Six regulators compared

The six agencies' records differ in kind. Of 2,637 records, the SEC holds 1,860, the CFTC 338, the AMF in France 209, ASIC 113, the OSC 69 and the FCA 48. A penalty is stored for 31% of ASIC records and 90% of AMF ones. Medians are US$173,436 (SEC), US$1.5 million (CFTC), A$65,000, C$267,500, £279,922 and €355,000, unconverted. Gaps follow collection as much as regulators.

Published 2026-10-05 · 10 min read

Put the six agencies’ records side by side and they look different in almost every respect: what they cover, how the matters ended, how often money is stated, and how large that money is in its own currency. Much of that difference is real enforcement behaviour. Some of it is simply how this library collected each agency’s records. This post separates what the data can say from what it cannot.

The finding first

The library holds 2,637 records from the six. The SEC accounts for 1,860 (71%), the CFTC 338, the French Autorité des marchés financiers (AMF) 209, ASIC 113, the Ontario Securities Commission (OSC) 69 and the UK Financial Conduct Authority (FCA) 48. No other agency appears. The AMF is the newest addition: its records are decisions of its Commission des sanctions, the administrative sanctions committee, and they were added on 5 October 2026.

• Money. A stored penalty figure exists for 90% of AMF records, 72% of CFTC, 63% of FCA, 54% of SEC, 46% of OSC and 31% of ASIC. Counting any money field (penalty, disgorgement or interest), the SEC figure rises to 69% and the CFTC to 75%; for the AMF it stays at 90%.
• Outcome. CFTC, ASIC, OSC and AMF records are mostly judgments (61%, 85%, 54% and 80%); the FCA’s are mostly settlements (58%). The SEC’s largest group is settled (56%), with 8% still recorded as filed.
• Bans. 36% of OSC records record a ban, 31% of SEC, 29% of CFTC, 9% of ASIC (10 records), 6% of FCA (3 records) and 2% of AMF (4 records).
• Criminal case alongside. 81% of ASIC records, 32% of CFTC, 31% of SEC, 19% of OSC, 17% of FCA and 3% of AMF.
• Typical penalty, each in its own currency. Median US$173,436 for the SEC (1,005 records) and US$1,500,000 for the CFTC (244). Median A$65,000 for ASIC (35), C$267,500 for the OSC (32), £279,922 for the FCA (30) and €355,000 for the AMF (189). These numbers are not comparable across currencies, and the next section says why.

How it was measured

A script, scripts/analysis/cross-border.mjs, reads every case file and groups by the agency field. Every figure in this post comes from its output.

Currencies. The SEC and CFTC amounts are the penaltyUsd field. For ASIC, the OSC, the FCA and the AMF the amount is the penaltyNative field, whose currency occurs as AUD on all 35 ASIC records that have one, CAD on all 32 OSC records GBP on all 30 FCA records and EUR on all 189 AMF records. No record of the SEC or CFTC has a native amount, and no other currency appears. Nothing was converted. A conversion needs an exchange rate, and no single rate fits 2010 to 2026: sterling, the euro and the Australian and Canadian dollars each moved by tens of percent against the US dollar across the period, and a rate fixed to one date would misstate the rest. The records span different years and different legal regimes, so even a correct conversion would not make a penalty under one regime comparable with another. The library’s own decision on this is the same: non-US penalties are recorded as published, and left out of every USD total. So this post compares shares and shapes, and within each currency the distribution of amounts.

As of 5 October 2026. The French AMF’s 209 records were added after the five-agency evening update of 4 October, taking the library from 2,428 to 2,637 records. Everything below was recomputed with the AMF included; the SEC, CFTC, ASIC, OSC and FCA figures are unchanged by that addition, and the shares of the whole library (for instance the SEC’s 71%) fall. The notes that follow describe the 4 October corrections that the SEC, CFTC, ASIC, OSC and FCA figures reflect.

