Corrections

This site logs every correction publicly with the date, what was wrong and what changed. Errors in enforcement records are corrected as a priority, and corrections that record a case resolving in a respondent's favour are treated as the most urgent category.

How to report an error

Email [email protected] with the page URL and what is wrong. If you have a primary document that establishes the correct position, include the link — it makes the fix immediate rather than an investigation.

We aim to acknowledge within two working days.

What we prioritise

In order:

1. A case that resolved in a respondent’s favour and is not recorded that way. A dismissal, an acquittal, a withdrawal, or charges dropped. This is the most consequential category of error this site can make, and it is fixed first.
2. A factual error in an enforcement record — wrong amount, wrong date, wrong respondent, wrong status, wrong court, a technique tag that does not fit the conduct described.
3. A broken or wrong primary-source link. Every case record’s value rests on that link.
4. An error in an explanation — a misstated statute, a wrong citation, a worked example that does not compute.
5. Everything else — typographical errors, awkward sentences, formatting.

How corrections are handled

We do not edit silently. When something material changes, the change is recorded in the log below with the date, the page, what was wrong and what it now says.

Where a case has resolved in a respondent’s favour, the outcome is rendered above the fold on the case page and on any person page linked to it, before the description of what was alleged. We do not delete the page. Deleting it would make the original allegation harder to find without removing it from the internet; keeping the page with the outcome on it is the only version that actually corrects the record.

Where a record was machine-extracted and is wrong, we fix the record and, where the error came from a rule rather than a one-off, we fix the rule as well.

What we will not do

We will not remove an accurate record of a public enforcement filing on request. Enforcement actions brought by regulators in public are public. If a matter has resolved, we will record that prominently. If a record is inaccurate, we will correct it. If it is accurate and unresolved, it stays, described as an allegation.

We will not add material about individuals beyond what public filings state. See the editorial policy for what a person page may contain.

Corrections log

Entries appear in reverse chronological order, each with the date, the affected page, the nature of the error, and the change made.

2026-10-09 (scope widened) — SEBI scope widened: 167 records added, SEBI now 656; analysis posts re-run on 3,273 records

Affected: 167 new SEBI records, the SEBI total (489 to 656: 466 judgments, 122 dismissals, 68 settlements), the library total (3,106 to 3,273), the SEBI regulator page, the sources page and the analysis posts.

• Why. The 8 October SEBI scope was narrower than the library’s own practice of including related conduct. Under the wider scope, fraud on investors or the market under the PFUTP Regulations and section 12A is in: issuer fraud such as GDR or IPO-proceeds fraud, fund diversion with PFUTP penalties, broker fraud on clients with PFUTP findings, and fraud matters that were alleged and dismissed. Many of these records name no manipulation technique.
• What was re-read. The 189 orders held out on 8 October and 7 earlier rejections, 196 in all, were read from the orders: 167 were added and 29 were rejected. About 100 other candidates read in the first round remain rejected, and the guard list now holds 122 SEBI entries.
• Rejected on reading. Future Retail (order 101374) was read in full and rejected: the fraud and unfair-trade-practice charges were not established, and only listing-obligation penalties remain.
• Reviewed under the wider scope. The Rana Kapoor YES Bank bond mis-selling order, the NSE dark fibre order and the Guiness Securities orders were reviewed and are in the library now (Rana Kapoor 62755, NSE dark fibre 60350, Guiness 60493 and 76628). Other mis-selling cases are kept only where PFUTP penalties were imposed.
• How they were read. The 167 added records come from a single AI reading; a sampled second reading of 50 of them on 9 October agreed on every field for 46 (92%, interval 81% to 97%). They are checked by AI agents, not lawyers.
• Posts. The analysis posts were re-run on 3,273 records. Statements that SEBI orders are limited to manipulation, insider dealing or front running were corrected, because the scope now also includes issuer and broker fraud with PFUTP findings, and technique tags are missing for many.

2026-10-08 (new source and removals) — SEBI added as a seventh regulator; 21 non-matter records removed; analysis posts re-run

Affected: 489 new records, 21 removed records, the library total (3,106 at the time; widened on 9 October, see the entry above), the regulator, firm and coverage pages, the Stanford and Bretas records, and every analysis post that counted records.

• What was added. Final orders of the Securities and Exchange Board of India from 2022 to October 2026: 357 judgments, 90 dismissals and 42 settlements. They were chosen from 4,624 listed orders by a classifier and an AI reading of each order; the about 1,580 “illiquid stock options at BSE” adjudication orders are grouped into five records. Penalties are in rupees as published and are kept out of every US dollar total. SEBI sanctions and does not convict. See Sources.
• How they were read. Each record comes from a single AI reading of the order, with no independent second reading yet; some penalty totals are sums of multi-noticee tables made by the reading agents. They are checked by AI agents, not lawyers.
• Records removed. 21 records that were not enforcement matters: 16 SEC applications to enforce a subpoena, three CFTC umbrella announcements, the CFTC RED List notice and a dismissed OSC shareholder motion. Their release addresses are kept in a guard list so the collectors do not recreate them. Four lower-confidence candidates were read and kept: Roberts, Sechovich, Cognata and CFTC release 7814-18.
• Posts. The analysis posts were re-run on 3,106 records. Six regulators compared became Seven regulators compared, with a redirect from the old address.
• Sourcing. Stanford (2025) is back to “sentenced” (1,320 months), sourced to the Fifth Circuit opinion no. 12-20411; Bretas was verified against CFTC releases 8163-20 and 8282-20.
• Already logged. The AMF second reading is in the 2026-10-07 entry. A sampled second reading of 60 SEBI records on 8 October agreed on every field for 56 (93%, interval 84% to 97%); the four disagreements were all penalty amounts, and one (Commex) was corrected.

2026-10-07 (data checks) — AMF second reading, criminal-stage corrections, a new technique

• AMF second reading. An independent AI re-read of 60 of the AMF France records (12 settlements, 12 dismissals, 36 sanctions, drawn with a fixed seed) agreed with the recorded values on every field for 54 (90%, 95% interval 80% to 95%) and on defendants, status, amount and date for 59 of 60 (98%). Six records were corrected: one fine was reduced on appeal from EUR 2.1 million to EUR 1.8 million after the Paris Court of Appeal set aside the sanctions on four respondents, and five records had technique tags changed or added. Technique tags are a judgment call and were the main source of disagreement. The sample bounds the error and does not remove it.
• Criminal stages. Nineteen records marked “convicted” whose sources show only a criminal restitution or forfeiture order were moved to “not stated”; fifteen others were checked against their sources and kept. One kept record (Bretas, a CFTC release that could not be fetched) was not checked against its source. Stanford 2025 was among the nineteen: he was convicted, but the SEC release cited states only forfeiture orders, so the record says that until a primary source for the conviction is cited. The civil and criminal parallels post now shows 26 convicted and 49 not stated.
• New technique. Misleading issuer disclosure covers false or late information a listed company itself gives the market; 33 AMF records that had no technique now carry it. Two were left untagged: a share buy-back volume breach and an individual’s false shareholding notices.
• Still open. All 190 records marked “filed” were searched again against the SEC litigation-release index and the cached SEC documents; none could be resolved, because a final judgment against the lead defendant would sit in a court docket we cannot reach. Two AMF decisions (SAN-2013-02 and SAN-2014-18) remain out of the library because their PDFs are no longer online.

2026-10-05 (new source) — AMF France added as a sixth regulator; Google Analytics moved to Consent Mode

Affected: 209 new records, the library total (2,428 to 2,637), the regulator, firm and coverage pages, and every analysis post that counted records.

• What was added. Decisions of the Commission des sanctions of France’s Autorité des marchés financiers from 2004 to 2026: 167 sanctions decisions, 24 homologated settlements and 18 dismissals (clearances). 119 concern insider dealing and 23 price manipulation, with layering, spoofing, marking the close and false information among the rest. Penalties are in euros, kept out of every US-dollar total. The AMF anonymises respondents in older decisions as “X” or “A”; those are recorded as published and never matched across records. See AMF France on the sources page and the regulator page.
• How they were read. The ingester collected 590 decision and settlement pages; a French-language classifier chose 239 candidates; AI agents read each candidate decision in French and kept 209, rejecting 28 that charged compliance, disclosure or reporting failures rather than manipulation or insider dealing (and two whose documents could not be read). Each kept record had a single reading; a sampled second reading followed on 7 October (see the entry of that date). Disclosure-type cases the AMF treats as market abuse now carry their own technique, misleading issuer disclosure, added on 8 October.
• Posts. The analysis posts were re-run with the sixth regulator. Five regulators compared became Six regulators compared, with a redirect from the old address. The origins post excludes the French documents, and the repeat-actors post and firm pages exclude the anonymised placeholders.
• Analytics. Google Analytics now runs in Consent Mode v2: the tag loads on every page with consent denied, so a visit reaches Google before any choice, with cookieless pings only; cookies depend on Accept. The privacy page says so.

2026-10-04 (new features) — criminal outcomes, statutes, firm and regulator pages, a database, six landmark posts

Affected: every record flagged as having a criminal parallel, and new pages built from the data.

• Criminal outcomes. Each of the 805 records with a criminal parallel now carries the furthest criminal stage its documents state (charged, pleaded, convicted, sentenced, acquitted, dismissed, or not stated), read by an AI model from the documents already linked. In the course of that reading, the flag was cleared on about a dozen more records where the document did not describe a criminal case on the same conduct, and set on a few where it did (Stanford 2025, Mohan 2018). An independent re-read of 80 records agreed on 68 (85%, interval 76% to 91%); seven were corrected. About twenty “convicted” records rest on a criminal restitution or forfeiture order alone and may belong at “sentenced”; they are kept and the civil and criminal parallels post says so.
• Statutes. 39 statutes and rules are catalogued with links to official text, and 1,833 records are matched to at least one by explicit citation in the document (browse by statute). A read of about 230 matched pairs found four wrong in the first round and none in the second; a cited statute is what the document charges or alleges, not a finding.
• Firms. 41 companies named in two or more matters have a page each; matching is by name only, and no ownership link between similarly named entities is claimed.
• Regulators and coverage. Pages for each of the five regulators and a coverage page say which sources feed the library and what they do not cover.
• Data. The data dictionary, a SQLite download and per-technique and per-regulator feeds.
• Landmark posts. Six matters read in full from their primary documents: Stanford, the 2013 to 2014 benchmark orders, JPMorgan 2020, the January 2018 anti-spoofing announcement, Glencore 2022 and Control-Finance.
• Small fixes. The Lloyds and R.P. Martin benchmark orders are recorded as settled, not as judgments; Gregg Smith’s two-year and Rodney Forrest’s sixty-three-month sentences are now recorded in months; a stray criminal-matter sentence was removed from two benchmark records; an invalid URL in one criminal-outcome record was fixed.

2026-10-04 (outcomes) — 543 of 733 records stuck at “filed” were updated; the criminal-parallel flag was corrected on about 140 records

Affected: records whose status was still “filed”. A random sample of 100 found that 66 had since settled, been decided or dismissed, so all 733 were researched in two rounds (the second after the SEC and CFTC sites stopped rate-limiting) against regulator and court pages. 543 now have a final status (net change in the library: settled +302, judgment +225, dismissed +16); 190 remain “filed”, and that figure is an upper bound on cases truly still pending: for most of them the SEC and CFTC pages show no later release naming the defendants (checked on 2026-10-04) or the court dockets could not be reached, and for some only part of the defendants were resolved. Each updated record has a new dateResolved where the source gave one, money only where the order states it, a rewritten summary and narrative, a timeline event with the source opened, and reviewedOn 2026-10-04. Many outcomes cover only some respondents; the narrative says which. Several dates are announcement dates, not the date of the court’s entry. A few outcomes rest on weak sources and say so on the page: a proposed judgment, a whistleblower-programme notice, a news article for one date.

