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Regulatory Roundup: A Look Back on the 2024 Regulatory Landscape and the Lessons We’ve Learned

Tony Sio
Tony Sio Head of Regulatory Strategy and Innovation

A Look Back on the 2024 Regulatory Landscape and the Lessons We’ve Learned

  

January Edition ->

Analysis: 2024 Global Regulatory Outlook. I comb through regulators’ 2024 goals and plans to identify common themes.

Key Update: The U.S. Securities and Exchange Commission (SEC) approved the first U.S.-listed exchange-traded funds (ETFs) to track bitcoin.  

 


 

February Edition ->

Analysis: Social Media Propelling the Humble Pump-and-Dump Scheme. I dive into how pump-and-dump schemes around the world have evolved to incorporate social media as a key component.

Key Update: The Federal Court of Appeals for the D.C. Circuit heard arguments around the Alpine Securities case that could affect the self-regulatory organization (SRO) model in the U.S. 

 


 

March Edition ->

Analysis: The Many Faces of Wash Trading and How Unregulated Crypto Markets Reveal its Effectiveness in Market Manipulation

Key Update: The European Parliament approved the Artificial Intelligence Act. The act bans certain AI applications that threaten citizens’ rights, places strict restrictions on law enforcement’s use of biometric identification and establishes clear obligations for the use of high-risk systems. 

 


 

April Edition ->

Analysis: An Overview of Recent Updates: The Evolving Regulatory Landscape. The world is ever changing, and this edition looks at how cases I highlighted, like shadow trading, have continued to evolve.

Key Update: The International Organization of Securities Commissions (IOSCO) published its updated Workplan. New workstreams are announced to reflect increased focus on AI, tokenization and credit default swaps, as well as additional work on transition plans and green finance. 

 


 

May Edition ->

Analysis: Spoofing the Front-Runners in Ethereum. In this edition, I explore an incredibly interesting case which pushes the limits of the concept of market manipulation.

Key Update: The Securities and Exchange Board of India (SEBI) introduced guidelines to manage stock price impact from market rumors, including the concept of an unaffected price, aiming to curb artificial stock price fluctuations by requiring companies to verify and respond to rumors triggering material price movements within 24 hours. 

 


 

June Edition ->

Analysis: The Power of Whistleblowing in Safeguarding Markets. The SEC paid $600 million dollars to whistleblowers in one year, and I dive into why they consider it great value.

Key Update: The Bank for International Settlements (BIS) published a working paper analyzing how generative AI, emerging AI agents, and artificial general intelligence will impact finance. 

 


 

July Edition ->

Analysis: Navigating Front-Running. This analysis covers what Front-Running is and how it can be detected. 

Key Update: The South Korean Financial Services Commission (FSC) announced the Act on the Protection of Virtual Asset Users, enforcing rules for virtual asset service providers (VASPs) to safeguard user assets and prevent unfair transaction activities in the virtual asset market.  

 


 

August Edition ->

Analysis: Kitchen Renovations and Market Manipulations. Not every case is a complex billion-dollar scheme. In August’s analysis, I look at a simple price manipulation attempt and its proportionate response.

Key Update: The Danish Financial Supervisory Authority (FSA) published guidance clarifying that entering into confidentiality agreements does not in itself constitute a legitimate reason for postponing the publication of inside information. 

 


 

September Edition ->

Analysis: The Mechanics of Cross-Market Manipulation and Lessons from a Real-World Case. This edition explores the first in a series on cross-market manipulation, a growing concern in global markets.

Key Update: The U.S. Commodity Futures Trading Commission (CFTC) granted approximately $4.5 million in awards to seven whistleblowers for their contributions to successful enforcement actions. The four orders granting awards to a total of seven whistleblowers are the most the CFTC has issued on a single day. 

 


 

October Edition ->

Analysis: Market Manipulation for Hire. What if you created a market manipulation business? Here’s a look at the people who did, and the products and services they offered.

Key Update: The SEC Division of Examinations released its 2025 examination priorities, informing investors and registrants of potential risks in the U.S. capital markets. The 2025 priorities focus on perennial and emerging risk areas, such as fiduciary duty, standards of conduct, cybersecurity, and artificial intelligence. 

 


 

November Edition ->

Analysis: The Union of Hacking and Market Manipulation. A whole new family of financial crime is possible when you combine hacking with securities fraud.

Key Update: The IOSCO published a consultation report reviewing the potential market conduct and integrity issues associated with pre-hedging and set out a series of proposed recommendations of regulators to consider when addressing the risks posed by pre-hedging.