As of 4 October 2026 (evening). The figures were recomputed after the library’s status and flag corrections that day. Of the 733 records that had been recorded as filed, 543 were researched and moved to settled, judgment or another outcome, so the SEC’s “filed” count fell from 589 to 157 and the CFTC’s from 107 to 30; the settled and judgment shares, the share of records with money and the ban shares moved with them. The criminalParallel flag was corrected on a further batch of records, and 805 of the then 2,428 records carried it (811 of 2,637 with the AMF). Five ASIC records that had held an Australian-dollar amount in a US-dollar field were fixed, and ASIC’s penalty count is now 35 where an earlier version of this post counted 26. On eleven further records the duplicated money on twin records of one matter was removed, which lowered the SEC and CFTC penalty counts slightly. The CFTC’s largest record, the five-bank benchmark order, is now stored at US$1.475 billion and as settled, and two further CFTC benchmark orders (Lloyds and R.P. Martin) moved from judgment to settled. Outcomes in some records cover only some of the defendants.

A penalty here is whatever monetary sanction the record stores in that field. For the OSC it includes the voluntary payments the Royal Bank of Canada and Toronto-Dominion settlements describe, which are payments to the regulator rather than penalties imposed after a finding; for ASIC it includes infringement-notice penalties; for the AMF it is the fine (sanction pécuniaire) the committee imposes or the settlement amount it homologates, and a “judgment” at the AMF means a sanctions decision rather than a court judgment. Where a record involves several respondents the stored amount is the sum across them.

“Share with money” counts records in which a penalty is stored; I also give the wider count that adds disgorgement and interest, which the ASIC, OSC, FCA and AMF records do not store (their native field holds the one figure). A record with no money may be a matter still pending, a criminal case, a settlement whose release gave no figure, or a record where the document was not clear enough to extract one.

What each agency’s records cover

The records are not a census of any regulator. The collection differs by source:

Three consequences matter for any comparison. First, each source is filtered by a classifier that keeps a matter only if it matches a manipulation-related technique, so the library is a selection of each agency’s output, not all of it. The FCA publishes far more final notices about consumer credit and fees than about market abuse, and the Tribunal’s docket is mostly unregistered trading, fraud and disclosure failures; those are read and skipped. Second, the Canadian coverage is Ontario only. British Columbia, Alberta and Quebec are not collected, and CIRO, which handles order-book conduct on Canadian marketplaces, cannot be reached by an automated client. FINRA is excluded for a different reason: its robots.txt disallows the disciplinary database. Third, the ASIC and FCA records come from media releases and final notices, not from court judgments, so a court outcome appears only if a release reports it. Fourth, the AMF records are the committee’s own decisions, which are administrative: an appeal to the Paris Court of Appeal or a criminal prosecution of the same conduct is not part of the record unless the decision mentions it. Older decisions are anonymised by the AMF (names appear as letters such as X or A), and the records keep those names as published; 154 of the 209 AMF records have a defendant recorded that way by a simple pattern check. This AMF is the French regulator, not the Québec body of the same initials, which is not collected. The sources page and the project’s decision log state each of these in more detail.

The SEC’s litigation releases begin in 2015 and its administrative orders in 2013, so the SEC’s early years are thinner, and 149 SEC records date from 2013 or 2014 against 1,701 from 2015 on. The CFTC, OSC and FCA start in 2013, ASIC in 2014 and the AMF in 2004 (107 of its 209 records are from before 2014 and 101 from 2014 to 2025). Excluding the part-year 2026, ASIC has 5 to 13 records a year, the OSC up to 10 (none in 2024), the FCA 1 to 9 and the AMF 3 to 17, so none of this should be read as a trend.

