What sanctions the records show
Where a penalty is recorded (1,250 of 2,428 records) the median is $250,000, but ten records hold 69% of the penalty dollars and Stanford alone 35%. The median recorded sentence is 36 months (285 records). 33% of records show no money at all. Settled records carry smaller penalties than judgments; that is an association in this selection, not an effect of settling.
Where a civil penalty is recorded, the middle record carries about $250,000, and the middle half of penalties run from $75,000 to $1.2 million (1,250 records). That figure describes almost nobody who pays the large numbers. Ten records, under one percent of those with a penalty, hold 69% of every penalty dollar in the library, and the single largest, the Stanford Ponzi judgment, holds 35%. Half of the records with a penalty share 0.3% of the dollars between them. About two thirds of the 2,428 records (1,630, 67%) carry some recorded money, 33% show none, and the sentence field is filled for only 285 records, with a median of 36 months.
This post sets out what the records say about sanctions, how little of it a single average can carry, and how much of any comparison between regulators, outcomes or respondents is explained by what each record happens to contain. It reports associations in this selection. It does not say that settling, cooperating, having a parallel criminal case or being a company causes any sanction to be smaller or larger.
The finding in five numbers
- Penalty, middle record: $250,000, with a middle half of $75,000 to $1.2 million (1,250 records with a US dollar penalty). Over a quarter (351, 28%) are $1 million or more and 29% (362) are under $100,000.
- Disgorgement, middle record: $354,000, middle half $66,000 to $1.9 million (1,052 records).
- Concentration: the largest 10 penalties are 69% of penalty dollars; with Stanford removed, the largest 10 of the remaining records are 56%, and the largest 10% are still 93%.
- Prison, middle record: 36 months, middle half 18 to 84 months (285 records with a sentence recorded, all of them among the 805 records with a criminal parallel).
- Nothing recorded: 798 records (33%) carry no penalty, disgorgement, interest or foreign-currency penalty. Of these 188 are records still recorded only as “filed”.
How this was measured
Every figure comes from one script, scripts/analysis/sanctions.mjs, which reads the 2,428 case files and prints
every number below. Five conventions matter.
As of 4 October 2026, after the status and flag corrections. This post was first written on the same day, before 543 of the 733 records then recorded as “filed” were researched and updated; 190 remain “filed”. The 543 mostly gained a status (settled or judgment), a resolution date and money fields, so the count of records with a penalty rose from 1,008 to 1,250 and the count with no money fell from 1,157 to 798. Statuses are now 1,192 settled, 985 judgment, 190 filed, 29 unknown, 25 dismissed and 7 appealed. The criminal-parallel flag was corrected on 128 records (113 set to false because the release states no criminal case, 15 set to true), then set to true on the records that carry a sentence and on others, leaving 805 flagged against 834 earlier (the Stanford record is now flagged too). Other corrections that touch this post: five CFTC benchmark orders, the five-bank 2014 order, the 2020 JPMorgan order, Lloyds and RP Martin moved from judgment to settled; the five-bank penalty was corrected to $1.475 billion; five ASIC records that held Australian-dollar amounts in US dollar fields were corrected; the money on the duplicate Fujinaga 2017, Bank of Nova Scotia 8221-20, Cartu 2020, Aequitas 2016, Agridime 2023, Tyche, Digitex 2022, Lek, Yin, Capital Financial, Illarramendi, Marquis, Churchville (two) and Apostelos records was removed; and the Sparkster and Woodward amounts were fixed. What moved in this post: the median penalty rose from $204,000 to $250,000, the top-10 concentration fell from 75% to 69%, the gap between settled and judgment penalties narrowed (to between 1.6 and 3.9 times), and the criminal-parallel comparison no longer reverses in the last row. Outcomes recorded for the 543 often cover only some of the defendants, so “settled” and “judgment” labels are per record, not per respondent.
Medians and quartiles, not means. Sanction amounts are so skewed that a mean would be a statement about Stanford, not about the records. “Middle half” means the first and third quartiles; “IQR” is the same range.
Per record is per matter, not per person. A record stores the sum of what every respondent owes. 1,036 records (43%) name two or more respondents, so a $2 million penalty may be one person or eight. The same applies to the sentence field: where a release reports several sentences, the field holds one figure. In the three records I opened to check (Simmons, Merrill and Kita) it is the longest term in the release, not a total. Where it matters I repeat a comparison using only the 1,383 single-respondent records.
