Who appears more than once

Of 4,199 names in the six older regulators' defendant lists, 662 appear in two or more records, 123 in two or more matters and 44 in separate episodes after a hand check: 31 firms, 13 individuals. SEBI (India) adds 2,979 names; by a rule on the listed company, not a hand check, at least 177 recur. A repeat name is not evidence of repeat misconduct.

Published 2026-10-04 · 9 min read

Most names in the library appear once. The library’s 3,273 case records come from seven regulators, and this post treats them in two parts because they were checked differently. For the 2,617 records of the six older regulators, 4,199 distinct names appear in the defendant lists, and 662 appear in two or more records, 123 in two or more matters, and 44 in two or more separate enforcement episodes. The gap between the first two numbers and the third is the point of this post: most repeats are one case recorded more than once, at its filing and again at its judgment, or the same conduct pursued by two regulators. The 44 that remain are 31 firms and 13 individuals, and 23 of the firms are banks, securities firms, stock exchanges or a transfer agent. The 656 records of the seventh regulator, SEBI (India), name 2,979 distinct people and companies; 317 appear in two or more SEBI orders, and at least 177 are named in orders on two or more different listed companies. That SEBI count comes from a rule on the company named in each order, not from a hand reading of every name, and is set out in its own section below.

What a repeat appearance is, and is not

It is the same name in different records. Nothing more. It is not a count of offences, and it is not evidence of recidivism. The records behind these counts include a settled order against a bank’s securities arm, a complaint that has not been decided, and a tribunal case in which none of the allegations were found proven. One name is a respondent in one record and appears again as a respondent in another; the library cannot tell from that how much conduct there was, whether it was related, or whether anyone at the firm was the same person. A large bank that trades in dozens of markets can appear in four unrelated orders. A small firm can appear in two because a regulator brought an order and then, years later, a follow-up. Both are repeats in the count.

How the names were counted

The analysis reads the defendants field of every case record: 8,920 entries, of which 485 are excluded as anonymised placeholders (below). The 5,484 entries of the six older regulators give 1,414 distinct entity names and 2,785 distinct individual names (4,199 in all) after normalising, and the 3,436 entries of the SEBI records give 925 entity names and 2,054 individual names (2,979 in all); no name appears under both groups. A name is lowercased, accents and punctuation are removed, “et al.” and a leading “the” are dropped, and trailing legal-form words (Inc, LLC, Ltd, plc, N.A., and the French SA, SAS and SARL, and similar) are taken off. The legal form stays part of the identity, so “Canaccord Genuity Inc.” and “Canaccord Genuity LLC” are different names, and a name with no suffix does not merge with a suffixed one unless a person has checked. One such merge was checked and made: “JPMorgan Chase Bank” and “JPMorgan Chase Bank, N.A.” in releases that name the national bank. For SEBI the Indian forms “Pvt”, “Pvt.” and “Private” are treated as the same legal form as “Ltd” and “Limited”, so “Pasha Finance Pvt. Ltd.” and “Pasha Finance Private Limited” are one name; SEBI orders spell personal names inconsistently (Agarwal and Agrawal, a middle name present or missing), and those variants are not merged, so SEBI repeats are, if anything, under-counted by spelling.

Anonymised respondents are excluded. Many decisions of the AMF (the French markets authority), mostly before about 2017, publish respondents only as placeholders such as “X”, “Y”, “A”, “U and V”, “Company X” or “M. A”, which mean a different person in every decision. 485 defendant entries (46 distinct strings, all in AMF records) are of this kind. They are never matched across records and take no part in any count here, so repeat appearances among those respondents cannot be seen; named AMF respondents, mostly companies, are matched like any other name. The same rule wrongly flagged one SEBI company, “M.T. Corporation”, whose key becomes two letters once the legal form is stripped; it was exempted by hand, and SEBI otherwise has no anonymised respondents.

Names were then counted at three levels.

Records. A name in two or more case records.

Matters. A name in two or more matters, using the library’s own grouping rule from src/lib/matters.ts, which links records of one scheme (a filing release, a settlement, a judgment, sometimes from different agencies) on strong evidence only. The script copies the rule unchanged. It gives 2,872 matters for 3,273 records: 2,242 for the 2,617 older-regulator records and 630 for the 656 SEBI records.

Episodes. The matter rule misses many pairs, so every one of the 123 names in two or more matters from the six older regulators was read by hand: the records, the release numbers, and for the doubtful ones the cached regulator document. Where the records are a filing and its judgment, a follow-on proceeding, or parallel orders from two regulators on the same conduct, the name was counted as one episode. Where they show a different order, scheme, period or court, it was counted as two or more. The calls are listed, with a note for each, in scripts/analysis/repeat-actors.verified.json, and the script reads that file, so the numbers can be re-run.