What each agency’s records show

Technique mix. The SEC records are dominated by insider trading (534 records, 29%) and Ponzi schemes (337, 18%), followed by unregistered distributions (157, 8%) and pump and dump (112, 6%). The CFTC’s are different: Ponzi schemes (109, 32%), spoofing (74, 22%) and price manipulation (55, 16%) lead, so 44% of CFTC records fall in the order-book family against 5% for the SEC. ASIC is led by insider trading (55, 49%) and price manipulation (36, 32%). The OSC is split between insider trading (18, 26%) and Ponzi schemes (17, 25%). The AMF is the most concentrated on insider dealing: 119 of its 209 records (57%), then price manipulation (23, 11%), with marking the close and layering 9 each (4%). It has no Ponzi scheme records, and 14 (7%) carry spoofing or layering. The FCA is the benchmark and FX agency: 22 of its 48 records (46%) carry benchmark submission rigging or FX fixing, none of which appears in ASIC, OSC, AMF or SEC records, and the CFTC has 18 (5%). Records with no technique tag: 15% at the SEC (277), 15% at the CFTC (51), 5% at ASIC (6), 15% at the FCA (7) 33% (23 of 69) at the OSC, the largest share of any agency, and 17% (35) at the AMF.

Technique tags are this library’s, not the regulators’, and some are judgement calls (the audit post lists them). The mix differs between agencies partly because the agencies oversee different markets (the CFTC derivatives, the SEC securities) and partly because of what each source publishes; the data cannot say how much of each.

Outcome. The recorded status reflects what each regulator’s release reports, and the SEC and CFTC use their documents differently from the others. 157 SEC records (8%) and 30 CFTC records (9%) are still recorded as filed, meaning the library has not tracked an outcome; 15 SEC and 4 CFTC records of unknown outcome are separate. ASIC has 3 filed records. The FCA publishes final notices, which are decisions, so none of its records is “filed”, and the OSC and AMF have none either. For the AMF, 167 of 209 records (80%) are sanctions decisions, 24 (11%) homologated settlements and 18 (9%) dismissals. ASIC’s media releases often announce a charge and, later, a sentence; 87 of its 96 judgment records carry the criminal flag. Its 7 settled records are too few to compare.

Money. Restricting to resolved records (settled or judgment), 60% of the SEC’s have a penalty stored (1,000 of 1,664), 80% of the CFTC’s (244 of 304), 34% of ASIC’s (35 of 103), 48% of the OSC’s (31 of 64) 67% of the FCA’s (28 of 42) and 99% of the AMF’s (189 of 191). The project’s ingest notes record that CFTC headlines routinely name the money, which may help explain the CFTC’s high rate. 60 ASIC records, 53%, carry a prison sentence length, and 40 of them report no civil figure, which may help explain the low ASIC rate. The SEC resolves most matters with a combination of penalty, disgorgement and interest, and 53% of SEC records have a disgorgement figure, against 20% of the CFTC’s. The AMF’s two judgment records with no stored fine are the exception to a pattern in which a sanctions decision nearly always states one.

Bans. The barsImposed field holds each regulator’s own vocabulary: SEC officer-and-director, penny stock and industry bars, CFTC and OSC trading bans, FCA prohibition orders and ASIC bans from financial services. A “ban” is therefore a different restriction at each agency, and the shares are not like for like. Excluding 65 SEC records and 4 CFTC records whose only entry is a conduct-based injunction (not a bar from an activity), the SEC rate is 28% and the CFTC’s 28%. The OSC’s 25 records with a ban (36%) are the highest share, and the FCA’s 3 and ASIC’s 10 are too few to say more than that bans are uncommon in the records of those two. The AMF’s 4 (2%) are professional bans on individuals, one for 2 months and two for 10 years, and one permanent ban on an adviser.