What counts as money. Penalties and disgorgement are in US dollars. Penalties from Canadian, Australian and British regulators are held in their own currency and are deliberately not converted, so they are in no figure here. That leaves the ASIC, FCA and OSC with one US dollar penalty among 230 records (a 2013 FCA record). “No money at all” means no US dollar penalty, disgorgement or interest and no native-currency penalty; 97 records (35 ASIC, 30 FCA, 32 OSC) with only a foreign-currency penalty are not counted as empty.
The “status” is a label, not a trial. The 985 “judgment” records are court judgments of any kind. In 263 of them the summary mentions a consent or settlement, and in 129 a default. So “settled” against “judgment” is not the same as “settled” against “litigated”, and the 190 records still recorded as “filed” have no tracked outcome.
Cross-checks. The Stanford penalty of $5,905,000,000 is the sum of $5.9 billion on Robert Allen Stanford and $5 million on James Davis in the SEC release; the same release gives disgorgement and interest only as combined figures in the billions, deemed satisfied by forfeiture, so the record carries no disgorgement for it. The Glencore penalty ($865.6 million) and disgorgement ($320.7 million), the Battoo penalty ($147 million) and the Cartu penalty ($153.5 million) matched their CFTC releases when I first read them. The last two are recorded as default judgments, which is a reminder that a large number on paper is not a large number collected.
After the refresh I checked the other top-ten penalty records against their record narratives (not the original releases, which I did not re-open). The five-bank record’s $1.475 billion equals the five penalties its summary lists ($310 million twice, $290 million twice, $275 million). JPMorgan ($436.4 million) is the penalty part of a $920.2 million total that also includes restitution the library has no field for. International Enterprise ($338.8 million) is a January 2025 default judgment, joint and several, against eight defendants, and the Control-Finance record ($429 million) is a 2021 default judgment against one individual in a case about roughly $147 million of bitcoin. Large figures in this top ten are therefore partly default judgments, not collected money. These records match what their own summaries say; I did not find a mismatch. The Quan record’s $80.6 million of disgorgement is the Minnesota court’s award restated in the SEC proceeding, which its narrative now says.
Matters that appear twice. The refresh removed the money from 15 records that restated another record’s figures: Fujinaga 2017, Bank of Nova Scotia 8221-20, Cartu 2020, Aequitas 2016, Agridime 2023, and then Tyche, Digitex 2022, Lek, Yin, Capital Financial, Illarramendi, Marquis, Churchville (two) and Apostelos (Fujinaga 2015 and 2017; Bank of Nova Scotia one and two; Cartu 2020; Aequitas 2016 and 2020; Agridime 2025 and 2023). The ten latest of these were identified from the records’ narratives and the matching amounts, not by re-reading every release, and I rely on that. The script no longer finds any pair of records of one agency that share an identical amount of $10 million or more and a respondent name, so no sensitivity run is needed: the median penalty is $250,000, total penalties $16.7 billion and total disgorgement $5.2 billion with the duplicates already gone. I have not edited any record myself.
What it shows
A few records are the money
Of $16.7 billion in recorded penalties, ten records are $11.6 billion. Nine of the ten are CFTC records: the five-bank 2014 foreign-exchange benchmark orders ($1.475 billion, one record summing five respondents), the Glencore price-manipulation order, Deutsche Bank ($800 million), Rabobank and Société Générale ($475 million each), JPMorgan, the Control-Finance default judgment ($429 million), Barclays ($400 million) and the binary-options default judgment. The tenth is Stanford. Strip out Stanford and the total falls to $10.8 billion, 35% lower, while the median penalty stays at $250,000. Strip out the ten largest and the remaining 1,240 records total $5.1 billion with a median of $248,000 and a middle half of $75,000 to $1.1 million. In other words the median is stable, and everything that grows or shrinks with outliers is the total.
The same shape holds for disgorgement: the largest 10 of 1,052 records are 43% of $5.2 billion, and the largest 105 (10%) are 83%. Counting penalty, disgorgement and interest together over 1,533 records with any dollar figure, the largest 10 hold 56% of $22.5 billion.
Who the large amounts belong to depends on the outlier. Before removing Stanford the SEC’s penalties ($7.8 billion over 1,005 records) and the CFTC’s ($8.9 billion over 244) look similar. After removing Stanford, the SEC is $1.9 billion and the CFTC 82% of recorded penalty dollars. The CFTC dollars are themselves concentrated, with its largest ten records 68% of its total.
