CFTC v. Michael Nowak and Gregg Smith (spoofing, 2019)
Settled
Checked against the primary document on October 4, 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 September 2019 the CFTC sued two precious-metals traders at a major bank, Gregg Smith and Michael Nowak, alleging spoofing and attempted price manipulation. On 22 December 2025 an Illinois federal court entered consent orders imposing a $200,000 penalty and three-year trading and registration ban on Smith, and a $150,000 penalty and six-month ban on Nowak. Both had been convicted in a parallel criminal case.
The record
| Agency | CFTC |
|---|---|
| Release number | 8013-19 |
| Date filed | 2019-09-16 |
| Date resolved | 2025-12-22 |
| Court | U.S. District Court, Northern District of Illinois |
| Status | settled |
| Asset class | commodities, futures |
| Venue | CME |
| Criminal parallel | Yes: sentenced (Smith and Nowak), U.S. District Court, Northern District of Illinois |
| Sentence | 2 years |
| Bars imposed | trading ban, registration bar |
| Defendants | Michael Nowak ; Gregg Smith |
| Techniques | Price manipulation , Spoofing |
What was ordered
- Civil penalty
- $350k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $350k
- Alleged gain
- —
What is alleged to have happened
the Commodity Futures Trading Commission announced this matter on September 16, 2019 as release 8013-19. The respondents named are Michael Nowak and Gregg Smith (2 individuals, 0 entities).
This library tags the matter as price manipulation and spoofing, 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.
The CFTC filed a civil complaint alleging the two bank traders spoofed, ran a manipulative scheme and attempted price manipulation in precious metals futures.
The conduct is recorded against commodities and futures, with CME identified in the release.
The release references a parallel criminal proceeding. Where a criminal case exists, the civil and criminal outcomes are recorded separately, because they resolve on different standards of proof.
Outcome. The CFTC's January 2026 release says the Northern District of Illinois entered consent orders against Smith and Nowak; the orders themselves are dated 22 December 2025. Smith pays a $200,000 civil monetary penalty and is barred from CFTC markets and registration for three years; Nowak pays $150,000 and is barred for six months; both are enjoined from further spoofing. The money field here is the sum, $350,000. The release also reports that both men were convicted in the parallel criminal case, with Smith sentenced in August 2023 to two years in prison and a $50,000 fine, and Nowak to one year and a day and a $35,000 fine; the sentence recorded here (24 months) is Smith's. The consent orders are settlements, not findings after trial in the civil case.
For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.
What technique is this, and how does it work?
This action is tagged with 2 techniques 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.
- Price manipulation — see how it works, what statute it engages, and every other action tagged the same way.
- Spoofing — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2019-09-16 CFTC release published
- 2025-12-22 Consent orders entered against Smith and Nowak: penalties of $200,000 and $150,000 and trading and registration bans
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
- CFTC release
- CFTC order or complaint
- CFTC press release 9168-26 (consent orders)
- Smith consent order (dated 22 December 2025)
- Nowak consent order (dated 22 December 2025)
Same matter
The library links these 2 records because they appear to concern one matter: the same lead defendant, an overlapping technique tag and close filing dates, or a shared court docket or a release that cites the other. Records are listed by date filed.
| Date filed | Agency | Record | Status |
|---|---|---|---|
| 2019-09-16 | CFTC | CFTC v. Michael Nowak and Gregg Smith (spoofing, 2019) | Settled |
| 2026-01-16 | CFTC | CFTC v. Gregg Smith and Michael Nowak (spoofing, 2026) | Judgment entered |
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| FCA v. Corrado Abbattista (spoofing, 2020) | FCA | 2020-12-15 | Price Manipulation , Spoofing | — | judgment |
| CFTC v. JPMorgan (price manipulation, 2020) | CFTC | 2020-09-29 | Price Manipulation , Spoofing | $436m | settled |
| CFTC v. Hard Eight Futures, LLC and Igor Chernomzav (spoofing, 2019) | CFTC | 2019-09-30 | Price Manipulation , Spoofing | $2.5m | judgment |
| CFTC v. Corey D. Flaum (price manipulation, 2019) | CFTC | 2019-07-25 | Price Manipulation , Spoofing | — | settled |
| CFTC v. Merrill Lynch Commodities (price manipulation, 2019) | CFTC | 2019-06-25 | Price Manipulation , Spoofing | $11.5m | judgment |
| CFTC v. Deutsche Bank (price manipulation, 2018) | CFTC | 2018-01-29 | Price Manipulation , Spoofing | $30m | judgment |