Criminal case alongside. A criminal parallel is recorded for 583 SEC records (31%), 109 CFTC (32%), 13 OSC (19%), 8 FCA (17%) and 6 AMF (3%). The AMF’s 6 (3%) are the lowest: its records are administrative decisions, and a criminal case running alongside appears only where a decision mentions one. ASIC stands apart at 92 of 113 (81%), and the flag may not mean the same thing there. For the SEC and CFTC it usually marks a Justice Department prosecution of the same conduct, announced alongside a civil action. In ASIC’s records, 91 of the 92 flagged records describe a criminal charge, plea, conviction or sentence in their summaries (a keyword check, not a reading of each), and 60 carry a prison sentence length, so the flag marks that the record concerns a criminal case, and not necessarily a second action running beside a civil one. Four unflagged ASIC records also use criminal vocabulary, which I have not checked individually. The ASIC share therefore says something about what ASIC’s releases announce, and cannot be set against the SEC’s as a measure of how often the two agencies pursue conduct criminally. The 4 October corrections raised ASIC’s share (from 72% to 81%) rather than lowering it, so the earlier explanation still stands.

Penalty size, in each currency

Every row below is in its own currency. Do not read across a row.

Within the US dollar, the CFTC median is about nine times the SEC’s (US$1.5 million to US$173,436, a ratio of 8.6), and the CFTC’s smallest stored penalty is US$17,500 where the SEC’s is US$1,000. The two agencies’ records also differ in who they are about: 65% of CFTC records name at least one entity, against 37% of the SEC’s. Restricted to records naming only individuals, the medians are US$113,444 for the SEC (573 records) and US$350,000 for the CFTC (66); where an entity is named, US$375,000 (432) and US$2,134,083 (176). The same pattern holds in each other regime where the group is large enough: OSC records naming only individuals have a median of C$76,663 (20) against C$650,000 where an entity is named (12). ASIC splits the same way (A$42,840 for 25 records and A$832,500 for 9), but the second group is below 10 records and should not be treated as a comparison. The AMF shows the same split: 70 individual-only records have a median of €180,000 against €545,000 for the 119 that name an entity. The comparison within each agency is between kinds of respondent. It is not between regulators.

The FCA is two populations. Of its 30 penalty records, 12 name an entity, with a median of £216,681,500 and a minimum of £630,000; all 12 were filed in 2013 to 2015, and most are the benchmark-rigging and FX cases against banks, with a broker and one layering firm. The 18 naming only individuals have a median of £97,800. The £279,922 overall median falls in the gap between the two and is representative of neither. The 75th percentile of £100,625,000 shows it. With 30 records the figures are sensitive to a few cases.

Outliers. One record dominates each total, and the medians barely move when it is removed.

Totals are shown only to put the outlier in proportion; they are sums of records, not of regulators’ total penalties, and several records in each group are the same matter at different stages. The SEC total without Stanford is US$1.89 billion. Two ASIC records hold the A$5 million (the CBA matter at two stages), so the table’s removal leaves another A$5 million in the data, and the ASIC median barely moves. The CFTC’s largest record is a joint order against five banks, stored as a sum across the respondents.

Settled against judgment. Within the SEC, the median settled penalty is US$129,140 (687 records) and the judgment median is US$434,887 (313). Within the CFTC, US$1,000,000 for settled records (69) and US$1,600,000 for judgments (175). The OSC’s settled median is C$200,000 (21) against C$450,000 for judgments (10). The AMF’s homologated settlements have a median of €100,000 (24) against €420,000 for sanctions decisions (165); the settlements are a small group and may concern different conduct. The ASIC and FCA groups are too small to compare: ASIC has 6 settled and 29 judgment records with a penalty, the FCA 25 settled and 3 judgment. Restricting to matters filed from 2014 to 2025, which is the span all six agencies cover in full, leaves the medians unchanged for ASIC (A$65,000) and the OSC (C$267,500), and moves the SEC’s to US$177,139, the CFTC’s to US$1,542,916, the FCA’s to £250,000 and the AMF’s to €475,000 (94 records); the AMF’s 94 records with a fine from before 2014 have a median of €300,000, so its stored fines are larger in the later period.

What this does not show

It does not compare the regulators. These are the cases each regulator chose to bring and publish, passed through this library’s classifier and sources. A low count for an agency can mean the agency brings few such cases, or that the library collects it thinly. The FCA’s 48 records, for example, are final notices that survive a filter that skips most of the FCA’s docket, and the OSC’s are Ontario only. Which matters an agency pursues, and how it chooses to resolve them, shape what is published. The records cannot show how much manipulation each agency faces, how it chooses cases, or how severe its penalties are, and a larger penalty in a record does not mean a stricter regime.