Typical amounts differ by regulator, technique and family
| Regulator | Records | With a US$ penalty | Median penalty | Middle half | No money at all |
|---|---|---|---|---|---|
| SEC | 1,860 | 1,005 | $173,000 | $64,000 to $750,000 | 31% |
| CFTC | 338 | 244 | $1.5 million | $350,000 to $7.8 million | 25% |
| ASIC, FCA, OSC | 230 | 1 | too few to compare | n/a | 57% |
The CFTC median is more than eight times the SEC’s. That says something about what each agency publishes: the CFTC records here are dominated by firm-level manipulation and benchmark orders, the SEC records by individuals. It does not say the CFTC penalises the same conduct harder, because the conduct is not the same. The ASIC, FCA and OSC have too few US dollar penalties to compare; their sanctions are in other currencies and are not on this page.
By technique the median runs from $88,000 for paid stock promotion to $12.4 million for price manipulation, a 141-fold spread; insider trading, the largest group, is $89,000. The two ends are different populations: insider trading records are mostly one person’s trades; the price-manipulation records are firms. A technique tag is the library’s own classification and a record can carry several, so these groups overlap. Spoofing is a case in point: the 71 records with a spoofing penalty have a middle of $700,000 and a middle half from $275,000 to $2.0 million. Benchmark-submission rigging, not in the chart because only 18 records carry a penalty, has a median of $110 million, the highest of any technique; its upper quartile is $381 million. Counted by the broader families, the median penalty is $750,000 for the order-book family (175 records), $230,000 for information (141), $150,000 for issuer and structural (138) and $195,000 for related-but-distinct (554, mostly insider trading and Ponzi). The “benchmark and cross-market” family ($208,000, 108 records) mixes benchmark rigging with the 79 Rule 105 records, so its median describes neither. The 364 records with no technique tag have a median of $470,000, higher than most tagged groups, and 85 of the 195 with a penalty name only entities; the audit left untagged the records whose document did not support a technique, so this group is a mixed remainder.
Where the money is missing
Of all 2,428 records, 798 (33%) show no money. Nearly a quarter of that (188, 24%) is the status. For those filed records the library records the filing and does not follow the outcome, so the empty field means “not tracked”, not “no sanction”. Of the 2,238 records that are not “filed”, 610 (27%) still have none. Among 985 judgments, 316 do (32%), as do 242 of 1,192 settled records (20%). The three records I opened that had a prison sentence and a civil judgment (Gupta, Kita and McClatchey) show why: disgorgement ordered but deemed satisfied by criminal forfeiture, with no civil penalty on top. A sanction can exist and not be a number the record carries.
Settled and judgment
| Group | Settled: records with a penalty, median | Judgment: records with a penalty, median |
|---|---|---|
| SEC | 687, $129,000 | 313, $435,000 |
| SEC, one respondent only | 484, $100,000 | 113, $214,000 |
| SEC insider trading | 263, $67,000 | 73, $251,000 |
| SEC Ponzi | 37, $200,000 | 65, $780,000 |
| CFTC | 69, $1.0 million | 175, $1.6 million |
In every row the median penalty is smaller in records recorded as settled than in records recorded as judgment, by roughly 1.6 to 3.9 times (the CFTC gap is the narrowest). Across all records the settled median is $150,000 and the judgment median $657,000. Judgment records also carry more disgorgement (SEC median $730,000 against $189,000) and more bars (39% against 27% in the SEC records). Both groups still have wide overlaps: the middle half of SEC settled penalties ($50,000 to $425,000) and judgment penalties ($150,000 to $1.5 million) overlap across much of their range.
What this supports is an association in this selection: the records labelled judgment are, on average, the bigger matters. What it does not support is that settling lowers a penalty. A judgment record, as noted above, is often a consent or default judgment; the cases that are litigated to judgment are more likely to be the larger and the more contested ones before a penalty is set; 318 of the 631 SEC judgment records show no penalty, which cannot be told apart from “not recorded” (and many of those were updated only on 4 October, with outcomes for some defendants). The data cannot say what the same respondent would have paid on the other route.
Entities and individuals
| Respondents named | Records | With a penalty | Median penalty | Middle half | No money at all | Any bar or injunction |
|---|---|---|---|---|---|---|
| Individuals only | 1,455 | 640 | $138,000 | $46,000 to $404,000 | 37% | 33% |
| Entities only | 390 | 299 | $500,000 | $136,000 to $4.4 million | 15% | 5% |
| Entities and individuals | 574 | 309 | $945,000 | $193,000 to $3.6 million | 33% | 37% |
Nine records list no respondent type and are not in the table. Restricting to records with a single respondent, so the figure is per respondent, an entity’s median penalty is $400,000 (267 records, middle half $125,000 to $2.5 million) and an individual’s is $100,000 (449 records, $36,000 to $298,000). Entity records are far more likely to show money (86% of single-entity records against 62% of single-individual records) and almost never record a bar: 19 of 390 entity-only records. Individuals, not entities, receive prison sentences. None of the 390 entity-only records has a sentence recorded.