• Criminal parallel. The flag is set from release wording. Reading the releases showed 113 flagged records state no criminal case (set to false) and 15 unflagged records report a criminal case on the same conduct (set to true); Eleven more records with a recorded prison sentence but no flag were set to true; about 816 records are now flagged after the outcome research. The flag is still a reading of the release, not a court record.
• Statuses. Five CFTC benchmark-rigging orders recorded as judgments were settled administrative orders.
• Money. The five-banks benchmark order now carries its $1.475 billion total and is marked settled; the money for the Cartu, Aequitas and Agridime matters sits on the record for the final judgment, not on both records; Australian-dollar amounts were removed from the US-dollar fields of five ASIC records; a duplicated $442 million disgorgement on the 2017 Fujinaga appeal record and the overlapping Bank of Nova Scotia record were cleared; Sparkster’s penalty total and Woodward’s alleged gain were corrected.
• Names and tags. Royal Bank is now Royal Bank of Canada, Standard Registrar and Transfer Co., Inc. is one defendant, three names that began “and” were fixed, and the CFTC announcement of eight spoofing actions in 2018 is kept but no longer carries tags or defendants.
• Duplicates noticed, not merged. Several matters appear as two records (for example the two Mark Miller records, Panuwat 2021 and 2024, the Spivak 2015 and 2016 records and the Tadrus pair). They are left as they are and the analysis posts count them once as one matter.

2026-10-03 (source check) — the last six records: Cormark was not an insider-trading case, and Caruso’s co-respondents were cleared

Affected: Caruso (OSC), Candusso (OSC), Cormark (OSC), Swift Trade (FCA), LeadFX (OSC) and CFTC release 8716-23. All 2,428 records are now marked checked.

• Caruso. The record implied a case against all four respondents. The Tribunal’s October 2019 decision found only Cornish liable and dismissed every allegation against Caruso and Sidders; Hutchinson had settled. Cornish’s sanctions (15-year ban, C$300,000 penalty, C$128,000 disgorgement) were added and the ban recorded as his alone.
• Candusso. The record showed C$600,000, which was one respondent’s penalty. The five respondents found liable were penalised C$2.95 million in total, with bans of 3 to 15 years. Claudio Candusso and John Fielding were not found to have traded.
• Cormark. The Commission alleged an illegal distribution and a failure to deal fairly around Canopy Growth’s index inclusion, not insider trading. The Tribunal found none of the allegations proven in November 2024. The insider-trading tag and the status “appealed” were removed (no appeal appears in the decision documents read). The library now holds 632 insider-trading records and 362 with no technique tag; the posts that quote those counts were updated.
• Swift Trade. The tag is confirmed by the Court of Appeal judgment of December 2013, which describes layering on the London Stock Exchange; no change to the record beyond the source.
• LeadFX and release 8716-23. Both are not enforcement actions against a named respondent and carry no tag; they are marked checked as non-cases.

2026-10-03 (policy) — Ponzi sellers keep the Ponzi tag; Cartu binary-options tag confirmed

Records against unregistered sellers or promoters of someone else’s Ponzi product keep the Ponzi tag, because the regulator’s filing describes the scheme as a Ponzi scheme. The Ponzi schemes page now says this. Both Cartu records keep the rigged binary options tag: the CFTC’s body text in each release states that the defendants manipulated the results of some trades. The note at the top of the reverse-merger gatekeepers post was shortened with no change to its figures.

2026-10-03 (addresses) — 551 case page addresses renamed because they named a technique the record no longer carries

Affected: 551 case records. Examples: a record at .../sec-mizuho-securities-usa-llc-front-running-2018/ is now at .../sec-mizuho-securities-usa-llc-2018/; a record whose address said “wash trading” but whose conduct is matched orders now says “matched orders”. The full list of old and new addresses is published in the site’s source repository (src/lib/slug-redirects.json).

• Why. The address of a case page is built from the respondent, the lead technique tag and the year. After the audits removed or changed tags, 551 addresses still named a technique the primary document does not support, which implies a finding the record does not make. Of these, 353 records now carry no technique tag and the technique word is dropped from the address; 198 take their current lead tag.
• What changed. Each record was moved to its new address, and every reference to the old address in posts, technique pages, news digests and this log was updated. Every old address now holds a short “this record has moved” page that names the new address, marks it as the canonical one for search engines and sends the visitor there at once, so links and bookmarks keep working. These are ordinary pages rather than server redirects, so the old address answers 200, not 301.
• What did not change. Record content, titles (already corrected) and case dates are untouched. New records still take the lead tag at the time they are first written, and are not renamed again if a later review changes the tag; the address is a label, and the tags on the page are the record of what the library finds.

2026-10-03 (audit) — all 2,428 records now checked against their primary documents

Affected: every technique group. Round one on 2 October checked 1,045 records; round two on 3 October read 1,377 more, so 2,422 records were marked checked with the date. The last six were read later on 3 October (see the entry below): Caruso (OSC), Candusso (OSC), Cormark (OSC), Swift Trade (FCA), LeadFX (OSC) and CFTC release 8716-23. Detailed entries for each group follow.

The figures below are the reviewers’ own counts, summed here; several are approximate (marked “about”) and a record can be counted under more than one heading.

• What was read. Insider trading, 569 of the remaining records in four lists (143, 141, 143, 142); Ponzi schemes, 441 in three lists (147 each); Rule 105 and naked short selling, 132; the structural group (reverse merger, undisclosed control blocks, free riding, benchmark rigging), 111; and a miscellaneous list of 128 (churning, mismarking, hack to trade, records with no tag, and the smaller techniques). Every record in these lists was opened and compared with its document where the document could be obtained.
• Retagged: about 234. Insider trading 45 (8% of those read); Ponzi schemes 109 (25%); naked short selling 18 of 49 records (37%), with all 83 Rule 105 tags correct; the structural group about 50 (45%), of which about 23 now carry no technique at all; the miscellaneous list 12 (9%).
• Corrected fields. About 450 money figures, about 350 statuses and about 500 defendant names. By group: insider trading about 253 money, 159 status and 147 name fixes; Ponzi schemes about 74 money, 132 status and 248 name fixes; Rule 105 and short selling about 70 money (plus 4 gain fields), 6 status and 22 name fixes; the structural group about 28, 20 and 35; the miscellaneous list 25 (plus 24 alleged-gain fields cleared), 35 and 44.
• Recurring causes. A technique phrase matched in a compliance, disclosure or subpoena release (insider trading on “material nonpublic information” in policy orders; naked short selling on “Regulation SHO” or “locate”); a single “Ponzi-like” clause in a list of uses of money; a reverse merger or control person mentioned as company history; FX notices matched as LIBOR; the first respondent’s figure or a headline total entered for a multi-respondent matter; “judgment” or “settled” read from the verb in a release when only a freeze, a charge, one defendant’s consent or a settlement awaiting court approval was reported; and “et al.”, comma-split or generic strings stored as defendants. Requested bars and injunctions had also been recorded as imposed.
• A surprise in the Ponzi group. Round one’s random sample of 31 Ponzi records found no wrong tag. In round two 109 of 441 lost it, because the reviewers treated a clause-only “Ponzi-like” mention as not charging the conduct. The sample was too small to predict this, and the difference comes mostly from that definition, not from sampling alone.
• Open policy calls. (1) About 12 to 15 unregistered sellers or promoters of other people’s Ponzi products (Woodbridge, EquiAlt, Madison Timber, 1 Global, Stanford, JCS, MJ Capital, Aras) kept the Ponzi tag; whether a seller of a third party’s scheme is a Ponzi-scheme record is undecided. (2) Clause-only mentions were untagged, and 10 to 15 borderline records could go either way; the line was an amount or the lead paragraph. (3) The binary-options call-centre cases were left as they were pending a decision. (4) Knight Capital and CBOE were untagged as naked short selling (market-access controls and exchange system failures), and the same call applies to other exchange and ADR pre-release orders. (5) Barton was moved from insider trading to unregistered distributions. (6) For multi-respondent matters the stored amount is now the sum across the listed respondents.
• Unchecked records. None remain; see the entry on the last six records.
• Techniques that now hold no record. Custodianship shell hijacking, options expiry pinning and dilution death spirals: the records carrying them matched a law-firm custodianship, an exchange expiration alert and an applicant’s phrase, not the conduct. In the structural group more than 23 records lost their technique tag, and the reverse-merger-schemes tag fell from 40 records to 13 in the gatekeepers list. The technique pages still describe the three empty techniques.
• Still being recomputed. The reverse-merger gatekeepers post, and the insider-trading, Ponzi-scheme and Rule 105 statistics in posts and technique pages, are being recomputed from the corrected records and may differ from the case pages until that is done. The keyword rules that caused these errors have not yet been changed.
• A correction to our own correction. The Delaney Equity Group record corrected on 2 October had attached the firm’s $20,000 penalty to the wrong respondent; it belongs to a separate 2016 recordkeeping settlement and is cleared.

2026-10-03 (source check) — insider trading, oldest 143 records: 13 were not insider trading, and nearly half carried the wrong status or money

Affected: ISS, Meade, Wolf, Wolf (decision), Hart, Citigroup Global Markets, Marwood, Federated Global, Grossman, Bar, MDC Partners, Sidoti, and 131 others.

• Policy and disclosure cases tagged as insider trading (13). Compliance or disclosure failures (ISS, Meade, Citigroup, Marwood, Federated, Sidoti), a compliance officer’s altered file (both Wolf records), a chief executive’s misleading press releases (Bar), undisclosed executive perquisites (MDC), a subpoena application (Grossman) and perjury or obstruction charges (Hart, Martin-Caro Sanchez). None found anyone trading or tipping. Tags removed; the second Wolf record had been shown as dismissed, but the judge found violations and declined only sanctions.
• Money (about 60). Prejudgment interest, disgorgement or penalty stated in the order was missing, or one respondent’s figure stood for several (Geist/Taylor, McEnery, Spallina, Khan, Carpenter, Andrade). Cañas Maillard showed a disgorgement from his earlier case; Tamayo showed another defendant’s $1,236,657; Hochtief’s A$400,000 penalty sat in the USD field; Teeple mixed three defendants’ figures (now blank).
• Status (46). Asset freezes, preliminary injunctions, charges and one-defendant partial judgments recorded as judgments or settlements (Xia, Aggarwal, Zhou, Darvasi, Yin); complaints recorded as settled (Cañas Maillard 2015, McPhail, Spivak). Jury verdicts (Berrettini, Payton), ASIC pleas and sentences (Xiao, Hull) and a 2016 McGee consent judgment recorded as unknown, filed or appealed are now judgments.
• Names (51). “et al.”, joined or split names (Hegedus and Shawn C., Peixoto and Jordan, Wolf and Judy K.); the named parties are now listed. Five ASIC records had no defendant.
• Open. Skilling keeps the tag: the release says one criminal count was insider trading, but the SEC’s 2004 complaint was not read.

