CFTC v. Mehran Khorrami and Cayley Investment Management, LLC (wash trading, 2020)
Judgment entered
Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In May 2020, the CFTC settled charges against New York trader Mehran Khorrami and his firm Cayley Investment Management, LLC, ordering a US$150,000 penalty for wash sales and noncompetitive trades in CME futures for a single client's accounts.
The record
| Agency | CFTC |
|---|---|
| Release number | 8161-20 |
| Date filed | 2020-05-07 |
| Date resolved | 2020-05-07 |
| Status | judgment |
| Asset class | commodities, futures |
| Venue | CME |
| Criminal parallel | No |
| Defendants | Mehran Khorrami ; Cayley Investment Management, LLC |
| Techniques | Wash trading |
What was ordered
- Civil penalty
- $150k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $150k
- Alleged gain
- —
What is alleged to have happened
The Commodity Futures Trading Commission announced this matter on May 7, 2020 as release 8161-20. The respondents named are Mehran Khorrami and Cayley Investment Management, LLC (1 individual, 1 entity).
The order finds that on February 8, 2018, Khorrami placed simultaneous buy and sell orders for a client's accounts in six CME futures contracts, then adjusted them until the prices matched, producing six prearranged cross trades in crude oil and four currency futures. The same client was on both sides, so this is a wash sale, not a matched order. CME separately fined Khorrami $30,000 and suspended him for ten days.
This library tags the matter as wash trading, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
A $150,000 civil monetary penalty, shared by the two respondents, and a cease-and-desist order.
The respondents consented to the order.
What technique is this, and how does it work?
This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.
- Wash trading — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2020-05-07 CFTC release published
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.