Prison
Only the criminal court sets a prison term, and the records carry it only when the regulator’s document mentions it. Of the 805 records with a parallel criminal matter, 285 (35%) carry a sentence, and 197 of those 285 are records recorded as judgment; the field is empty for most criminal parallels, which means “not stated”, not “no prison”. Across the 285 records with a sentence the median is 36 months, the middle half 18 to 84 months. A little over a third (107, 38%) are 24 months or less, 38% (108) are over five years, and 16% (47) are over ten.
| Group | Records with a sentence | Median months | Middle half |
|---|---|---|---|
| All | 285 | 36 | 18 to 84 |
| SEC | 179 | 42 | 18 to 86 |
| CFTC | 41 | 66 | 37 to 120 |
| ASIC | 60 | 19.5 | 15 to 34 |
| Ponzi schemes | 104 | 84 | 45 to 156 |
| Insider trading | 86 | 18 | 8 to 27 |
| Price manipulation | 21 | 21 | 15 to 24 |
| Pump and dump | 18 | 45 | 21 to 66 |
| Boiler rooms | 10 | 91.5 | 32 to 119 |
The FCA (3 records) and OSC (2) are too few to compare, and so is any other technique below ten. The range runs from two months (Gupta, an insider-trading plea) to 480 months in Simmons, a forex Ponzi-style scheme with five respondents, where the release gives Simmons 40 years and a co-defendant 4.5. The gap between Ponzi and insider-trading records is large, but the records do not carry the criminal charge or the size of the fraud, so the data cannot say why. The record for Merrill shows 264 months, the 22 years given to one of three people; the person the release is about, a co-defendant sentenced to two years, is not what the field holds. The two records I suspected of a wrong flag, Bekkedam and CR Intrinsic, are now flagged as having a criminal parallel, and every record with a sentence now carries the flag.
Criminal parallel or not
805 records (33%) are flagged as having a parallel criminal matter. The two groups differ in what the civil record shows.
| Recorded status | Criminal parallel: with a penalty, median | No criminal parallel: with a penalty, median |
|---|---|---|
| All records | 173, $584,000 | 1,077, $230,000 |
| Settled | 66, $200,000 | 691, $150,000 |
| Judgment | 107, $1.15 million | 381, $539,000 |
| SEC judgment | 68, $478,000 | 245, $414,000 |
Before the flag corrections the last row reversed the pooled gap; it no longer does. The criminal-parallel penalty is larger in every row, by 2.5 times pooled and 1.1 to 2.1 times within a status, and the SEC judgment gap is so small, with overlapping middle halves ($150,000 to $1.5 million against $130,000 to $1.5 million), that I would not call it a difference. The pooled number partly reflects which kinds of record sit in each group: 23% of the CFTC’s penalty records (56 of 244) are flagged against 12% of the SEC’s (117 of 1,005), 49% of Ponzi-tagged records are flagged (231 of 474), and the CFTC’s flagged penalties have a median of $5.9 million against $1.0 million for its unflagged. Stanford’s record is now itself flagged, which lifts the flagged SEC total but barely moves any median. Treat the size of the gap as unstable.
A steadier pattern is the missing money. Only 173 of the 805 flagged records (21%) carry a penalty, against 1,077 of 1,623 (66%) without. Of the 2,177 records recorded as settled or judgment, 319 of the 713 with a criminal parallel (45%) show no money, against 239 of the 1,464 without (16%). The three records I read (Gupta, Kita, McClatchey) say why in those cases: the civil disgorgement was deemed satisfied by criminal forfeiture and no civil penalty was set. Whether that explains the whole 28-point gap I cannot say from the data.