2026-10-03 (source check) — insider trading, second list of 143 records: 9 retagged, and about 4 in 10 carried wrong money, status or names

Affected: Wm Smith & Co., LBMZ Securities, Deerfield, Cannell Capital, TherapeuticsMD, Fifth Street, Silva, Blakstad, Barton, Napodano, Hayden, Bovorn Rungruangnavarat, and 129 others.

• Compliance and non-trading cases tagged (9). Orders faulting written procedures or disclosure (Wm Smith, LBMZ, Deerfield, Cannell, TherapeuticsMD selective disclosure); Fifth Street is expense allocation and valuation, Silva revenue fraud, Blakstad offering fraud. Barton is a shell-share distribution and is now tagged unregistered distributions. Two subpoena actions (Waymack, Kimmel) charge no one. Tags removed. Williky was given price manipulation.
• One respondent’s figure shown for the case (about 55). LBMZ’s $240,000 penalty sat on the Napodano record; Badin Rungruangnavarat’s $3.2 million and $2 million sat on his brother’s complaint; Hayden, Patel, Kennedy, Sundarraj, Hovannisian, Nall, Special and others showed one respondent’s amount. Amounts are now summed across the settling respondents, or left empty where the release combines disgorgement and interest. Requested bars, and a penalty paid by a different respondent (Carr/Hanratty), were corrected.
• Status (about 27). Matters recorded as judgment, unknown or settled were at the filing stage, or were consent judgments or jury verdicts. Asset freezes (Cluff, Bioverativ, Anadarko) are filed.
• Names (about 28). “et al.” or a spliced string (“Gandra,” or “Corrected Version”) had been stored as a defendant; individual names now.
• Not read. Caruso and Candusso (OSC): the decisions are not cached and the records give no URL.

2026-10-03 (source check) — insider trading, third list of 143 records: 13 tagged it wrongly, and about half carried a wrong name, outcome or amount

Affected: Ares Management, Andeavor, Advanced Practice Advisors, AT&T, App Annie, MIO Partners, Trovias, Willis, Conway, Covington & Burling, Charnas, Virtu, and 131 others.

• Tag removed (13). Policy or controls failures (Ares, Andeavor, MIO, Advanced Practice Advisors, Virtu); disclosure or fraud cases (AT&T Regulation FD, App Annie data misrepresentation, Willis press releases, Lyft related-party disclosure, Trovias selling fake “tips”); and subpoena enforcement actions that charge no trading (Conway, Covington, Charnas). Each now carries no technique.
• Money (about 52). One respondent’s figure for a multi-respondent matter (Hirsch/Friedman, Kendricks/Ettu, Kirsch/Terris, Bohra, Fu/Xu, Pithapurwala, Holzer); another party’s figure (Wang took Chan’s disgorgement; CR Intrinsic took the $601 million compensation fund; Roda took Larkin’s); omitted penalties and interest (Mahan, Waldman, Compton, Holzer 2023, Kelly, Barr).
• Status (about 36). Settlements awaiting court approval, or filed complaints, recorded as judgment or unknown (Jacobs, Barr, Cohen/Rotter, Jun, Brown, Klein, Weiss, Roman, Davis, Dobkin and about twenty more). Bowen (ASIC) stays filed because he was later indicted directly.
• Names (about 45). “et al.” or run-together names split into the actual defendants (Kendricks, Waldman, Hong, Bohra, Nall, Sure, Buyer, Dobkin, Jun and others); eight ASIC records had no defendant name.
• Not read. Cormark Securities (OSC): only the proceeding index page is cached. Kraft (OSC) was checked against the July 2024 sanctions order (C$200,000 and C$150,000 penalties; costs excluded).

2026-10-03 (source check) — insider trading, newest 142 records: ten were not insider-trading cases, and most settled orders had no money or the wrong respondent’s money

Affected: Pirrello, Senvest, FlowPoint, Sound Point, Marathon, Unisys, SogoTrade, Silver Point, Virtu, Willis, Morgan Stanley, Groom, and 130 others.

• Not insider trading (10). Pirrello is a pre-IPO offering fraud (insider trading only as his earlier history). Senvest is off-channel recordkeeping; SogoTrade is anti-money-laundering reporting; Unisys is cybersecurity disclosure; Willis is false statements and Regulation FD. FlowPoint (false audit claims), Sound Point, Marathon, Silver Point (dismissed 4 April 2025) and Virtu are failures to keep policies against misuse of confidential information, with no trading charged. Tags removed.
• Money (about 86). About 85 records had no figure or the wrong one. Cook, Bhandari, Targum and Ruffalo showed one respondent’s amount or a headline total as the disgorgement; Groom’s disgorgement was the settlement total ($28,000 against $12,937); Perez showed one sibling’s combined figure as interest; Morgan Stanley showed one block trade’s profit as the alleged gain and omitted the $83 million penalty. Passi’s $250,000 and many orders’ penalties and interest were missing and are added. Combined figures add each respondent’s stated amount, and the narrative says so.
• Status (50). Consents subject to court approval recorded as judgment, charged cases as unknown, Silver Point as filed although dismissed, Marsico and Chammout as settled while co-defendants litigate.
• Names (23). Comma splices, “et al.” as a name, a title naming the wrong Forlano, a non-respondent in the SogoTrade title. Nourafchan is cut to the two defendants the release names.

2026-10-03 (source check) — Ponzi schemes, first list of 147: 18 carried a tag the document does not support and about 30 had wrong money

Affected: CFTC v. Martin, Martin, Queen Shoals, Quan, Total Wealth Management, Fry, Clark, Klatch, Lunn, Luca International, Garfield Taylor, Summit Trust, and 137 others.

• Tags removed (18). Feeder or adviser to someone else’s Ponzi scheme: Quan (two records), Fry, Total Wealth (Life’s Good), the Martins (customer money passed to Hanson). Earlier scheme as background only: Clark, Klatch. One incidental “Ponzi-like” repayment in a theft or fake-firm case: Riel, Blazer (2016, 2017), Newsholme (2017, 2018), Kolf, Lunn, Chamroonrat (three records), Ikokwu.
• Money (about 30). Luca carried a minor officer’s $25,500 penalty; Garfield Taylor, Summit Trust, Rivera, PMC, Bentley, Aronson, Bogar and Harris carried one defendant’s figure and now carry totals; Fujinaga’s $40 million penalties and $544 million disgorgement and interest were blank; Hicks’s waived disgorgement was entered as owed; Cheryl Jones carried her brother’s 70-month sentence.
• Status (48). Wrong “judgment” or “unknown”: Tagliaferri, Quan and Martin (proceedings only instituted), Illarramendi 2015, Elm, Holzhueter, Torchia, Neman; consent judgments are now “settled”.
• Names and bans. About 100 defendant lists were split strings, “et al.”, residence phrases (“Florida Resident”) or a lone surname. Bans were recorded as imposed on 12 records where the CFTC or SEC only seeks them.
• Kept tagged, open. Unregistered sellers of a third party’s Ponzi product (JCS agents Barnes, Shipley, Peterson; Stanford sellers Bogar, Young, Green; Bartholomew, Hicks, Bryan, Sellers, Gilmond, Cheryl Jones). Weakest kept tags, where “Ponzi-like” appears once among several uses: Diverse Financial, Mogler, Kaplan, FX & Beyond, Chahal (SEC), Iannelli, McAllister.

2026-10-03 (source check) — Ponzi schemes, second list of 147: 58 carried a tag the document does not support, 34 had the wrong status and 23 the wrong money

Affected: Murakami, Goldman, Chiat, Krimm, Bekkedam, Rumbaugh, Mooney, Dalius, Elliott, and 138 others.

• Tags removed (58; 57 emptied, 1 partial). The release says “Ponzi-like payments” or “in the manner of a Ponzi scheme” once, as one use of stolen money, in a fraud headed as something else (hedge fund loss concealment, offering fraud, forex pool fraud, misappropriation). Two were other people’s schemes: Bekkedam sold Rothstein’s; Rumbaugh, Mooney, Wright and Flippen recommended Werth’s and Woods’. Dalius also lost the undisclosed-control-blocks tag (a concealed role, not a share stake).
• Status (34). “Settled” or “judgment” where only one defendant settled or only charges were filed (Goldman, Bramlette, Carpoff, Minuskin, Matthes, Kholamian); “unknown” where a complaint and freeze were reported (16).
• Money (23). Combined disgorgement and interest recorded as disgorgement or twice (Chiat, Pedersen, Burkholz, Elliott 2022); a headline total as penalty (GBI, Ramirez, Clavin 2021); disgorgement plus penalty as disgorgement (Krimm); missing penalties and interest (Spark, NL Technology, Rumbaugh, Vick).
• Names and bars. 85 records had “et al.”, generic or run-together defendants (for example Hitt, Griffithe, Gity). 35 CFTC and SEC records listed a ban or injunction that was only sought; cleared. Seven sentences were added.
• Judgment line, left open. The tag was kept where Ponzi-style payments were a main use of funds (Oasis $28 million of $75 million, Sky Group $19.2 million, Marchi $1.4 million of $2.8 million, Control-Finance); 10 to 15 borderline records could go either way. Twelve unregistered sellers of Woodbridge, EquiAlt, Madison Timber and 1 Global products (Davis/Nilosek, Wieniewitz, Pittsenbargar, Church-Koegel, Tenhulzen, Sears, Wootten, Armijo, McHenry, Billings, Kelly, and Staisil for Merrill) kept the tag. Four slugs carry a stale technique label (paid-stock-promotion in four, benchmark-submission-rigging in one); slugs were not changed.

2026-10-03 (source check) — Ponzi schemes, third list of 147: 33 lost a tag, 50 had the wrong status and 63 had truncated or spliced defendant names

Affected: Kaplan, Russell, Dow Rockwell, Sanaullah, Wells Real Estate, Kawuba, Aras agents, and 140 others.

• Tags removed (33). Ponzi-like payments appear as one clause in a fraud about something else (Kaplan, Russell, Lawrence, McKnight, Verne, Todd, Feloni, Fernandez, Patel, Newell, Gilchrist and others); another party’s scheme (Dow Rockwell, Sanaullah, Wendy Swensen as relief defendant); a follow-on bar reciting a clause (Heckler, Vargas). Wells Real Estate also lost undisclosed control blocks, which was a fraud control person, not a stock block.
• Status (50). Unknown or “judgment” for filed cases, including a TRO-stage case recorded as judgment (Kawuba 2022), and “settled” where only one of several defendants had consented (Forsage, Trade Coin Club, Van Gundy, McKnight, Voyager, Goliath, CryptoFX, Aras).
• Names (63). “et al.”, “Civ. Action”, “Three Puerto Rico Residents”, “Several People”, “Texas Man”, “Relief Defendants” and “a/k/a” strings replaced with the named parties (Forsage 11, CryptoFX 17, Traders Domain 16).
• Money (21). Combined disgorgement and interest entered as disgorgement (Lahr/Megas, Christensen, Stickforth); a penalty doubled for two defendants (Christensen $400,000); Stanford penalties and the Agridime, SLIG, Engel, Horwitz, Chalk, Tadrus and Bryant judgments filled in from the orders. The criminal-parallel marker was cleared on five records that only cited “assistance”.
• Judgment calls, open. The tag was kept where the release gave Ponzi-like payments an amount or put them in the lead, and removed for an unquantified clause in a list (Larrick, Meade, Stickforth, Lam, Griffis, Dencer, Toltec). Sellers of third-party products kept the tag: Ruiz, Gonzalez, Lauer, Conn, Celicourt, and the MJ Capital and Aras agents. Several matters appear in more than one record or group (Rocha 2023/2025, Tadrus in three, Ellison-Meade, Engel, Feloni, Fernandez, Kawuba, Agridime, Aras, Goliath) and are not yet linked.