Two kinds of name check were also made by hand. 27 groups of spellings were confirmed as one person or firm by reading the records (a middle name in one record and not another, a nickname, a legal form given in one record and not another). 20 pairs that look alike were deliberately left apart, for example the same name with a different legal form, a common name with no link between the records, and “Marc Judah Bistricer” in an Ontario case and “Marc Bistricer” in an SEC order, which may be the same person but could not be confirmed from the cached tribunal page.

As of 2026-10-07, re-run for the SEBI additions of 9 October. The figures are from a re-run on 3,273 records after four rounds of changes. First, the status and flag corrections of 2026-10-04: 543 of the 733 records that had status “filed” were resolved, and name fixes were made (the “Royal Bank” record now names Royal Bank of Canada, “Standard Registrar and Transfer Co., Inc.” is one name, and three names that began with “and” were cleaned). The new narratives and timeline events let the library’s matter rule join more records. Second, on 2026-10-05, 209 records from the AMF (France) were added; the three added episode names were HSBC France, Natixis and 3Red Trading LLC, each an AMF decision alongside a record on different conduct (3Red Trading was sanctioned by the AMF for orders in a French index future and by the CFTC for spoofing in US futures, so the two are counted as separate episodes). Third, on 2026-10-07, 21 records that were not enforcement matters were deleted (16 SEC subpoena-enforcement applications, 3 CFTC umbrella announcements, a CFTC notice and an Ontario motion). That removed two individuals from the hand-checked count of separate episodes, which fell from 46 to 44: each had been counted in a subpoena-enforcement action and again in a later complaint, with nothing in the records linking the two. It also removed the CFTC’s January 2018 announcement of spoofing actions from the records of three banks, which did not change any bank’s episode count. Fourth, 489 SEBI records were added on 2026-10-07 and 167 more on 2026-10-09 (656 in all, the later ones read under a wider scope that includes issuer fraud and broker fraud with fraud-regulation findings); they are analysed separately, and the older-regulator figures did not move. Records the status pass flagged as duplicates of one matter (for example two records of one SEC complaint and its judgment) were checked: each falls in one episode, so duplicates raise the record count and cannot create a repeat.

What it shows

Most repeats are one case

Of the 123 names in two or more matters from the six older regulators, 79 are in one episode. Agridime is the plainest example. The firm and its two co-founders appear in four records: a CFTC complaint (May 2024) and consent order (June 2025), and an SEC complaint (December 2023) and judgments (September 2025). The matter rule now joins all four into one matter, which fits what the records describe as one cattle-investment scheme; before the records were updated on 2026-10-04 it counted them as four. A different shape is the follow-on proceeding, which the rule still misses. An SEC administrative decision of 2019 imposes an industry bar on a former salesperson on the strength of an injunction entered in a civil case that is already in the library, and cites it (the 2015 case, the 2019 decision). Both are the same name in two matters and one episode. Before the 7 October deletions the rule also erred the other way once, joining a subpoena-enforcement action and a later judgment in a separate case into one matter; that record has been deleted, so all 44 names in separate episodes are now also in two or more matters.

So 199 of the 2,242 older-regulator matters (9%) involve a name that appears in two or more matters, but that is mostly the same case seen twice. Counting only names in separate episodes, 87 of 2,242 matters (3.9%) and 98 of 2,617 records (3.7%) involve a repeat name. Firms account for 69 of those matters (3.1%) and individuals for 23 (1.0%); five matters have both. The 23 banks, securities firms, exchanges and the transfer agent appear in 53 matters (2.4%).

The names that come back are mostly banks and securities firms

Of the 44 names, 37 appear in two episodes, four in three and three in four. The three with four are JPMorgan Chase Bank, Citigroup Global Markets Inc. and Deutsche Bank Securities Inc. The firms with three or more:

These count each legal entity separately, as the records do. Banking groups hold several, and when the entities of one group are joined by name the totals rise: Citigroup and Citibank to seven episodes, JPMorgan and Deutsche Bank to six, Morgan Stanley to five. The records do not say which entities share a parent, so that grouping is the library’s own, built from names.

