Market manipulation as a service
The SEC's phrase for a paid offering in which a firm that calls itself a market maker generates artificial trading volume or moves the price of a token on behalf of the token's promoters. The regulator alleged it in its October 2024 complaints against Gotbit, ZM Quant and CLS Global.
Where does market manipulation as a service come up?
This term is used in the following manipulation techniques, each explained in full on its own page.
Enforcement actions involving these techniques
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| SEC v. Gotbit Consulting LLC a/k/a Gotbit Hedge Fund and Fedor Kedrov (paid crypto market making, 2026) | SEC | 2026-08-03 | Paid Crypto Market Making , Wash Trading | — | judgment |
| SEC v. CLS Global FZC LLC (paid crypto market making, 2025) | SEC | 2025-04-17 | Paid Crypto Market Making | $425k | judgment |
| SEC v. Gotbit Consulting LLC a/k/a Gotbit Hedge Fund and Fedor Kedrov (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making , Wash Trading | — | unknown |
| SEC v. ZM Quant Investment Ltd., Baijun Ou a/k/a Eric Ou, and Ruiqi Lau a/k/a Ricky Liu (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making , Wash Trading | — | unknown |
| SEC v. CLS Global FZC LLC and Andrey Zhorzhes (paid crypto market making, 2024) | SEC | 2024-10-09 | Paid Crypto Market Making | — | unknown |