2026-10-03 (source check) — Rule 105 orders and Regulation SHO matters: all 83 Rule 105 tags correct, 18 of 49 naked-short-selling tags wrong, and 70 records with wrong money

Affected: Nasdaq, CBOE, LavaFlow, Knight, du Pasquier, Nevatia, LaPenna, Orthofix executives, Morgan Stanley, Citadel Securities, ITG, Argosy, and about 120 others.

• Tag removed (18 of 49 naked-short-selling records). The documents charge something else: exchange and system failures (Nasdaq, CBOE, LavaFlow); market-access controls (Knight); adviser compliance (du Pasquier); fraud (Nevatia, LaPenna); accounting (Orthofix executives); order marking only (Morgan Stanley, Citadel Securities); ADR pre-release under Securities Act 17(a)(3) (ITG, Banca IMI, Deutsche Bank Trust, Citibank, BNY Mellon, ICBCFS, Wedbush); Ontario registration terms (Argosy). Titles lost the technique label.
• Money (70 records, plus 4 gain fields). Prejudgment interest or disgorgement was missing on most Rule 105 orders (for example FiveT, now $1,593,295 disgorgement and $357,199 interest). Combined orders were recorded for one respondent: Colak and Kostov are now $420,000, $32,315 and $220,000 (the record held Colak’s alone); Barkley and Davis penalty $75,000 (was $50,000); Murchinson penalty $900,000 (was $800,000). Also: Nasdaq $10 million penalty (the record held its $10.8 million trading profit as the gain); ITG and Banca IMI gain fields held ADR counts as dollars (cleared); Knight’s held “4 million executions” (cleared); CBOE $6 million; Merrill $9 million penalty, $1,566,246 disgorgement and $334,565 interest (the record had interest only); Anson gain $2,469,109. The Candlestick and HITE administrative orders carried the court judgments’ money; they impose only a cease-and-desist, so the money now sits on the litigation-release records alone.
• Names (about 22). Spliced or incomplete: Delaney/Yancey, Johnson, Goldman, Orthofix (the record listed non-respondents), CBOE/C2, Nasdaq (two entities in one), Murchinson, Barkley/Davis, Axius/Robertelli, Pennington/Evans, ASIC (blank), “et al.” on Candlestick and HITE, and omitted co-respondents on 2 West (eight respondents), Nicoletta (four) and M.S. Junior (three). Three entities were typed as individuals.
• Status (6). G-2 Trading 2013 is an order instituting proceedings (filed, not unknown); Delaney 2014 and Wilson-Davis 2016 filed; Merrill settled (was filed); Delaney 2016 judgment (Delaney found liable, Yancey dismissed; it had been “dismissed”); ASIC Tolpigin judgment.
• Judgment calls. Knight and CBOE were untagged. Sycamore Lane, EMS (mismarking caused a locate breach) and BNP Paribas (enabled naked shorting) kept the tag as borderline. Nob Hill and Suttonbrook disgorgement is recorded as ordered although payment is waived. Five recent Rule 105 orders were read from sec.gov because they were not cached.

2026-10-03 (source check) — reverse mergers, undisclosed control blocks, free riding and benchmark rigging: about half of 111 records carried a tag the document does not support

Affected: Perry, China Valves, Anderson/CYIOS, L&L Energy, Muellerleile, Tiber Creek, Shermeta, Reger, Ambassador Capital, UBS (FCA FX), Toronto-Dominion, Hamilton.

• Incidental mention tagged as the conduct (about 50 retagged). About 23 records now carry no technique, among them Perry (Natural Blue consultants; moved to undisclosed control), China Valves, Idle Media, C-Bond, HF Foods, Dipp, Oh and Pappas (disclosure or kickback cases that mention a reverse merger), Citigroup Alternative Investments, BlackRock and the NYSE order (tagged as benchmark rigging), Tomahawk (a coin offering), and Pauciulo and Durante (control person mentioned as background). Anderson lost the tag; L&L Energy is now undisclosed control; Muellerleile is shell factories and undisclosed control; Tiber Creek is shell factories. Roberts and Gilbertson 2015 are subpoena-enforcement releases and were cleared. The reverse-merger-schemes tag falls from 40 records to 13.
• FX and LIBOR confusion. Six FCA FX notices (UBS, Citi, HSBC, JPMorgan, RBS, Barclays) were tagged benchmark submission rigging; they concern FX-fix failures. Toronto-Dominion’s settlement expressly disclaims benchmark manipulation and front running. Plunkett (gold fixing) is now banging the close.
• Money (about 28). Another respondent’s or case’s figure: Perry $75,000 (Corazzi’s 2002 penalty) is now $150,000; Shermeta $6.5 million disgorgement (Reger’s); Reger $250,000 (an instalment) is now $750,000; Pauciulo $490,000 (a third party’s) is now $125,000; DiChiara’s $165 million alleged gain; Bittar and White penalties that were never imposed. Ambassador, Rose, Muellerleile, Tiber Creek, Warren, Stark and others lacked disgorgement or interest; combined totals were entered for Zukowski/Samaras, Esmark, C-Bond, Idle Media, Tobin and Flagg. Manhattan Transfer had interest added and Delaney’s penalty was cleared.
• Status (about 20). Hamilton “dismissed” although orders issued; Weed “dismissed” (judgment); Wey “dismissed” (filed); Bittar, Johnson, Moryoussef, Danziger and White are now judgment; Thurlow, LFS and Dreslin filed (only some defendants settled).
• Names (about 35). Joined or fragmented defendants split (for example Empire/Mokros, ShopEye, Sears, Bodden, Manhattan Transfer).
• Not fully read. Beekmeyer and Bye were checked only through the SEC page summary; the document is not cached.

2026-10-03 (source check) — 128 miscellaneous records (churning, mismarking, hack to trade, smaller techniques and no tag): 12 retagged, two recorded as dismissed when the sanctions stand

Affected: Athena Capital Research, Marcus, Briner, Bresner, Darrigo, Wanger, Cedrone, Kliushin, Koski, LeadFX, and 118 others.

• Wrong tag (12). Athena’s order charges marking the Nasdaq close; a quoted regulator alert had caused the pinning tag. Marcus and Briner (a “money pass” of 1,248 pre-arranged futures trades) were tagged shell hijacking because a law society held a firm in custodianship; they are now matched orders. Fouke (churning only in an indictment recital) and both Hallas records (unsuitability and theft) lost churning. Goodland lost a background reverse-merger tag; Ieremenko lost insider trading; Markusen gained churning; Koski’s fake notices are now fake press releases. Custodianship shell hijacking, options expiry pinning and dilution death spirals now hold no record.
• Non-cases cleared, not verified. LeadFX is a shareholder’s failed application, not enforcement. The CFTC RED List notice names no respondents. The Swift Trade final notice does not describe conduct.
• Status (35). Darrigo and Wanger were shown dismissed: Darrigo’s application to review IIROC’s sanctions was dismissed and Wanger’s re-entry application was denied, so both sanctions stand. Complaints shown as judgments (Iat Hong 2016, Kliushin) and 30 others fixed.
• Money (25, plus 24 gain fields). Bresner showed one respondent’s penalty and another’s disgorgement; Cedrone showed Thoreson’s $75,000 instead of $225,000 across three; Markusen’s $147,000 was commissions. Penalties were missing on Canaccord, Panos, Alexander Capital, Zhu and others. A$ and C$ amounts were moved out of USD fields. Customer deposits stored as alleged gain were cleared on 24 records.
• Names (44). Spliced or generic strings, including Bresner, Royal Alliance, Gibson, Quigley, Cedrone, Kliushin, NanoBit, “Former Deutsche Bank Trader” (Bourne), “Swap Dealer” (Natixis) and “Former Hedge Fund Portfolio Manager” (Rege).
• Posts. The mismarking post cites Brooks, Bourne, Rege, Lumiere, Natixis, Citigroup and Live Well; no mismarking tag was lost, and Live Well is now filed, matching the post’s wording. The binary-options post cites Davis 2019, whose alleged gain was cleared.

2026-10-02 (audit) — 1,045 of 2,428 records now checked against their primary documents

Affected: the case records for eight technique groups: paid stock promotion, wash trading and matched orders, boiler rooms with fake press releases and newsletter scalping, unregistered distributions, insider trading, pump and dump with price manipulation, spoofing and layering, and Ponzi schemes. Each group’s findings are in the separate entries that follow.

• What was read. Each record was opened and compared with its primary document. Paid stock promotion: 129 of 129 records read, 64 (50%) carried a tag the document did not support. Wash trading and matched orders: 132 of 132 read, 53 (40%) lost both tags and 11 more had the two swapped. Boiler rooms, fake press releases and newsletter scalping: 106 read (all but one of 78 boiler-room records, 15 of the fake-press-release records, 14 newsletter-scalping), with wrong tags on 10 of 77 boiler-room records, 1 of 15 fake press releases and 3 of 14 newsletter scalping. Unregistered distributions: 160 of 160 read, 21 (13%) had no Section 5 finding. Pump and dump and price manipulation: 111 of 125 and 109 of 131 read (the remainder were checked by other reviewers during the same pass); the tag was wrong in 18 and 7 records. Spoofing and layering: 128 of 128 read, 36 were not spoofing or layering. Insider trading: about 150 of 725 read, a sample, not the whole group. Ponzi schemes: 147 of 602 read, a sample.
• Sampled groups were not read in full. Insider trading and Ponzi schemes were sampled, so their figures cannot be applied to the whole group. In a random stratified sample of 44 insider-trading records not flagged as suspect, 3 (7%) had a wrong tag and 12 (27%) had some error; of 22 targeted likely false positives, 11 (50%) were wrong, and in a set of 52 selected by a loosened phrase search, 27 (52%) were wrong. In the random Ponzi sample of 31 records, none had a wrong tag, 2 had wrong money (6%) and 10 had a wrong or empty status; of 116 records picked from flags, 20 had a wrong tag. Targeted sets find errors at a much higher rate than random samples, and the unread remainder of both groups probably sits closer to the random figure.
• Recurring causes. A keyword matched in boilerplate or background (guidance lists, a respondent’s history, a quoted comparator case); anti-money-laundering orders that list pump and dump, spoofing, layering or wash trading only as red flags the firm failed to report; the letters “wash” inside “Washington”, and “wash sale” meaning the tax rule; “fictitious” used for invented revenue rather than trading; “spoofed” meaning a phishing email or fake website; annual-results releases keyed to a single respondent and a multi-case figure; another respondent’s figures entered as the record’s own; statuses set to “dismissed” by a partial dismissal or a dropped claim; and older CFTC releases dated a day late.
• The “checked” marker. Each case page now shows whether the record has been checked against its primary document. It means someone read the document and confirmed the technique tag, defendants, money and status against it. It does not mean the record is free of error. Records without the marker (about 57% of the library) have not been read this way and may contain the same classes of error.
• Counts quoted in posts. Counts, totals and shares quoted in blog posts and on technique pages were computed before these corrections. They are being recomputed, and affected posts will be corrected in this log.