Two cautions on the table. First, one record can serve several names: the CFTC’s order record of November 2014 on foreign exchange benchmarks names five banks, and counts once for each. Second, the entries are not the same kind of event. Citigroup Global Markets is a respondent in four SEC and CFTC orders on, among other things, hedge-fund disclosures, surveillance gaps, failure to supervise spoofing traders and mismarking; JPMorgan Chase Bank’s four include a 2013 swaps-trading order and a 2020 order on precious metals and Treasuries. Each episode concerns different traders, products and years.

Different regulators, different conduct

Thirteen of the 44 names have their separate episodes opened by more than one regulator, and all thirteen are firms. Eleven have a record from a regulator outside the United States (the FCA, the Ontario Securities Commission or the French AMF): nine banks, a Canadian securities dealer and a US trading firm. In several of those, the non-US order and a US order are the same episode, as in the 2014 foreign exchange settlements, so the second regulator is not always a second episode. Among the 31 names with at least two episodes that carry a technique tag, 17 share no tag across their episodes: the library tags one episode as, say, spoofing and another as something else. 14 share at least one. Thirteen of the 44 have fewer than two tagged episodes, because some orders concern supervision or reporting failures to which the library applies no technique. The median gap between the first and last episode of a name is three years. The longest is 11, an individual.

Gatekeepers

The library’s records name few gatekeepers in the narrow sense, and fewer still twice.

• Transfer agents. Three, each in a settled SEC order (2014 and 2016, 2017, 2018). Only one, Empire Stock Transfer, appears more than once, in two separate orders: one on undisclosed control of the firm, one on unregistered distributions of four penny stocks. An officer of the firm, a vice president, is also a respondent in both.
• Audit firms. Five China-based firms, in one SEC administrative proceeding of 2014 about audit work papers. None repeats.
• Law firms. Three, in three unrelated records. None repeats as a firm. Two further law-firm records, both subpoena-enforcement actions (the record for one, against a large firm, said no violation was charged), were deleted on 7 October as non-matter records. See also the earlier post on reverse-merger gatekeepers.
• Banks and broker-dealers. These are where the repeats concentrate: 20 of the 44 names are banks or securities firms, and with two stock-exchange entities and the transfer agent they make 23.

Individuals

Thirteen individuals appear in separate episodes: nine in SEC cases, four in CFTC cases. Three are the owner, an officer or the principal of a firm that is itself on the list. One is the owner of a Houston introducing broker whose settled CFTC orders of 2019 and 2021 are separate; the second order describes conduct that continued after the first, and the respondents admitted its facts. Two pairs of individuals come together in the same records. The other six each have two or three proceedings on different conduct. This post names no individual, including among the SEBI names: most of the records describe allegations or settled orders, and a count does not need names.

Named in someone else’s record

Firms also come up in the text of records where they are not respondents. Twenty-five records name one of eleven large banking groups (Citigroup, JPMorgan, Deutsche Bank, UBS, Royal Bank of Scotland, Barclays, HSBC, Goldman Sachs, Morgan Stanley, Merrill Lynch and Bank of America, BNP Paribas) in their text without naming any of its entities as a defendant. Fifteen are actions against people described as former employees of the bank, such as former traders sanctioned individually; two concern an insider-trading tip that traced to deal information at J.P. Morgan (a 2015 case and a 2026 case against one of its defendants); one is a firm’s order that mentions a bank’s traders; three are AMF decisions that mention a bank in passing (an employee of one, a credit line, a share traded); and four are SEBI orders: one names Morgan Stanley (France) SA as the counterparty to option trades for which SEBI penalised an Indian company, and three concern noticees said to have traded indirectly through UBS bank accounts. None of the twenty-five charges the bank. These are mentions, not respondent roles, and they are not in the counts above. (Before 7 October the list also held the CFTC’s January 2018 announcement of eight actions, which named three banks but no defendants; that record was deleted.)

SEBI (India): names that recur across orders

SEBI’s 656 records name 2,979 distinct people and companies (2,054 individuals and 925 entities) in 3,436 defendant entries, an average of 5.2 per record, because its orders are often made against a whole trading group. 317 names (11%) appear in two or more SEBI records (221 individuals, 96 entities), 289 of them in two or more matters under the library’s grouping rule, and the most any one name appears is 16 times. No SEBI name appears in a record of another regulator.

