SEC v. CLS Global FZC LLC and Andrey Zhorzhes (paid crypto market making, 2024)
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 October 2024 the SEC charged CLS Global FZC LLC, a UAE crypto market maker, and Andrey Zhorzhes over an alleged scheme to create false trading activity in the NexFundAI token. On April 7, 2025 CLS Global consented to a final judgment with an injunction, a $425,000 penalty, $3,000 in disgorgement and $80.39 in interest, plus undertakings to stop serving U.S. clients; the release does not report an outcome for Zhorzhes.
The record
| Agency | SEC |
|---|---|
| Release number | LR-26154 |
| Date filed | 2024-10-09 |
| Date resolved | 2025-04-07 |
| Court | U.S. District Court, District of Massachusetts |
| Status | settled |
| Criminal parallel | Yes: charged (CLS Global FZC LLC and others (No. 24-cr-10293)), D. Mass. |
| Defendants | CLS Global FZC LLC ; Andrey Zhorzhes |
| Cited as charged or alleged | Exchange Act s.10(b) and Rule 10b-5 ; Exchange Act s.9(a)(2) ; Securities Act s.17(a) |
| Techniques | Paid crypto market making |
What was ordered
- Civil penalty
- $425k
- Disgorgement
- $3k
- Prejudgment interest
- $80
- Total relief
- $428k
- Alleged gain
- —
What is alleged to have happened
The Securities and Exchange Commission filed this complaint on October 9, 2024 and announced it on October 15, 2024 as litigation release LR-26154, in civil action 1:24-cv-12590 in the District of Massachusetts. The defendants are CLS Global FZC LLC and Andrey Zhorzhes (1 individual, 1 entity).
The complaint alleges that the promoters of NexFundAI, a crypto asset the FBI had created as part of its own market-manipulation investigation and that was offered as a security to retail investors, hired CLS Global to provide market-manipulation-as-a-service. CLS Global and Zhorzhes allegedly traded the token in ways that served no economic purpose and used an algorithm to generate artificial volume, to give investors the false impression of an active market. The SEC charges Securities Act Sections 17(a)(1) and (3) and Exchange Act Sections 9(a)(2) and 10(b) and Rules 10b-5(a) and (c).
The complaint asked for permanent and conduct-based injunctions, disgorgement with interest and penalties. Those are requested remedies, so no bar or money is recorded, and an earlier version that listed a conduct-based injunction as imposed was wrong. The U.S. Attorney's Office announced a parallel criminal action. A later record covers CLS Global's 2025 resolution.
For the regulator's own account of the facts, read the primary document linked above.
Outcome. SEC litigation release LR-26287 (April 17, 2025) reports that the District of Massachusetts entered a final judgment against CLS Global on April 7, 2025, to which the company consented. It enjoins CLS Global from violating the cited antifraud and market-manipulation provisions, orders a $425,000 civil penalty, $3,000 in disgorgement and $80.39 in prejudgment interest, and requires undertakings: take steps to ensure its clients are not U.S. persons, adopt new-client procedures, and certify compliance. Payments may be offset by amounts paid in the parallel criminal case, United States v. CLS Global FZC LLC et al., No. 24-cr-10293 (D. Mass.). This outcome covers CLS Global only; the release does not resolve the claims against Andrey Zhorzhes, and we did not check how those ended.
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.
- Paid crypto market making — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2024-10-09 Complaint filed (D. Mass.)
- 2024-10-15 Litigation release published
- 2025-04-07 Final consent judgment entered against CLS Global FZC LLC (reported in LR-26287)
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
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 |
|---|---|---|---|
| 2024-10-09 | SEC | SEC v. CLS Global FZC LLC and Andrey Zhorzhes (paid crypto market making, 2024) | Settled |
| 2025-04-17 | SEC | SEC v. CLS Global FZC LLC (paid crypto market making, 2025) | Judgment entered |
Related actions
Other actions in the library sharing at least one technique tag with this one.
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Gotbit Consulting LLC a/k/a Gotbit Hedge Fund and Fedor Kedrov (paid crypto market making, 2026) | SEC | 2026-08-03 | Paid Crypto Market Making , Wash Trading | — | settled |
| SEC v. CLS Global FZC LLC (paid crypto market making, 2025) | SEC | 2025-04-17 | Paid Crypto Market Making | $425k | judgment |
| SEC v. Gotbit Consulting LLC a/k/a Gotbit Hedge Fund and Fedor Kedrov (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making , Wash Trading | — | unknown |
| SEC v. Russell Armand, Maxwell Hernandez, Manpreet Singh Kohli, and Nam Tran (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making | — | settled |
| SEC v. Vy Pham (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making | — | settled |
| SEC v. ZM Quant Investment Ltd., Baijun Ou a/k/a Eric Ou, and Ruiqi Lau a/k/a Ricky Liu (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making , Wash Trading | — | unknown |