2026-10-02 (removal) — thirteen CFTC summaries and notices that were not enforcement actions deleted from the case library

Affected: thirteen records. Five were the CFTC’s annual enforcement-results announcement for fiscal 2013, 2014, 2015, 2016 or 2017, filed under respondent-style names (for example “MF Global” and “Navinder Sarao”) although each announcement summarises many unrelated actions and names no respondent. The other eight were summary-style or non-case records that the audit had retitled: the CFTC’s fiscal 2018, 2019 and two fiscal 2020 reports, a director’s departure, a task-force announcement, a whistleblower alert and a prediction-markets advisory.

• What was wrong. A summary of a whole year’s enforcement is not an action against anyone. The records carried one respondent’s name in their address and, before the audit, aggregate dollar figures from the whole year.
• What changed. The audit had already stripped their tags, defendants and money. The first five were deleted on 2 October and the other eight on 3 October, so the library holds 2,428 records, 1,045 of them marked as checked, and the ingest now refuses to write new ones. The post’s counts are updated again: 162 records carry no technique tag, the CFTC has 338 records and records form 2,194 matters.

2026-10-02 (statistics) — counts and charts in thirteen posts and five technique pages recomputed after the audit, 124 case titles and 91 filing dates corrected

Affected: Spoofing enforcement since 2015, charted, What the enforcement record is made of, Pump and dump has moved to Telegram, Eleven records, one chat group pump, Fourteen front-running records, Nine of twenty-five churning records, Reverse merger gatekeepers, the Hunt brothers, celebrity touting, mismarking, hack-to-trade, short-selling and Rule 105 posts, and the technique pages for analyst manipulation, hack to trade, mismarking, Rule 105 offering shorts and sham tender offers.

• Why. The audit changed tags, money and statuses on hundreds of records, so every figure the library computed for a post was stale. Each figure was recomputed from the case files; figures read from a primary document were left alone.
• Spoofing. Spoofing and layering records fall from 127 to 102, because records where “spoofed” meant something else, and firms charged only with reporting or supervision failures, lost the tag. Recorded penalties now total $873 million rather than $337 million, with a median of $745,000 and a maximum of $436 million (JPMorgan, about half the total); the earlier figures omitted that record’s penalty. The two Bank of Nova Scotia records overlap, so the total double counts part of it, and the post now says so. No spoofing record is now marked dismissed or on appeal.
• What the record is made of. Records tagged only with related-but-distinct techniques are 1,319 (54%), not 1,371 (56%); 948 carry a manipulation tag; 174 carry no technique tag at all, which the post now states. Paid stock promotion falls from 129 to 66 records and wash trading from 107 to 50. Records form 2,207 matters (204 with more than one record, six across more than one agency).
• Telegram and chat-group pumps. Only three records, all one ASIC matter, are now tagged as chat-group pumps; ten were wrongly tagged and the posts say so. One issuer’s figure had been recorded as a promoter’s ($777,000); the record shows $1.63 million in penalties.
• Hunt brothers. The cornering and delivery-squeeze facets hold no records, and the Statoil 2017 settlement-price case replaces a Deutsche Bank record that no longer carries that tag.
• Smaller changes. Analyst manipulation had said it holds no record; it now holds three. Mismarking moves from 15 to 16 records (a former trader booking fictitious internal trades is counted as a marker charged with fraud), hack to trade from 13 to 14, and pump and dump from 125 to 122. All eleven celebrity-touting orders pair disgorgement with a penalty (the post had said ten). The Rule 105 penalty maximum is now OZ Management’s combined order at $4.25 million.
• Front-running post. The post counted seven of fourteen records as genuine front running. On a second reading the number is four: Monness, Crespi, Hardt is a policy-and-procedures failure whose order finds no front running, and the CFTC releases on EOX Holdings and Andrew Gizienski and Classic Energy describe misuse of customer order information rather than trading ahead of an order. The post is rewritten to say so. The EOX record, which had a placeholder “Block Trade Broker” as its only defendant and listed a trading ban the CFTC only seeks, now names both respondents, no longer carries the front-running tag, and records no ban.
• Titles. One hundred and twenty-four case titles ended in a technique label the record no longer carries (“(front running, 2018)” on a record with no such finding); each now shows the lead remaining tag or, where there is none, only the year. Slugs are unchanged.
• Filing dates. The CFTC index shows pre-2018 releases one day later than the release page itself. The ingest now reads the page date, and 91 records had dateFiled corrected (and dateResolved and timeline dates where they matched); 117 more were already right.

2026-10-02 (source check) — paid stock promotion: 64 of 129 records did not describe undisclosed paid promotion

Affected: 129 records read; 64 retagged. Among them Esposito (2016-18), Carnovale (2021-24), Stubos, Moynes, Abujudeh, Aegis Capital, Wilson-Davis and Matin.

• Wrong tag. Records said “paid stock promotion” because a release mentions promoters. About 30 concerned a controller who hired promoters inside a concealed-control or dump scheme (now undisclosed control blocks or pump and dump); about 8 were broker-bribery or kickback matched-trade cases (now price manipulation or matched orders); others were anti-money-laundering cases against broker-dealers (Aegis, Wilson-Davis, Terracciano), subpoena applications (Kon, Forster), a dismissed administrative case (OTC Live), promoters paid to buy rather than publicise (Lonergan), and the 2026 Sun release, in which the promotion claims were dismissed. The tag was kept where the document charges Section 17(b) or alleges concealed payment or payer.
• Wrong money. One respondent’s penalty was recorded for a multi-respondent order: Heimann ($487,616 was one firm’s; the total is $1,250,000), Mikula ($776,932 was one issuer’s; now $1,630,661), Medallion ($3 million, now $4.1 million), Moynes, Giamichael, Catapano, Irth and Thompson/Fung. Missing figures were added for Blotics, ICO Rating, Mason, Cheung, Costello, Mahone, Medifirst, CSIR, Ronk and Aegis. Stubos 2024 repeated George Stubos’s disgorgement for a release about his wife (now $1,775,000). Skerry showed the issuer’s penalty as his.
• Wrong status and names. Contrarian Press 2021 was “dismissed” (only the defunct company was; judgments were entered). Barbera 2020 and Babini 2015 were “judgment” but were complaint filings. Sun 2023 was “settled” while the principal defendants were litigating. Houston American’s defendants were spliced (“John F., Jr. Undiscovered Equities Inc. McKnight”); LR-23303 and Patel had no or wrong defendants; Heimann listed one of four respondents.

2026-10-02 (source check) — 53 of 132 wash-trading and matched-orders records described a different matter, and eleven more had the two techniques swapped

Affected: 132 records read; 64 retagged or detagged. Among them Betterment, Wealthfront, Honeywell, Pyxus, Wells Fargo Advisors, optionsXpress, Wedbush, Daniel Fingerhut, Gregg Smith and Coinsquare.

• Compliance mentions. Six suspicious-activity-report failure orders (Archipelago, Canaccord, Lightspeed, OTC Link, Paulson, SpeedRoute), Wedbush’s market-access order and the OSC RBC/TD foreign-exchange-controls settlements named wash trading only as a red flag. Openmarkets is a surveillance failure. Tags removed.
• Not market conduct. “Wash sale” in Betterment and Wealthfront is the tax rule. “Fictitious sales” in Godwin (two records), Pyxus and Honeywell means invented revenue or a sham consultancy. Wakefield, Rounsville, Palermo, Ramapo, Dohan (auditor discipline) and a dozen CFTC binary-options, Ponzi and customer-fund releases are likewise unrelated. Tags removed.
• Not cases. Five CFTC annual-results releases (filed as MF Global, Sarao, UBS, FY16 and FY17) carried one respondent and unrelated dollar figures. Defendants and money are cleared and they carry no tag.
• Cross trades and boundary. Legal & General, Palmer Square and Morgan Stanley Investment Management are adviser client-cross-trading cases; Cognata’s prearranged trades appear only in his exchange discipline history. Money-pass trades between different owners (Li/Kering, Zhang, Absa/FirstRand, Yu, Bao, Miller) are now matched orders; same-owner trades (SummerHaven, Khorrami, Coinbase) are wash trading.
• Wrong money. Morgan Stanley’s $8 million penalty was missing (only Huang’s $125,000 was shown). Kit Mun Chan 2020 showed one defendant’s disgorgement for five. Fingerhut’s $7 million was the combined figure for four defendants. Gregg Smith’s disgorgement belonged to Peter Miller. optionsXpress had no money ($4.075 million in penalties and $4.23 million in disgorgement per the order). Penalties were missing for Reyes ($160,000), Gu 2021 and 2025, Coinsquare (C$1.9 million), OSC RBC/TD, Rosenthal Collins, Gelber, McLaren and Li. Klein’s £103,700 was a hypothetical fine. Heath’s A$765,000 was a statutory maximum.
• Status, names, dates. Wells Fargo ($5 million, settled) and Dohan were recorded dismissed. Galanis was recorded as judgment. Gotbit and Sun 2026 are proposed settlements. Spliced names were fixed (optionsXpress, Wedbush, Kit Mun Chan, SafeMoon, Dubai). 25 CFTC dates were a day late.

2026-10-02 (source check) — boiler rooms, fake press releases and newsletter scalping: 18 of 106 records carried the wrong tag, 20 a wrong money figure, and 61 a truncated or split defendant name

Affected: 106 records read. Among those retagged or corrected: CFTC fiscal 2014 results summary (deleted), Guarino, Sterling Grace and Casale, McDuff, Anglim, Turbo Global, Fisher Capital, International Enterprise, Advanced Trading Workshop, Deutsche Bank Securities, Mizuho and Oxford City (2015).

• Bystander mentions. MF Global is an annual-results roundup. The documents for Guarino, Casale, McDuff and Anglim mention boiler rooms only as the respondent’s history or someone else’s conduct; Turbo Global’s order recalls a 1999 boiler-room case. The boiler-room tag was removed (Turbo Global is retagged fake press releases, since its charge is false press releases; Anglim is retagged price manipulation).
• Not a security sold by cold-calling. Fisher Capital sold physical coins; ASIC 17-378MR and 18-034MR sold binary-options account packages. Tag removed. CFTC v. International Enterprise (internet binary options with rigged outcomes) is retagged rigged binary options execution.
• Word match. Advanced Trading Workshop’s later name was “Sniper Scalping” (a trading style); Deutsche Bank and Mizuho quote a 1988 list of abuses that includes scalping. Newsletter scalping was removed; Deutsche Bank’s false analyst certification is retagged analyst manipulation, and Mizuho carries none.
• Wrong money. Oxford City’s $495 million “gain” was the company’s own projection, and a $6.6 million figure sat on the stop order instead of the judgment. Bio Defense, Wayland, Wallace, 8000 Inc., Weber, Toon Goggles, Vuuzle and Sodi (2023) carried a combined or other defendant’s figure labelled as interest or penalty, or omitted a penalty. Conde’s $3.3 million belonged to a different action; it is now $3.1 million. Fixed on 20 records.
• Defendants and status. 61 records listed “et al.”, comma-split or truncated names (Hilton/Yurkin was one person). McDuff-style follow-on administrative outcomes, Daniels/Doxey (“dismissed”) and LR-26174 (“dismissed”, though only Ticino was) were corrected.

2026-10-02 (source check) — unregistered distributions: 21 of 160 records carried the tag without a Section 5 finding, and many carried the wrong money, status or names

Affected: 160 records read; the tag was removed from 21. Among them OTC Link, Cambria Capital, COR Clearing, Chardan, Advanced Cell, Sheehan, Coldicutt, Emrich; status and money fixes include Lexington/Pierce, Sason, Dobrovodsky and Bandimere.

