Market Manipulation. Search

Who appears more than once

Of 4,017 distinct names in the defendant lists, 666 appear in two or more records and 126 in two or more matters, but only 43 in separate enforcement episodes after a hand check: 28 firms and 15 individuals. 21 of the firms are banks, securities firms, exchanges or a transfer agent. A repeat name is not evidence of repeat misconduct.

Published 2026-10-04 · 9 min read

Most names in the library appear once. Of 4,017 distinct names in the defendant lists of its 2,428 case records, 666 appear in two or more records, 126 in two or more matters, and 43 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 43 that remain are 28 firms and 15 individuals, and 21 of the firms are banks, securities firms, stock exchanges or a transfer agent.

Names that appear more than once, counted three waysA column chart of the distinct names in the library’s defendant lists that appear more than once, out of 4,017 distinct names. 666 appear in two or more case records, 126 in two or more matters under the library’s own grouping rule, and 43 in two or more separate enforcement episodes after every name in two or more matters was read by hand (one of the 43 sits in a single matter under the rule). Most of the other 84 names in two or more matters are the same case recorded at its filing and again at its judgment, or the same conduct brought by two regulators. 0 222 444 666 666Two or more records 126Two or more matters 43Two or more episodesDistinct names (of 4,017)

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: 4,822 entries, 1,306 distinct entity names and 2,711 distinct individual names after normalising. 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 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.

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 2,051 matters for 2,428 records.

Episodes. The matter rule misses many pairs, so every one of the 126 names in two or more matters 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. 28 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 the evening of 2026-10-04. The figures are from a re-run on 2,428 records after the status and flag corrections of that date. The corrections that matter here are the name fixes (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) and the new narratives and timeline events on the 543 of 733 records whose status moved from “filed” (190 remain “filed”). Those new cross-references let the library’s matter rule join more records: matters fell from 2,162 to 2,051, and names in two or more matters from 304 to 126. The counts of names in two or more records (666) and in separate episodes (43) did not change. 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 126 names in two or more matters, 84 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. The rule also errs the other way once: it joins the two records of one individual, a 2015 subpoena-enforcement action and a 2026 judgment in a separate case, into one matter, and that name was counted as two episodes by hand. So 42 of the 43 names in separate episodes are also in two or more matters.

So 202 matters (10%) 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, 84 of 2,051 matters (4.1%) and 96 of 2,428 records (4.0%) involve a repeat name. Firms account for 63 of those matters (3.1%) and individuals for 26 (1.3%); five matters have both. The 21 banks, securities firms, exchanges and the transfer agent appear in 49 matters (2.4%).

The names that come back are mostly banks and securities firms

What the 43 names that appear in separate episodes areA horizontal bar chart of the 43 names that appear in two or more separate enforcement episodes, by the analyst’s reading of what each is. There are 15 individuals (11 in SEC cases and 4 in CFTC cases), 10 securities firms, 8 banks, 3 commodities or trading firms, 3 investment firms, 2 stock exchange entities, 1 transfer agent and 1 firm described as a boiler room. Banks, securities firms, exchanges and the transfer agent make 21 of the 28 firms. No audit firm and no law firm appears in more than one episode.Individuals 15 11 SEC, 4 CFTCSecurities firms 10Banks 8Commodities or trading firms 3Investment firms 3Stock exchanges 2Transfer agents 1Boiler rooms 1

Of the 43 names, 36 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:

Name as in the recordsEpisodesRecordsRegulatorsYearsConduct tags (ours)
JPMorgan Chase Bank45CFTC, FCA2013 to 2020price manipulation, FX fixing, benchmark rigging, spoofing
Citigroup Global Markets Inc.44CFTC, SEC2015 to 2018spoofing, mismarking; two 2015 SEC orders carry no tag
Deutsche Bank Securities Inc.44CFTC, SEC2016 to 2020analyst manipulation, benchmark rigging, price manipulation, spoofing
The Royal Bank of Scotland plc35CFTC, FCA2013 to 2017benchmark rigging, FX fixing, price manipulation, wash trading, cash-versus-derivatives schemes
Citibank N.A.34CFTC, FCA, SEC2014 to 2018benchmark rigging, FX fixing, price manipulation; the 2018 SEC order carries no tag
Wedbush Securities Inc.33SEC2014 to 2021unregistered distributions on one of three

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.

Banking groups with three or more separate enforcement episodes in the libraryA horizontal bar chart of banking groups, with the legal entities of each group joined by the analyst by name, ranked by the number of separate enforcement episodes in which any entity of the group is a named respondent. Citigroup and Citibank have 7 episodes across 8 records from the CFTC, FCA and SEC between 2014 and 2018. JPMorgan has 6 across 8 records from 2013 to 2021. Deutsche Bank has 6 across 7 records from 2015 to 2020. Morgan Stanley has 5 across 6 records from 2014 to 2024. UBS and Merrill Lynch with Bank of America have 4 each. The Royal Bank of Scotland, HSBC, Toronto-Dominion and the Royal Bank of Canada have 3 each. The records do not say which entities share a parent, so the grouping is the library’s own, and the chart shows how often a name came back, not how much misconduct there was.Citigroup and Citibank 7 8 records, CFTC FCA SEC, 2014 to 2018JPMorgan 6 8 records, CFTC FCA SEC, 2013 to 2021Deutsche Bank 6 7 records, CFTC FCA SEC, 2015 to 2020Morgan Stanley 5 6 records, CFTC SEC, 2014 to 2024UBS 4 5 records, ASIC CFTC FCA SEC, 2013 to 2018Merrill Lynch and Bank of America 4 4 records, CFTC SEC, 2015 to 2019Royal Bank of Scotland 3 5 records, CFTC FCA, 2013 to 2017HSBC 3 4 records, CFTC FCA, 2014 to 2023Toronto-Dominion 3 3 records, OSC SEC, 2013 to 2024Royal Bank of Canada 3 3 records, CFTC OSC, 2014 to 2019

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

Eleven of the 43 names have their separate episodes opened by more than one regulator, and all eleven are firms. Eight have a record from a regulator outside the United States, the FCA or the Ontario Securities Commission: seven banks and a Canadian securities dealer. 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 28 names with at least two episodes that carry a technique tag, 15 share no tag across their episodes: the library tags one episode as, say, spoofing and another as something else. 13 share at least one. Fifteen of the 43 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.