Bars
714 records (29%) list at least one bar or injunction, and 645 list a bar of some kind, mostly of the kinds the SEC uses: a penny stock bar (244 records), an officer-and-director bar (226), a registration bar (158) or a trading ban (116); 149 list a conduct-based injunction, and 69 of those list nothing else. A record can list several. The share varies by family: 51% of information records (152 of 299) and 45% of issuer-and-structural records (120 of 265), against 28% for the order book and 1% for benchmark and cross-market. By respondent, 33% of records naming individuals only (480 of 1,455) list one, against 5% of entity-only records (19 of 390). By agency 31% of SEC records list a bar, 29% of the CFTC’s, 36% of the OSC’s (25 of 69), 6% of the FCA’s (3 of 48) and 9% of ASIC’s (10 of 113). Among SEC records, 39% of judgments list one against 27% of settlements. The field is free text taken from the release; a bar that a release does not mention is missing, and the regulators’ own remedies differ, so cross-agency comparisons say as much about what each publishes as what each imposes.
Penalty against gain, a small sample
Only 267 records carry an alleged gain, and 145 of those also carry a penalty (141 SEC, 4 CFTC). That is a small sample drawn almost entirely from one regulator, and it should not be read as a market-wide pattern. In it the median penalty is 1.0 times the alleged gain, the middle half runs from 0.50 to 1.5 times, 57 records (39%) are below 1 and 10 above 3. The highest ratio, 10, is the International Capital Group reverse-merger settlement, whose order was not in the cache and which I could not check; the lowest, 0.003, is Tobin, which sets a $165 million alleged gain against penalties of $460,928, so the gain is a scheme-wide figure and not the respondent’s. The Woodward gain, previously misread, now equals its $21,326 penalty.
Two warnings make the ratio weaker still. First, in 75 of the 159 records that carry both a gain and a disgorgement figure the two are within one percent of each other, so the “gain” field often restates the disgorgement. Where the two differ or there is no disgorgement (82 records with a penalty) the median is still 1.0 (middle half 0.27 to 1.6). Second, a scheme-wide gain set against one respondent’s penalty is not a ratio: the Bauer record sets a $145 million scheme against $1 million of penalty across the defendants, and Roda sets one respondent’s $560,762 profit against the other’s $5,602 penalty. A larger sample is the penalty against disgorgement, 771 records with both: the median is 1.0, the middle half 0.5 to 1.5, 205 (27%) within one percent of 1.0, 313 below and 253 above, 86 (11%) more than three times. Insider-trading records hold the sharpest pattern, 148 of 260 (57%) at about one times disgorgement; Ponzi records sit well below, with a median of 0.5 (108 records); CFTC records median 2.1 (56 records). These are what the records show, not what any rule requires.
What this does not show
It does not show what regulators sanction in general. These are the matters that regulators chose to bring and publish, and that this library ingested and read. Many are the large, the clear or the settled. Cases not published, not brought or not pursued are not here, so a median penalty here is a median of selected matters.
It does not show what settling does. The settled-judgment gap is large and holds across the cuts I tried, but a judgment record includes consent and default judgments, a matter that goes to judgment differs from one that settles in ways the records do not capture, and nobody observes what the same respondent would have paid by the other route. That the two groups differ is a fact about these records. Why is not something these records can answer.
Money that is missing is not money that was not ordered. 33% of records show no money; about a quarter of those are records still tracked only as “filed”. Disgorgement deemed satisfied by a criminal forfeiture, as in Stanford (where the disgorgement figure is missing and the penalty is the only dollar amount), does not show as money. Collected amounts are not in the data at all: an ordered penalty against a defendant in default, like Battoo, Cartu or Control-Finance, is a judgment, not a payment. The 543 records updated on 4 October often report outcomes for only some of their defendants, so a status or amount may describe part of a matter.
Other currencies are missing. Of the ASIC, FCA and OSC records, 97 have a penalty only in Australian, British or Canadian dollars or pounds and are excluded from every dollar figure, so regulators outside the US are all but absent from the penalty comparisons. Their sentence figures are in months and are included (65 records, mostly ASIC).
Per record, not per person. 1,036 records sum several respondents’ amounts, a sentence figure is the longest term in the release, and a matter can appear in more than one record (the duplicates found so far are nulled, others may remain undetected). The 2,428 records are not 2,428 independent matters and not 2,428 respondents.
The tags and the fields were read by AI agents, not lawyers. Every record was compared with its primary document on 2 and 3 October 2026 by Claude agents following written instructions, with samples and disputed records re-read, and no lawyer reviewed it (see what reading every record found); the 543 updated records were researched on 4 October the same way. The figures in this post were checked by recomputing them a second way and by reading the record narratives for the largest values; several orders in the cache, mostly SEC administrative PDFs, were not available, so the figures that rest on them are unverified. If you find a figure that is wrong, use the error link on the record’s page and it will be logged on the corrections page.