The hand check described above was not repeated for every one of these 317 names; that would have been another 317 judgments. Instead each name’s SEBI records were joined into one episode when they name the same listed company, and counted as separate episodes when they name different listed companies. The company is read from the record’s instruments field (for example “Ejecta Marketing Ltd shares”), after legal-form words are removed; one rename was added by hand (an order on “Appu Marketing and Manufacturing Ltd (now Ejecta Marketing Ltd)” is the same company as the Ejecta Marketing orders). Records whose instruments name no company (“listed equity securities”, front-running orders, several of the global depository receipt orders) are left out of the lower bound. The SEBI records now include issuer fraud, fund diversion and broker fraud under the fraud regulations as well as trading manipulation, so a name can recur across orders for quite different conduct. The result is a lower and an upper bound:

• Lower bound: 177 names (108 individuals, 69 entities) are named in orders on two or more different listed companies. They appear in 184 of the 656 SEBI records (28%). Of the 177, 127 are in orders on two companies, 30 on three, 13 on four and 7 on five or more; the most for one name is 10 companies, a run of orders on global depository receipt issues. The lower bound merges two different companies of one listed group, and two orders on one company that charge different conduct, so it cannot overstate.
• Upper bound: 245 names (160 individuals, 85 entities), 239 records (36%), if every order without a named company counts as its own episode and two orders on one company with different technique tags count as two. 72 of the 317 names appear only in orders on a single company, for example a series of orders on one company’s results.
• I read the records behind these calls. I read the order titles, dates, instruments and statuses of the 118 groups of names that share the same set of records and contain at least one lower-bound name (164 names, out of 182 groups for the 289 names in two or more matters), and checked every pair of company names that were close in spelling. The 64 groups with no lower-bound name were not read. The rule wrongly merged two companies of one listed group (the two Talwalkars companies) and correctly merged the spelling variants of one company (Garware). For the twenty names with four or more companies I read each order’s title and company. That check found that the one hand-added rename had not taken effect, because the alias was keyed on a longer string than the script produced; it was corrected and the counts above are after the fix (it did not change the lower bound). It also found two pairs that might be renames of one company (“Kushal Ltd” and “Kushal Tradelink Limited”, and “K Sera Sera Limited” and “K. Sera Sera Production Limited”). The records do not say so, so they were left as different companies, and merging both would not remove any name from the lower bound. I did not read the underlying SEBI orders again for every name.
• Dismissals are common. Of the 184 SEBI records with a lower-bound repeat name, 131 are judgments, 43 are dismissals and 10 are settlements. A name charged in six separate orders that SEBI dismissed is a repeat charge, not a repeat finding, and the cleanest example in the data is a small set of people each named in a series of orders on different companies’ published results, every one of which was dismissed.

This is not comparable with the 44 names above. The SEBI figure is a rule-based lower bound on a share of 28% of its records, against 3.7% of the older regulators’ records for hand-checked episodes. Part of the gap is how SEBI works: a trading network or a family of traders is charged in a run of orders on different shares, and the library holds those orders for 2022 to 2026. Part of it is method (a rule on the company instead of a reading of each pair), part is that SEBI names are as published and Indian names recur, and some of the 317 may be different people with the same common name (two orders naming a “Sanjay Gupta” do not show that it was one person). The records carry no identifier beyond the name. Read the SEBI result as “names recur across orders on different companies, often in dismissed or small-penalty orders”, not as a count of repeat offenders. No SEBI name is given here.

How sensitive the counts are

• Without the hand-verified spelling merges the figures for the six older regulators are 646 names in two or more records, 101 in two or more matters, and 41 in separate episodes. The merges add three names to the 41.
• Two names could not be settled. One appears in two SEC records of 2020 and 2025, the other in a 2023 and a 2024 CFTC record, and the cached releases do not say whether each pair is one matter or two. Counted as separate, the total is 46.
• Three names were assumed to be one episode though the records do not state it: a CFTC consent order and a later CFTC judgment on a Texas managed-account fraud, an SEC follow-on after a criminal conviction paired with a CFTC judgment on a commodity pool, and a run of SEC records on a ticket-resale scheme. If any is two episodes the total rises by one.
• Four pairs of names always travel together (two stock-exchange entities, an introducing broker and its owner, a boiler room and its principal, two individuals in the same pair of cases). Counted as parties, the 44 names are 40.
• Names that run together in the data. A crude check (individual entries containing “and”, ”&”, ”/” or ”;”) flags 27 of the 4,794 entries outside the AMF and SEBI records, about one in 180, as possibly holding several people in one string, and 4 of the 3,436 SEBI entries (all firm names given in brackets after a person’s name, which the normaliser drops); entity names containing “and” were not counted. Such entries are treated as one name, which can hide a repeat but cannot create one. One SEBI record has no respondent listed.
• SEBI bounds. The 177 and 245 are not a confidence interval but the two ends of the rule: the lower end leaves out orders that name no company, the upper end counts them. A different rule, for example one that read each pair of orders, could land outside them.

