CFTC v. U.K. Resident Navinder Singh Sarao and His Company Nav Sarao Futures Limited PLC (layering, 2015)

Settled

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The CFTC's 2015 civil case against Navinder Singh Sarao and Nav Sarao Futures Limited PLC over E-mini S&P 500 spoofing and layering ended, as to Sarao, in a consent order entered in the Northern District of Illinois on 14 November 2016. The order requires him to pay a $25,743,174.52 civil penalty and $12,871,587.26 in disgorgement, with permanent trading and registration bans. The CFTC says Sarao admitted the allegations in the order; the release does not describe the company's separate treatment.

The record

What was ordered

Civil penalty

$25.7m

Disgorgement

$12.9m

Prejudgment interest

—

Total relief

$38.6m

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Commodity Futures Trading Commission announced this matter on April 21, 2015 as release 7156-15. The respondents named are U.K. Resident Navinder Singh Sarao and His Company Nav Sarao Futures Limited PLC (1 individual, 1 entity).

This library tags the matter as layering, 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 unsealed a civil complaint alleging Sarao and his company manipulated and spoofed the E-mini S&P 500 with a layering algorithm, contributing to the May 6, 2010 flash crash.

The conduct is recorded against 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.

On 17 November 2016 the CFTC announced that Judge Andrea R. Wood had entered a consent order against Sarao in the civil case. The order, which the court filed on 14 November 2016, imposes a civil monetary penalty of $25,743,174.52 and disgorgement of $12,871,587.26, permanently bars further violations of the Commodity Exchange Act as charged, and bans Sarao from trading and from registration. In the order Sarao admits the complaint's allegations and the order's findings of fact, which describe a dynamic layering program, a back-of-queue program and manual spoofing in the E-mini S&P 500 contract, including on 6 May 2010. The order credits him dollar for dollar against his disgorgement obligation for any disgorgement paid in his criminal case, refers to roughly $6.96 million of frozen escrow funds, and finds him liable as a controlling person for the violations of Nav Sarao Futures. The CFTC release says he pleaded guilty to one count of spoofing and one count of wire fraud in that related criminal action. The CFTC release is about the order against Sarao; it does not say whether a separate order was entered against Nav Sarao Futures Limited PLC, and this page does not record a prison sentence because neither source states one.

For the regulator's own account of the facts, read the primary documents linked above. This page summarises the structured record and does not reproduce them.

What technique is this, and how does it work?

This action is tagged with 3 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.

• Layering — see how it works, what statute it engages, and every other action tagged the same way.
• 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

1. 2015-04-21 CFTC release published
2. 2016-11-14 Consent order entered against Sarao (N.D. Ill.)
3. 2016-11-17 CFTC announces the consent order and monetary sanctions

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 press release 7486-16 (consent order and sanctions)
• Consent order, CFTC v. Nav Sarao Futures Limited PLC, No. 15-cv-3398 (N.D. Ill.), Doc. 77

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.