011, before the fund sold its remaining 4.9 million shares, he bought put options for himself and his then-girlfriend and advised his father to buy the same options, and sold them after the price fell, for total profits of about $380,000. These are allegations in an order instituting proceedings. The library holds no outcome.

Lawrence Billimek, an employee of a large asset manager, is alleged to have told Alan Williams, who had worked at several financial firms, about the employer’s market-moving trades before they were executed; on the same day Williams traded the same securities ahead of the employer or while its large orders were being placed, and closed once the price moved. The SEC’s complaint says this ran since at least September 2016 and produced at least $47 million in proceeds. Both are still allegations, with a parallel criminal case.

Sergei Polevikov, a quantitative analyst at two asset managers, did it for himself. From at least January 2014 through October 2019, on nearly 3,000 occasions he bought or sold a stock on the same side of the market as his employers before they executed trades in it for their fund clients, usually closing the same day, in an account in his wife’s name. The result is a final judgment, a 33-month prison sentence in the parallel criminal case and profits of about $8.5 million.

The figures span more than two orders of magnitude, but they are not comparable like for like. Motazedi’s is a loss to his employer covering two kinds of conduct; Gibson’s and Williams’s are allegations; only Polevikov’s is a profit that ended in a judgment. What the two larger cases share is duration: Polevikov describes a scheme running about five years, and the Billimek and Williams complaint one running six.

What the documents say about how they were caught

Less than the first version claimed. Only one of the four records says. The Billimek and Williams release states that SEC staff used the Consolidated Audit Trail database to uncover Williams’s trading and to see how he profited by repeatedly front-running large trades by Billimek’s employer. CAT went live for equities in stages beginning in 2020, which is consistent with a pattern spread over years and many trades being found that way. The Motazedi release thanks the staff of CME Group’s Market Regulation Department for their cooperation, which is not the same as saying the exchange’s surveillance found him. The Polevikov release describes the pattern, nearly 3,000 same-side trades preceding his employers’, but does not say how it was found, and the Gibson order is silent too. An earlier version of this section credited SEC examinations, customer complaints and CAT analysis to cases whose documents say none of those things, and said the CAT work in Polevikov’s case. It has been cut back to what the documents state.

Two near misses

Two CFTC matters were counted as the second half of the original seven, brokers who front ran a customer’s block order. The library does not hold the complaint in one case or the order in the other, so this reading is of the CFTC’s press releases, which are the primary documents we have. On those, neither describes trading ahead.

The 2018 matter, EOX Holdings and Andrew Gizienski, has the placeholder title “Block Trade Broker” in this library. The release is headlined as insider trading. It alleges that Gizienski, an introducing broker’s associated person, exercised discretion over a friend’s account from August 2013 to May 2014 while continuing to broker block trades for EOX customers, disclosed confidential information about those customers (identities, trading activity and positions) to the friend, and traded the account on the basis of it. It does not say the friend’s trades preceded those customers’ orders. The phrase “front running” appears only in the task force paragraph that lists the kinds of misuse of confidential information the Commission pursues. The matter is still an unresolved allegation.

The 2019 order, against Classic Energy LLC and Mathew Webb (placeholder title “Energy Broker and Its Owner”), is closer. On at least 63 occasions from April 2014 to September 2015, Webb used block-trade order information that customers gave him to take the other side of their trades in his own proprietary account instead of finding a counterparty, and kept charging brokerage commissions as though he had arranged them with someone else. The order’s figures are a $1.5 million penalty and $413,065 of disgorgement, and the release says he made over $400,000. That is a serious misuse of customer orders, and a looser definition of front running might include it. This library’s technique page defines front running as trading ahead of a customer order to capture the price improvement the order will produce, and filling the order from your own account is trading against it, not ahead of it. The release uses the phrase only in the same standing paragraph as the EOX release. We have dropped it from the count, and say here that it is a closer call than the others.

Which of the library’s front-running records this counts

On 2026-10-03 the library tags five records front running. This piece counts four: Motazedi, Gibson, Billimek and Williams, and Polevikov. It does not count the fifth. Classic Energy and Mathew Webb is the CFTC matter above, a closer call: Webb took the other side of his customers’ block trades, which the order treats as misusing their order information, and the tag on it should be reviewed against the order itself. EOX, Monness, Deutsche Bank Securities, Mizuho, UBS, Wolf, Wygovsky, Royal Bank of Canada and, since the second audit round, Toronto-Dominion Bank no longer carry the tag. The Toronto-Dominion record is an Ontario settlement over weak supervision and controls in its FX business, and had been tagged from a list of the kinds of misconduct the controls were meant to catch.

What this means for the library

None of this changes what front running is — the technique page describes the conduct accurately, and nothing in the four confirmed cases contradicts it. It changes how much of the library’s own tagging under this technique should be trusted at a glance, and how much of this piece could be trusted at a glance, since its first version made the mistake it set out to find. Of fourteen records, four described the conduct. Ten were tagged because the words front running appeared in a policy, a footnote, a list, a paragraph on what a task force pursues, or in a different matter, or because the conduct described was something nearby. A technique tag assigned by keyword match will always need this kind of check against the primary document before a number gets quoted from it, and a check by one reader needs a second one, which is exactly what this site’s editorial policy says a reader should expect.

Techniques referenced

• Front running — Front running is trading ahead of a customer order to capture the price improvement that order will produce, which breaches a duty owed to that customer rather than falsifying any public price.

Cases referenced

Reviewed October 3, 2026. Spotted an error? Tell us.