What this does not show

It is a count of cases regulators chose to bring and publish. A name that never appears has not been shown to have done nothing, and a name that appears more than once has not been shown to be worse than one that appears once. The library holds records from seven regulators (the SEC supplies 1,844 of the 3,273, SEBI 656, the CFTC 334, the French AMF 209, ASIC 113, the Ontario Securities Commission 69 and the FCA 48), with different publication habits and different start years (SEBI’s records are dated 2022 to 2026 only), so a firm active under a regulator that publishes more will appear more often.

Anonymised respondents cannot be matched. 485 defendant entries in AMF decisions are placeholders (X, Y, A and similar) and are excluded, so a repeat among those respondents is invisible and AMF repeats are under-counted relative to the regulators that publish names.

It has no denominator for activity. A bank that trades in more markets than a boutique has more chances to appear. The library holds no data on firm size, trading volume or employees, so it cannot rank firms by how often they appeared relative to what they do.

A repeat name is not a repeat finding. Some orders are settled without admitting or denying the findings; some matters are filed and have no recorded outcome (180 of the 3,273 records carry the status “filed” as of 2026-10-07; 122 of the 656 SEBI records are dismissals); one repeat name, Cormark, appears in a tribunal case in which none of the allegations were found proven. The defendants field also lists relief defendants, and the library does not tag the role of each name.

The episode calls are judgements by an AI agent. The 123 older-regulator names were read by a Claude AI agent working from the case records and, for some, the cached regulator documents; the 27 name merges that still apply and 20 near-misses were decided the same way. No lawyer reviewed them. The SEBI calls are a rule on the company named in each order, checked by that same agent reading the order titles and instruments, not the orders, and for the groups containing a lower-bound name only. The records themselves: the original 2,428 had sampled second reads; the 543 records updated on 4 October were researched that day; the 209 AMF France records had a single reading and a 60-record sampled second read on 7 October (54 agree on every field); the 656 SEBI records had a single reading by one AI agent; for the first 489 a 60-record sampled second read on 8 October agreed on every field for 56 (93%, interval 84% to 97%), the four disagreements all being penalty amounts, and for the 167 added on 9 October a sampled second read of 50 of them on 9 October agreed on every field for 46 (92%, interval 81% to 97%; the misses were two dissolved-company dismissals counted as out of scope and two technique tags, since corrected), so a SEBI name, status or company could be wrong. The rule for “one episode” is a rule of thumb (a filing and its judgment, a follow-on, parallel orders on the same conduct), and a reasonable reader could draw a few lines differently. Names that sit in a single matter but cover two episodes cannot be seen: the matter rule only merges, so it can hide a repeat inside a matter (none is known after the 7 October deletions). The list of settled calls, near-misses and assumptions is in the verified file.

The data has gaps. personSlug is null on every record, so people are matched by name alone and two people with the same name could be merged. Defendant lists are taken from the records as published and can still omit or mis-state a name; a repeat can hide behind an unlisted or differently spelled name. Several corporate groups are joined by name, not by ownership. SEBI orders list noticees as published, with inconsistent spellings and some very common names, and the five SEBI batch records each list only a few sample noticees of a year of hundreds of orders. Records change as corrections are made: a count here can move by a name or two between runs.

It is not legal advice or a ranking. If you find a record this analysis got wrong, use the error link on its page, or write to [email protected] with the slug and a link to the document; it will be logged on the corrections page. The earlier post What reading every record found explains how the records were checked.

Re-running it

node scripts/analysis/repeat-actors.mjs out.json reads src/content/cases/*.json and scripts/analysis/repeat-actors.verified.json and writes every number used here. Setting NO_ALIASES=1 skips the person-name merges to give the sensitivity figures above. The scripts’ SEBI_REVIEW=path.json option writes every SEBI name that appears in two or more matters, for checking. Five of the headline figures in the earlier version of this post (the 2,428 records, 4,822 defendant entries, 190 “filed” records, the record counts of five repeat names and the agency totals) were recomputed with a separate throwaway script and matched; the figures in this version were not independently recomputed.

Techniques referenced

• 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.
• FX fixing — FX fixing manipulation is trading during the short window used to calculate a daily currency benchmark, using advance knowledge of client orders that must be executed at that fix.
• The naked short selling debate — Naked short selling is selling short without having borrowed the security or arranged to borrow it, which is restricted by Regulation SHO and whose real-world scale and price impact remain genuinely contested.

Cases referenced

Reviewed October 4, 2026. Spotted an error? Tell us.