• Bystander mention, not a Section 5 charge. OTC Link, Cambria, COR, Chardan and Basmagy are suspicious-activity-report failures; “unregistered distribution” is a red flag in the firm’s own compliance policy. Chang, Woodard, Burke, Spaeth, Smith, Patterson, Coleman, Cleworth and Epic are follow-on bars or reciprocal orders resting on state or foreign findings, or a court judgment. Advanced Cell is a Section 16(a) disclosure case; Biltmore is Regulation SHO plus reporting; Sheehan is a Ponzi figurehead (retagged ponzi schemes); Coldicutt is a subpoena enforcement; Krinos and Lubin 2017 charge fraud only; Emrich rests on a fraud conviction. The tag was removed from all 21; OTC Link also lost layering, spoofing and wash trading, which that order does not support either.
• Wrong status. Glaza (shown dismissed; the judge ordered $318,193 disgorgement, a $110,000 penalty and bars), Lexington/Pierce (shown dismissed; cease and desist plus $2,043,362), Emrich (shown dismissed; Frankfurth was barred) and the May 2024 Nutra Pharma judgments (shown dismissed) now read judgment. Sason (shown dismissed; partial summary judgment, ongoing), Providence, Charlet, Longfin, Epic and others were corrected to filed; Kelley, Rojas, Palmer Martin, Arcturus 2016 and others from unknown or settled.
• Wrong money. Misattributed: Burke’s $5,000 (the state’s penalty), Advanced Cell’s $3.5 million (an earlier case), Dobrovodsky’s $4.9 million (a co-defendant’s), Bandimere’s $4.1 million (Parrish’s), Bergquist’s “$90 million gain” (a token count), BioElectronics’ $650,000 (a superseded judge’s figure), Wedbush’s $165 million gain and Lefkowitz’s waived Peacock figure. Omitted or mislabelled: Skaltsounis, Palmer Martin, Baker, Lorsin, Greenlaw, Apostelos (total shown as interest), Voorhees, Toomey, Underwood, Hudzik, Kramer/Hope and about 20 others.
• Names. About 60 records showed spliced or truncated names (Lubin as “Lubin” and “David”; Merrill Lynch split in two; “et al.” entries). iShopNoMarkup omitted Anthony Knight, against whom the relief ran.

2026-10-02 (source check) — insider trading: in a sample of about 150 of 725 records, wrong tags and wrong outcomes were common, and over half of the high-risk ones were the wrong matter

Affected: about 150 of 725 records read (a sample, not the full group); 44 retagged. Among them Cochran, Horsey, Bermingham, Mathew, Dhanani, Royal Bank of Canada, Charter, Zilkha, Wells Fargo Advisors, S.A.C. Capital Advisors, Artis and Matthew Clark.

• Boilerplate and policy mentions. Four FCA prohibition notices carried the tag only because standard guidance lists “insider dealing”; the conduct is sexual assault, voyeurism, and EURIBOR and LIBOR fixing. RBC’s tribunal settlement lists front running, layering and wash trades as guidance only, and Staff alleged none of them. More than twenty further records concern takeover bids, disclosure, accounting, suspicious-activity reports, Regulation FD or an “insider trading policy”. Tags removed.
• Outcome figures that were not outcomes. Zilkha showed the Division’s requested $2.52 million disgorgement and $120,000 penalty; the judge ordered $250,000. S.A.C.’s record showed earlier settlements recited as background; the order imposes no money. Artis showed analyst Teeple’s $133,000 instead of Artis’s $2.58 million. Dhanani showed British Columbia’s penalty. Clark’s “penalty” was restitution plus disgorgement. Four ASIC records showed statutory maximum fines.
• Wrongly favourable status. Nine of twelve SEC records marked dismissed (a relief defendant, a denied motion, one dropped count) were consent judgments, settlements or initial decisions with sanctions, including Wells Fargo Advisors ($5 million penalty). More than twenty ASIC and OSC records of convicted, sentenced or settled respondents were filed, unknown or dismissed; sentences are now recorded.

2026-10-02 (source check) — pump and dump and price manipulation: 25 records carried a tag the document does not support, and many carried another defendant’s figures or no real defendant name

Affected: 217 records read (111 of 125 pump-and-dump and 109 of 131 price-manipulation, with three in both); 49 retagged. Among them Aegis Capital, Albert Fried, Wilson-Davis, Canaccord Genuity LLC, Vandham, Einstein Investments, Proctor, Mulholland, Brian Hunter, Adam Flavin, Jaberian and Glencore.

• AML failures tagged pump and dump. Aegis, Albert Fried, Wilson-Davis, Canaccord ($20 million), SpeedRoute and Vandham are suspicious-activity-report cases; pump and dump, spoofing or wash sales appear only as red flags the firm failed to report. Tags removed (Vandham keeps naked short selling).
• Investigations and background mentions tagged as the charged conduct. Einstein, NVC Fund, Cherubim and Jeffre James are subpoena-enforcement actions (“has not concluded that anyone has violated the securities laws”); Proctor is a bond offering fraud (pump and dump was only his earlier plea); Mulholland is unregistered sales, and the $5.3 million shown was his 2013 judgment. Med-X and Jetronic cite pump and dump only in argument; Dalmy, McKelvey and Schneider were retagged to what is charged. NMC Health, Redcentric and Kraft (FCA) are misleading-statement or supervision cases; Macquarie’s undertaking is about controls.
• Another defendant’s money. Hunter’s $7.5 million was Amaranth’s (his is $750,000). Flavin’s $1.25 million belongs to an Iowa broker in the same release (his is $125,000). Jaberian carried co-defendant Rajkaran’s disgorgement and 18-month sentence. Glencore’s $1.186 billion was all entered as penalty; it is $865.6 million penalty plus $320.7 million disgorgement. CBA’s A$10 million was ANZ’s and NAB’s. Statutory maximum fines were recorded as penalties (ASIC 14-291, 17-285, Heng), as was a penalty the FCA did not impose on Foley, who was censured.
• Defendant names. Lists collapsed into one name, “et al.” as a name, and anonymised or truncated names: “Two Individuals” (McAfee, Watson), “Commodity Pool Operators” (Glen Point, Neil Phillips), “Florida” (Adam Todd, Digitex), “Co” (Rabobank) and “of Manipulation” (Deutsche Bank); 21 ASIC records had none.
• Status. Settled or convicted matters were shown as dismissed, appealed, filed or unknown (Mawji, Dalmy, Ongkaruck, Morelli, FCA Deutsche Bank).

2026-10-02 (source check) — 36 records tagged spoofing or layering were not spoofing or layering, and 36 carried wrong money

Affected: 128 records read; 36 retagged. Among them CFTC FY2016 results summary (deleted), FY2017 results summary (deleted), FY2019 report (deleted), FY2020 record year (deleted), ANZ, Tillage, Giltman, Sotnikov 2020, Cetera, Archipelago, Royal Bank of Canada and JPMorgan (CFTC).

• “Spoofed” meant something else. Annual-results releases and a director’s departure mention spoofing only in passing. Giltman and Sotnikov concern fake-CD websites that imitated banks. Cambridge, Cetera, KMS and M Holdings are customer-information safeguards cases with a footnote defining a “spoofed” phishing email. Tillage is a forged-email payment diversion.
• Surveillance or reporting failures, not manipulation. ANZ (a surveillance gap), Archipelago, Lightspeed and OTC Link (suspicious-activity reports), Wedbush (market-access controls), and RBC and TD (foreign-exchange supervision, with an express finding of no benchmark manipulation) now carry no tag; layering and wash trading appear only in lists of risks.
• Wrong money. Deutsche Bank Securities recorded $9 million, which is the swap-reporting penalty of its parent in the same release; the spoofing penalty is $1.25 million. JPMorgan had no figures; it is $436,431,811 penalty and $172,034,790 disgorgement. Sarao’s penalty was $38 million, the combined total; it is $25.7 million. Several multi-respondent records held one respondent’s figure (Visionary, Hard Eight, Gola/Brims, Franko, Heraeus, a Chicago prop firm, California, FNY, Vorley/Chanu, Briargate, Lek). Gregg Smith’s $135,788 belonged to another respondent. Annual-results records carried other cases’ figures. 7581-17 recorded a $350,000 penalty on non-prosecution agreements that impose none.
• Wrong status. Krishna Mohan (2019), recorded as dismissed, is a settled order. Milrud (2015) and Sarao (2015), recorded as judgments, are complaints. Five SEC consents awaiting court approval were recorded as judgments; K2 and Lek were unknown or appealed.
• Names and dates. 66 records carried truncated or spliced names (“CFTC Defendants Heet Khara”); 18 older CFTC records were dated a day late.

2026-10-02 (source check) — Ponzi schemes: of 147 records read, 20 carried a tag the document does not support, 12 were wrongly “dismissed” and 47 had wrong money

Affected: 147 of 602 records read (a sample, not the full group). Among those corrected: Bradon Technologies, Solar Income Fund, Paramount Equity, Nova Tech, Feng, TD Bank, BOKF, Morgan Stanley, Palmer and Bandimere.

• Bystander tags removed (20). Gatekeepers of someone else’s scheme (TD Bank, BOKF, Equity Trust, Morgan Stanley, Battoo’s Madoff exposure); another matter’s scheme (Gordon, Beane, Arbab 2022, Montanino, Epic Capital, the 3-14872 auditors); a comparator case or denial (Feng, Bedford, Wilson, and Nova Tech, where the tribunal says no Ponzi was alleged); diversion or disclosure rulings (Bradon, Solar, Paramount, Amato); a quotation (WorldWideMarkets). All now carry no tag.
• “Dismissed” that was not (12 of 13). Six OSC records plus TD Bank, Aequitas 2016, Griffithe, Hitt, Titanium 2026 and 3-14872 were settlements, judgments or bans; a partial dismissal or a dropped penalty claim had set the status. Ten more OSC records shown as filed, unknown or settled were final bans.
• CFTC headline totals entered as penalties (17). “Pay over $X” includes restitution: Saffron’s $32 million is a $1.48 million penalty; Evans’s $17 million is restitution with no penalty.
• Wrong respondent or combined figures (30). Palmer carried National Note’s $51.9 million; Bandimere carried Parrish’s judgment and two spliced co-defendants; Fujinaga’s $580 million was a sum, now split; Merrill, Feldman (DFRF) and Griffithe carried other defendants’ or joint totals; Zada’s $121.7 million mixed disgorgement, interest and penalties.

2026-09-29 (source check) — a reverse-merger tag applied to a gun-jumping case, and two defendant names spliced together

Affected: the case records for Canaccord Genuity Inc. and Delaney Equity Group LLC, David Delaney and Ian Kass; found while fact-checking a new blog post against the 59 records tagged reverse merger schemes.

• Wrong tag, Canaccord. The order’s only mention of a reverse merger is a single background sentence — the unnamed issuer “completed a reverse merger with another company” in December 2011, two years before the conduct actually charged. What the SEC charged was a Section 5(b) violation: Canaccord’s research analyst initiated coverage of the issuer while Canaccord was negotiating its own role in the issuer’s planned stock offering — improperly conditioning the market ahead of an offering, unrelated to how the company went public. Corrected: the reverse-merger-schemes tag is removed and the record now carries no technique tag; its summary and narrative are rewritten to describe the gun-jumping finding.
• Spliced defendant names, Delaney. The order names two individual respondents, David C. Delaney and Ian C. Kass. The record’s defendant list instead showed “David C. Kass” and “Ian C.” — the first two names of one respondent stitched to the surname of the other, and the second respondent’s surname dropped entirely. Corrected throughout the record, including its title.