It does not compare penalty sizes across currencies. The medians are in US dollars, Australian dollars, Canadian dollars, pounds and euros, over different years. The table does not support a statement that one regulator’s typical penalty is larger than another’s across currencies, and no exchange rate has been applied.

The data have gaps. 583 SEC records (31%), 83 CFTC (25%), 78 ASIC (69%), 37 OSC (54%), 17 FCA (35%) and 20 AMF (10%) carry no money field of any kind, and for ASIC 67 of those 78 are judgments and 3 are filed. A missing figure is not a zero penalty. 157 SEC and 30 CFTC records are still recorded as filed, so their outcome is not tracked, and some resolved records cover only some of their defendants. Multi-respondent records store the sum of the respondents’ amounts, which inflates what an agency’s “typical” record looks like. Ten ASIC amounts recur across two or three records (21 in all); in nine of the ten the same person is named on each, which fits one matter at charge and at sentence, and in one (A$810,000) two different people, which I did not investigate. At the AMF 105 records share a fine with at least one other (€100,000 on nine records, €300,000 on seven); round amounts recur across different matters, and some decisions store a sum across several respondents, so I did not treat these as duplicates and did not check them. Dates are mostly filing dates, and for the SEC many are the day an order was instituted and settled at once.

The native-currency fields. Checking every non-US record for money stored in the wrong field now finds one exception: the FCA’s Coscia record carries a US$903,176 penalty with no native amount, which is correct because the FCA’s notice states it in dollars, so it is the one FCA record outside the sterling distribution. It is not counted in the 30 above. No other ASIC, OSC, FCA or AMF record has a value in a USD field, no USD amount was found in a native field, and no SEC or CFTC record has a native amount. Separately, 44 resolved ASIC, FCA and OSC records (none at the AMF) have an amount in their summary and no stored figure; the count includes the Coscia record, and the pattern also matches losses or costs, so I did not check each; some may be missed penalties.

Checked by AI agents, not lawyers. All records were read against the regulators’ own documents on 2 and 3 October 2026 by Claude AI agents under written instructions, and no lawyer reviewed them. The AMF records, added later, were read in French by AI agents in the same way, so translation and the reading of French sanctions law are further places for error. The audit post sets out the method and its limits, and the corrections page logs what it changed. Where a record here described a matter that the regulator only alleged, the figure is the regulator’s claim, not a finding. Each record links to its primary document, and an error link on each case page goes to the maintainer. A record mentioned here is not a verdict on anyone.

An example of the difference in kind: the ASIC release about Westpac’s pre-hedging records a A$1.8 million penalty for unconscionable conduct, and the record carries no technique tag, while the FCA’s Coscia final notice records a layering finding in dollars. The records share a field name and not a meaning.

Techniques referenced

• Insider trading — Insider trading is dealing in securities on material non-public information in breach of a duty of trust or confidence, which exploits a true signal others cannot see rather than injecting a false one into the price.
• Ponzi schemes — A Ponzi scheme pays returns to earlier investors from later investors' money rather than from genuine profits, which is investment fraud with no market involvement and no price to manipulate.
• Price manipulation — Price manipulation is trading intended to create an artificial price — one that does not reflect genuine supply and demand — and it is the general charge a regulator brings when the conduct does not fit a more specific named technique.
• Spoofing — Spoofing is placing orders a trader intends to cancel before execution, to create a false impression of supply or demand and move the price toward a smaller genuine order on the other side.
• Benchmark submission rigging — Benchmark submission rigging is skewing the figures a panel member reports into a reference rate calculation, so that the published benchmark moves in favour of positions that settle against it.

Cases referenced

Reviewed October 5, 2026. Spotted an error? Tell us.