Individuals

Fifteen individuals appear in separate episodes: eleven 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. Two more were counted in a subpoena-enforcement action and later in a complaint, with nothing in the records linking the two. The other six each have two or three proceedings on different conduct. This post names no individual: 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. Nineteen 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. One is the CFTC’s January 2018 announcement of eight actions, which names three banks but no defendants. Fifteen of the rest 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. None of the eighteen charges the bank. These are mentions, not respondent roles, and they are not in the counts above.

How sensitive the counts are

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 five regulators (the SEC supplies 1,860 of the 2,428, the CFTC 338, ASIC 113, the Ontario Securities Commission 69 and the FCA 48), with different publication habits and different start years, so a firm active under a regulator that publishes more will appear more often.

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 (190 of the 2,428 records carry the status “filed” as of 2026-10-04); 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 126 names were read by a Claude AI agent working from the case records and, for some, the cached regulator documents; the 28 name merges and 20 near-misses were decided the same way. No lawyer reviewed them. 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 (one name is an example). 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. 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. Five of the headline figures (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.

Techniques referenced

Cases referenced

Action Agency Filed Technique Penalty Status
CFTC v. Citibank, HSBC, JPMorgan, RBS and UBS (FX benchmark manipulation, 2014) CFTC 2014-11-12 Benchmark Submission Rigging , FX Fixing +1 $1.5bn settled
CFTC v. Citigroup Global Markets Inc. (spoofing, 2017) CFTC 2017-01-19 Spoofing $25m judgment
SEC v. Citigroup Global Markets, Inc. (2015) SEC 2015-08-19 $15m settled
SEC v. Citigroup Global Markets Inc. and Citigroup Inc. (mismarking, 2018) SEC 2018-08-16 Mismarking $5.8m settled
SEC v. Citibank, N.A. (2018) SEC 2018-11-07 $13.6m settled
CFTC v. JPMorgan Chase Bank (price manipulation, 2013) CFTC 2013-10-16 Price Manipulation $100m judgment
CFTC v. JPMorgan (price manipulation, 2020) CFTC 2020-09-29 Price Manipulation , Spoofing $436m settled
SEC v. Wedbush Securities Inc., Jeffrey Bell and Christina Fillhart (market access controls, 2014) SEC 2014-11-20 $25k settled
SEC v. Wedbush Securities, Inc. (2019) SEC 2019-06-18 $2.4m settled
SEC v. Wedbush Securities Inc. (unregistered distributions, 2021) SEC 2021-12-15 Unregistered Distributions $1m settled
SEC v. Cormark Securities Inc. (naked short selling debate, 2020) SEC 2020-12-21 Naked Short Selling Debate $800k settled
OSC v. Cormark Securities Inc., William Jeffrey Kennedy, Marc Judah Bistricer and Saline Investments Ltd. (2022) OSC 2022-11-09 — dismissed
CFTC v. Classic Energy LLC and Mathew D. Webb (front running, 2019) CFTC 2019-10-01 Front Running $1.5m settled
CFTC v. Classic Energy LLC and Mathew D. Webb (block trade information misuse, 2021) CFTC 2021-06-15 — settled
CFTC v. Agridime LLC, Joshua Link and Jed Wood (ponzi schemes, 2024) CFTC 2024-05-14 Ponzi Schemes — judgment
CFTC v. Agridime LLC (ponzi schemes, 2025) CFTC 2025-06-16 Ponzi Schemes — judgment
SEC v. Agridime LLC, Joshua Link, and Jed Wood (ponzi schemes, 2023) SEC 2023-12-18 Ponzi Schemes — judgment
SEC v. Agridime, LLC, Jed Wood, and Joshua Link (ponzi schemes, 2025) SEC 2025-09-30 Ponzi Schemes $3.3m judgment
SEC v. Team Resources, Inc., et al. (unregistered distributions, 2015) SEC 2015-04-06 Unregistered Distributions — settled
SEC v. Andrew Stitt (boiler rooms, 2019) SEC 2019-02-06 Boiler Rooms , Unregistered Distributions — judgment
SEC v. Empire Stock Transfer, Inc. and Patrick R. Mokros (undisclosed control blocks, 2014) SEC 2014-04-08 Undisclosed Control Blocks $50k settled
SEC v. Empire Stock Transfer, Inc. and Matthew J. Blevins (unregistered distributions, 2016) SEC 2016-12-16 Unregistered Distributions $170k settled
SEC v. BDO China Dahua CPA Co., Ltd. and four other China-based audit firms (2014) SEC 2014-01-22 — judgment
CFTC v. Royal Bank of Canada (wash trading, 2014) CFTC 2014-12-18 Wash Trading $35m judgment
OSC v. Royal Bank of Canada (FX supervision and controls, 2019) OSC 2019-08-26 — settled

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