2026-09-29 (source check) — nine of 25 churning records describe something else, and two carry a misattributed dollar figure

Affected: the case records for NPA Asset Management, Royal Alliance Associates, SagePoint Financial and FSC Securities, Waddell & Reed, Canterbury Consulting, Bennett Group Financial Services and Dawn Bennett, William Quigley, Carla Lea Chastain, American Portfolios Financial Services and American Portfolios Advisors, FCA v. Edward Booth, and William C. Gennity and Rocco Roveccio (2018); found while fact-checking a new blog post against all 25 records tagged churning.

• Reverse churning, not churning. NPA, Royal Alliance/SagePoint/FSC and Waddell & Reed each use “churning” only preceded by “reverse” — charging a wrap fee on an account that traded too little, which this site’s own churning technique page already describes in its FAQ as the mirror image of the conduct the page defines. None of the three states that any customer was traded excessively. Corrected: the churning tag is removed from all three; no separate technique exists in this taxonomy to retag them to, so all three now carry no technique tag.
• Word appears, conduct is something else. Canterbury Consulting’s order charges cherry-picking; its two uses of “churning” describe an unrelated manager’s prior customer complaints at a different firm. Bennett Group/Bennett’s order charges overstated assets under management; its one use of “churning” is background on two of Bennett’s own prior arbitration awards. Quigley’s order charges a fraudulent offering scheme; its one use of “churning” describes a different brother’s disclosure history at an unrelated firm decades earlier. Chastain’s 2023 bar rests partly on an 18-year-old Arkansas state finding of “suitability and churning violations,” never restated as a finding in this order. American Portfolios’ order charges an unsuitable single-product recommendation; both uses of “churning” describe what the firm’s general exam program looked for, and the order states that exam did not review the product at issue. Booth’s FCA notice is an unrelated credit-broker fraud; its one use of “churning” is Booth’s own metaphor about “churning people’s information,” quoted from an interview. Corrected: the churning tag is removed from all six; this taxonomy has no cherry-picking, AUM-overstatement, offering-fraud, or credit-broker-fraud slug, so all six now carry no technique tag.
• Wrong money, Gennity and Roveccio (2018). The record states $225,359 in disgorgement. That figure belongs to Laurence Torres, mentioned in the same SEC release (LR-24108) as an already-settled, separate result; Gennity and Roveccio’s own case was an unresolved complaint at that release’s date, with no disgorgement stated for either of them. Corrected: disgorgement is now blank on this record, and the narrative explains where the $225,359.36 disgorgement, $25,748.02 interest and $160,000 penalty figures actually belong.
• Roveccio’s and Gennity’s separate 2019 judgment records. Each already states disgorgement and prejudgment interest but omitted a $160,000 civil penalty their own litigation releases (LR-24416, LR-24464) state alongside those figures. Corrected: both records now carry penaltyUsd: 160000, verified against each release, which separately confirms both defendants’ judgments were $160,000 each, not a single figure split between them.

2026-09-29 (source check) — six front-running records checked against their primary document; five mistagged, one records a conviction as a dismissal

Affected: the case records for Deutsche Bank Securities Inc., Mizuho Securities USA, ASIC v. UBS Securities, Judy K. Wolf, Sean Wygovsky and Christopher Matthaei and Sergei Polevikov, et al.; found while fact-checking a new blog post against all 14 records tagged front running.

• Boilerplate mistags. The Deutsche Bank Securities and Mizuho orders both concern equity research analysts leaking unpublished views to favoured clients; both cite the same 1988 congressional record describing what Section 15(g) covers “in general” — “insider trading, scalping, and front running” — and neither order alleges DBSI or Mizuho front ran anyone. ASIC’s UBS infringement notices concern crossing-system and principal-trading disclosures; the release’s one mention of front running describes the risk the disclosure rule guards against, not a finding against UBS. Wolf’s initial decision is a books-and-records case about an altered compliance file; “Front Running report” there is the name of an internal surveillance report she used, not conduct she is found to have engaged in. These four records still carry the front-running tag pending a rule fix; none should.
• Wrong money, Deutsche Bank. The record states a $100,000 penalty. The order actually before DBSI imposed $9.5 million; $100,000 is the individual penalty a separate, unrelated order imposed on analyst Charles Grom, cited only in a footnote.
• Wrong case, Wygovsky. The record we hold (LR-25683) charges insider trading ahead of SPAC merger announcements. Its one mention of front running refers to “a lucrative front running scheme” the SEC “previously charged” Wygovsky with in a separate, earlier matter that is not in this library.
• Conviction recorded as dismissal, Polevikov. The record’s status is dismissed. The primary litigation release states a final judgment entered against Polevikov himself, enjoining him and holding him liable for disgorgement, and a parallel criminal conviction with a 33-month sentence. What was dismissed, the same day, was a separate claim against a relief defendant — his wife, named only to recover trading proceeds — not the case against Polevikov. Not yet corrected in the record; flagged here first because a wrongly favourable outcome is this site’s top corrections priority.
• Corrected. All six records above are now fixed, verified independently against each cached primary document. The front-running tag is removed from Deutsche Bank Securities, Mizuho, ASIC v. UBS, Wolf and Wygovsky (no other technique fit UBS’s disclosure failures, so that record now carries no technique tag); Deutsche Bank Securities’ penalty is corrected to $9.5 million; Polevikov’s status is corrected to judgment and his 33-month sentence is now recorded. Separately, while re-reading Wolf’s initial decision to verify the front-running tag, we found her record’s $5 million penalty and $397,110 disgorgement were also wrong — those figures belong to Waldyr Prado’s unrelated default judgment, cited in the same decision. The administrative law judge explicitly declined to impose any sanction on Wolf; her record’s penalty and disgorgement are now blank. Mizuho’s order states a $1,250,000 penalty the record had shown as unextracted; that figure is now recorded too.

2026-09-29 (source check) — ten of eleven records tagged chat group pumps were the wrong matter, and the keyword rule that produced them fired on the bare mention of a messaging platform

Affected: the case records for BarnBridge DAO, Tyler Ward and Troy Murray, Flyfish Club, LLC, J.P. Morgan Securities LLC, Ontario Securities Commission v. Blockratize Inc., Jean-Noël Yves Alba, and both NanoBit records (2024, 2026); the chat group pumps technique page.

The error. The keyword rule matched the bare terms “telegram group”, “discord server”, “chat room pump” and “whatsapp group” anywhere in a release, with no requirement that the group be the mechanism of a pump. Read against their cached primary documents, none of the eight records above describes organisers accumulating a position, announcing a target to a group, and selling into the buying that announcement produces — the definition the technique page states. BarnBridge DAO and Ward/Murray sold $509 million of unregistered crypto bonds and used a Discord server only as one of several investor-information channels alongside Medium and Github. Flyfish Club marketed a $14.8 million unregistered NFT offering partly through Discord. J.P. Morgan’s order is a pure WhatsApp/text recordkeeping-failure case with no manipulation allegation. OSC v. Blockratize is an unregistered binary-options-platform case; none of its five cached documents mentions a chat platform at all. FCA v. Alba concerns due-diligence fraud at H2O Asset Management, and its only WhatsApp references are internal executive-committee messages about concealing a due-diligence failure. Both NanoBit records describe a “relationship investment scam” — scheme participants impersonating financial professionals in WhatsApp groups to build trust before soliciting money into a fake crypto trading platform that never executed a single trade — a confidence fraud, not a coordinated buying campaign. Only the ASX Telegram pump group — recorded across three ASIC releases (24-161MR charged, 25-098MR guilty pleas, 25-315MR sentenced) — actually matches the definition: organisers who “formed a private group on the Telegram app” to “discuss and select penny stocks” before announcing them “to the public Telegram group” and selling into the resulting buying.

The change. The chat-group-pumps tag is removed from all eight records above. BarnBridge DAO and Ward/Murray are retagged unregistered distributions, which their orders’ own Section 5(a)/5(c) findings support directly. Flyfish Club already carried that tag alongside chat-group-pumps and keeps it alone. J.P. Morgan, Blockratize, Alba and both NanoBit records now carry no technique tag — no other slug in this taxonomy fits a recordkeeping failure, an unregistered trading-platform case, a due-diligence fraud, or an impersonation confidence scheme, and we do not force a tag a document does not support. The keyword rule now requires a pump-and-dump signal — “pump”, “dump”, “accumulate”, “artificially inflate/increase” or “coordinated scheme/campaign/buying” — within roughly one sentence of the platform-and-group mention, rather than firing on the platform name alone; re-applying it by hand against all ten records confirms it now excludes the eight false positives while still matching both cached ASIC releases. Full reasoning is in DECISIONS.md §27.

2026-09-20 (technique recovery) — three techniques had no records although the cache held their cases

Affected: the EDGAR filing fraud, social media ramps and short and distort technique pages; What the enforcement record is made of; Is short selling manipulation?; Pump and dump has moved to Telegram; and the counts in Spoofing enforcement since 2015, charted.

• What was wrong. Fourteen of 58 techniques had no record. For three of them the fault was ours: the keyword rules did not match documents the library already held. Nothing was missing from the sources.
• What changed. New rules found ten EDGAR filing fraud records (four matters; all ten were existing false tender offer records that gained a second tag), ten social media ramp records (nine new, one existing) and three short and distort records (one matter). The eleven other empty techniques stay empty; a search of the cache found no genuine match for any of them.
• False positives caught. The first social media rule also tagged two BarnBridge DAO orders (an unregistered offering, not a ramp), a paid-promotion order, a company’s own short-squeeze messaging in a disclosure case and a pump-and-dump complaint where social media was only a distribution channel. Each was excluded by a tighter pattern before publication.
• Library total. The library holds 2,431 records, up from 2,419. What the enforcement record is made of is recomputed: 1,371 records (56%, not 57%) carry only related-but-distinct tags, 1,060 carry a manipulation tag, 269 carry several tags, the SEC has 1,856 records, and eight yearly counts move by one to three. Four columns (2017, 2020, 2022, 2023) had already drifted by one from the case files and are corrected.
• Claims withdrawn. The Telegram and short-selling posts said the social media ramp and short and distort facets were empty; both are updated. The three technique pages described a “worked example with real numbers” that was constructed; each now says so, and each gains a section on what the library’s own records show.
• Not done. The Costello and Beck matters now appear twice, once as before and once as the release that carries the social media tag; as elsewhere in the library, records of one matter are not merged.
• Annual-results roundups removed. Three CFTC records (releases 8613-22, 8822-23 and 9011-24) were the agency’s annual enforcement results summaries, not actions against one respondent, and attributed agency-wide totals to single names, such as a $14.5 billion figure to “FTX”. They are removed and the library now holds 2,428 records (2,247 matters). What the enforcement record is made of, the spoofing posts and the actions-per-year data page are recomputed: 1,057 records carry a manipulation tag, 266 carry several tags, the CFTC has 344 records, and spoofing and layering actions fall from 130 to 127 (penalty total $378m to $337m, 71 to 70 with a penalty).

2026-09-20 (record fixes) — garbled respondent names, one record describing another defendant’s plea, mixed money figures and filing dates

Affected: about 30 case records, chiefly under the hack to trade, Rule 105 offering shorts, sham tender offers, hijacked account ramping and paid crypto market making techniques.

• Names and defendants. “Worldwide Capital, Inc. and and Jeffrey W. Lynn” and “Petrou and Thrasos Tommy” (the respondent is Thrasos Tommy Petrou alone) are corrected, as is the Genesis Advisory record. The Mohamed/Wong record, which held eighteen defendants as one garbled name, now lists all eighteen, the Northern District of Georgia and the release’s “more than $1 million” gain. The EDGAR hacking record (LR-24381) named no defendants and now names the nine; the Zavodchiko, Dubovoy, Radjabli and Anderson records list their actual respondents.
• Wrong record. The “Korchevsky, et al.” record (LR-23610) described Leonid Momotok’s guilty plea, not any Korchevsky matter; it is retitled and rewritten, and its status corrected from settled to filed.
• Money. Ieremenko (LR-24793, LR-24956): each record mixed one defendant’s disgorgement with another’s interest; both now sum the settling defendants (penalties $148,804 and $425,000). Hydrogen: the figures were Hydrogen only and now include Kane and Ostern ($1,242,000 penalty). Radjabli gained its $419,330 penalty, PTG its full $1,470,000, Candlestick and HITE their disgorgement and interest split correctly (the order records had interest folded into disgorgement), Genesis its $140,488 interest, and the HSBC record its $45 million penalty in place of $1,733,838,372. The Anderson record’s $244,835 “disgorgement” was money CYIOS paid Anderson; the decision orders $37,500 disgorgement and $450,000 in penalties against CYIOS and Carnahan and dismisses the proceeding against Anderson.
• Dates. Filing dates that were release dates are now complaint dates for Hydrogen (28 September 2022), Mustapha (22 June 2016), Willner (30 October 2017), Zavodchiko (17 February 2016), the Candlestick and HITE complaints (17 February 2023), the Mohamed and EDGAR complaints, and the five October 2024 paid-market-making records (9 October 2024). The Cassidy, JPMorgan and five-bank CFTC records were a day late (30 May 2013, 16 October 2013, 12 November 2014).
• Status. The EDGAR complaint record (LR-24381) was a judgment and is now filed; the Ieremenko settlements, announced subject to court approval, and the Candlestick and HITE settlements are recorded as settled rather than as judgments.
• Not fixed. About a third of CFTC records appear to carry a filing date one day after the release date; this is under review. Duplicate and mis-tagged records (G-2 Trading 2013 and 2014, Oz Management, Cassidy, Anderson, the Fitbit and PTG scheme groups) are noted for review rather than deleted.

2026-09-20 (source check) — a $1.73 billion “HSBC” penalty that was not HSBC’s, and unsourced claims in older posts

Affected: Hunt brothers and the silver corner, LIBOR and benchmark design, Spoofing enforcement since 2015, charted, The anatomy of a spoofing case and Pump and dump has moved to Telegram.

• HSBC $1.73 billion, wrong. The case record for the CFTC’s HSBC “cash versus derivatives” matter draws on release 8822-23, which is the CFTC’s fiscal 2023 enforcement results summary. That release states a $45 million penalty against HSBC Bank USA; the $1,733,838,372 figure it mentions belongs to a different case. The Hunt and LIBOR posts no longer cite it. The spoofing enforcement post’s penalty table is recomputed without it: 71 actions with a penalty (not 72), total about $378 million (not $2.11 billion), median $600,000 (not $618,000), largest $50 million (not $1.73 billion), mean about $5 million. The teardown’s count of records with no penalty is 59, not 58. The case record itself still needs correcting.
• LIBOR “convictions overturned”. Kept but made specific and sourced: the Second Circuit reversed the LIBOR convictions of two former Deutsche Bank traders in 2022 and the UK Supreme Court quashed the convictions of Tom Hayes and Carlo Palombo in 2025. “Billions in penalties” softened to “large penalties”.
• Hunt brothers, Silver Thursday. The 27 March 1980 date and the January 1980 liquidation-only rules were confirmed against a secondary source, now linked; we did not reach a primary document.
• Telegram pump timings. The “seconds or minutes early” tier lead, the “ninety seconds” peak, the “ten minutes” return and the “$340,000 liquidity pool” had no source and are replaced with unquantified wording, in the text and the timeline figure.

2026-09-20 — our own repair script emptied 31 CFTC penalties, and five record and post errors

Affected: 31 CFTC case records that showed no penalty from 2026-09-17 until today, including the matters against Glencore, Vitol, Navinder Sarao and five banks in the benchmark case; four further case records; and four older blog posts.

The error. On 2026-09-17 we re-ran a repair script to fix a penalty-extraction bug (DECISIONS.md §22). For CFTC records the script re-read only the release body, but the CFTC source takes a penalty from the headline’s “Pay $X” when the body states none. The repair therefore set those 31 penalties to empty, and the penalty charts and every affected case page understated them for three days.

The change. All 31 values are restored, and the repair script now keeps a stored value it cannot re-derive rather than deleting it. Separately, while adding six techniques we found and corrected: the Visium Asset Management order, recorded as dismissed when it is a settled cease-and-desist order with a disgorgement and a penalty; the Robert Westbrook complaint, recorded as a judgment; the Langston Rule 105 judgment, which carried an earlier insider-trading amount instead of its own; and the Mark Burns record, which lacked its $60,000 penalty.

Older posts. Spoofing enforcement since 2015, charted still gave the 103-record figures of June; every number is refreshed to the 130 records now held. The anatomy of a spoofing case post counted 43 records without a penalty where there are 58. Pump and dump has moved to Telegram said the paid stock promotion facet ran to “over 150” records (129) and that the social media ramp and chat group pump “so often appear together”; the library has no social media ramp records, so that claim is withdrawn. The short-selling post said pump and dump had “hundreds” of records (125) and that the short and distort facet was “a fraction of the size” when it is empty. Several older posts carry statements we cannot yet source; they are being checked.

2026-09-10 — 100 accountants and attorneys were recorded as having run schemes their clients ran

Affected: 100 case records, most under the reverse merger schemes and undisclosed control blocks technique pages, naming accounting firms and attorneys including BDO USA, KPMG, Baker Tilly, Friedman LLP and named individual CPAs and lawyers. A further 21 records, mostly Rule 102(e) suspensions duplicating conduct already recorded from a separate litigation release, were also removed.

The error. These were SEC Rule 102(e) orders — proceedings that bar an accountant or attorney from practising before the Commission. Recording one as an enforcement action for the underlying scheme asserted that the professional had engaged in it. Most had not. BDO’s and KPMG’s orders find deficient audit work on financial statements a client company falsified; the scheme was the issuer’s. An attorney whose opinion letters “caused a fraudulent stock lending scheme directed by” a named third party was recorded here as though he had directed it.

The cause. The rule that decides which SEC administrative orders describe misconduct, rather than housekeeping, treated every substantive Rule 102(e) order as an enforcement action without asking what it actually found. A separate source added days earlier, reading initial decisions from the Commission’s administrative law judges, made the opposite mistake: it excluded every 102(e) order, blanket, losing genuine cases such as an accountant found to have personally tipped inside information. Neither had actually distinguished a professional’s own conduct from a finding that their audit or opinion work was deficient in connection with someone else’s.

The change. Both sources now defer to one function’s reading of each order: automatic suspensions following a conviction obtained elsewhere are excluded, as are findings that rest on deficient professional work — auditing-standard or opinion-letter negligence language — with no evidence the professional personally engaged in the underlying violation. Records that do show personal engagement stay: an accountant who tipped a friend to inside information, an attorney who personally authored the false filings rather than failing to catch someone else’s. Fixing this also surfaced a bug that let 84 further records, stale from earlier corrections this session, survive their own reclassification; those are removed too. The corpus falls from 2,479 to 2,293 records. Full reasoning is in DECISIONS.md §20.

2026-09-09 — the “touting” rule was still wrong, and 95 records carried the wrong technique

Affected: the paid stock promotion technique page and every case that was tagged with it in error — 95 records, of which three were removed from the library entirely because promotion was the only technique they had been given.

The error. The keyword rule for paid stock promotion matched the bare term “touting”. It fired on any boast. A CFTC action described a fraudster “touting his hundreds of thousands of dollars in weekly forex trading profits”; another described “touting the safety and security of precious metals investments”; an SEC administrative decision recorded that an accounting firm and its client “openly promoted the product and touted their joint relationship”. None of these is a paid promotion of a security, and every one of them was filed here as one.

The cause, and a correction to the correction below. The entry beneath this one, from 2026-09-08, says the rule “now requires language about compensation for publicising a security”. That was not true. Other terms in the rule were tightened at the time and the bare “touting” was left in place, so the defect that produced that correction survived it. The rule now matches only language naming what was touted and for whose benefit — “touting the stock”, “paid to tout”, “stock promoter”, the Securities Act anti-touting provision — and no longer fires on the verb alone.

The change. The corrected rules were re-run across the whole corpus. Most of the 95 affected records keep an accurate tag they already had: an SEC action headlined “Pump-And-Dump Scheme Touting Technology to End Fracking” is a pump and dump and is now recorded only as one; others are Ponzi schemes, churning, or marking the close. The technique’s case count falls from 230 to 158.

The substituted cases were wrong too. The correction below replaced the Kraft Heinz citation with two others, Notis Global and Empires Consulting. Both were tagged by the same defective rule and neither is a promotion case. The SEC’s own headline for Notis Global reads “Charges Marijuana-Related Company and Executives With Touting Bogus Revenues” — an issuer overstating its revenue, which is structurally the same kind of case as the accounting fraud the correction was made to remove. Empires Consulting is a fake trading bot whose operators sold investments “touting daily profits of one percent”. Under the corrected rule neither carries any technique in our taxonomy, and both records have gone.

Both posts now cite promotion cases that are unambiguously promotion cases, each matching language about payment for publicising a security rather than the verb alone: Friedland, a promoter paid to recommend a stock without disclosing he was paid; Mikula, paid to write bullish articles without disclosing the payments; and Abujudeh. The figures have been corrected to match those records.

What it prompted. A first attempt at the fix replaced “touting” with a list that included “promotional campaign”. That term is common in pump-and-dump releases that involve no paid promoter, and it silently added the tag to about ninety records that had never carried it — the same class of error, in the opposite direction, caught by comparing the count before and after rather than trusting the change. It was removed before publication.

2026-09-08 — a case was described as stock promotion when it was accounting fraud

Affected: Is short selling market manipulation? and Pump and dump has moved to Telegram.

The error. Both posts cited SEC litigation release LR-25195 as a paid stock promotion action carrying a $62 million penalty. It is not a promotion case at all. It concerns accounting irregularities at a large food company, and our classifier had tagged it paid stock promotion because the release states that the company “touted” purported cost savings to the market — the word appearing in an accounting context rather than a promotional one.

The cause. The keyword rule for that technique matched the bare term “touted”. A term that describes conduct in one context and ordinary corporate speech in another is not specific enough to tag on, and the rule now requires language about compensation for publicising a security.

The change. The record was removed from the library when the corrected rules were re-run across the corpus. Both posts now cite actions that genuinely are promotion cases, with their correct figures.

What else it prompted. The same audit found five further rule terms matching boilerplate rather than conduct — including one that tagged any release mentioning a “task force” as settlement price manipulation, because the trade-at-settlement acronym “TAS” sits inside the word “task”. All are fixed, and the reasoning is recorded in DECISIONS.md in the repository.

Last updated October 8, 2026.