 


 

Capital Markets Regulatory Updates

23 December: The Japanese Financial Services Agency (FSA) published its strategic priorities for July 2024 through June 2025, highlighting its commitment to advancing reforms and continuously reviewing its policy measures and tools. 

18 December: The Bank of England published its Financial Market Infrastructure Report, detailing efforts in maintaining financial stability and fostering innovation through supervision of critical financial infrastructure firms. The report outlines achievements in meeting statutory objectives, implementing new regulatory powers under FSMA 2023, and advancing innovation specifically related to stablecoins and the Digital Securities Sandbox.

17 December: The U.K. Financial Conduct Authority (FCA) is consulting on a proposal for a new type of trading venue – The Private Intermittent Securities and Capital Exchange System (PISCES) – which is intended to let private companies open trading windows for employees and early investors to sell stock.

17 December: The European Securities and Markets Authority (ESMA) released its final report with regulatory technical standards and guidelines ahead of the Markets in Crypto Assets Regulation (MiCA) implementation.

16 December: The Australian Securities and Investments Commission (ASIC) published its annual dashboard outlining regulatory costs by sector and subsector for 2023-24. The total regulatory costs to be recovered by levies across all industry sectors are approximately $328 million.

12 December: The Financial Stability Board (FSB) issued recommendations on data flows and the regulation and supervision of cross-border payments to address frictions in data flows, promote fair competition between bank and non-bank payment service providers, and advance goals outlined in the G20 cross-border payments roadmap.

4 December: The U.S. Commodity Futures Trading Commission (CFTC) announced a record monetary relief exceeding $17.1 billion for fiscal year 2024, comprising $2.6 billion in civil penalties and $14.5 billion in disgorgement and restitution. In FY 2024, the CFTC initiated 58 new actions, including landmark digital asset commodities cases, fraud investigations in voluntary carbon credit markets, manipulation cases across various sectors, and significant compliance matters. 

Fines & Enforcement Actions

The Comisión Nacional de los Mercados y la Competencia (CNMC) fined GESTERNOVA S.A. €6 million and AXPO IBERIA €1.5 million for manipulating the Spanish electricity market. The companies violated REMIT by engaging in quote stuffing and issuing non-genuine orders to gain advantage in executing cross-border sales with France, as revealed through algorithmic trading which aimed to monopolize the order book queue for specific energy products. 

The Monetary Authority of Singapore (MAS) imposed a civil penalty of $2.4 million on a major financial institution for its relationship managers’ (RM) misconduct in 24 OTC bond transactions, where clients were charged spreads above agreed rates due to inaccurate disclosures.

The Autorité des marchés financiers (AMF) Enforcement Committee fined several entities and individuals for disseminating false or misleading information and price manipulation. Fines totaling €4,150,000 were imposed on four legal entities and three individuals, with penalties ranging from €50,000 to €300,000.

The ASIC fined Bit Trade Pty Ltd, the operator of Kraken crypto exchange in Australia, $8 million for unlawfully providing a credit facility to over 1100 customers without a target market determination. The Federal Court found that Bit Trade breached its design and distribution obligations by offering margin extensions without the necessary TMD, resulting in significant financial losses for customers.

A former accountant with Heartland Bank Limited pleaded guilty to insider trading charges brought against him by the New Zealand Financial Markets Authority (FMA). The former accountant traded, and encouraged another individual to hold, Heartland Group Holdings Limited (HGH) shares while holding material information that was not generally available to the public.

The Brazilian Securities and Exchange Commission (CVM) fined an ex-officer at IRB Brazil RE, approximately $3.2 million for stock price manipulation tied to false information about Warren Buffett's interest. The ruling highlighted the ex-officer as the source of misinformation that led to a surge in IRB’s stock and assigned financial motivations linked to bonuses.

The FCA fined a former airline executive £123,500 for trading during restricted periods and failing to disclose his personal trades within the required timeframe. 

A securities trader from Massachusetts was sentenced to 30 days in prison for his involvement in a market manipulation conspiracy spanning several years, operating on U.S. stock exchanges. The trader worked with a group of traders to manipulate securities prices by placing deceptive orders, subsequently profiting from their scheme before canceling the initial orders.

The SEC charged the former CEO of Comtech with insider trading for allegedly selling company shares based on confidential negative earnings information before their public release, avoiding losses of approximately $122,445.

The founder and former CEO of Celsius Network LLC pleaded guilty to commodities fraud and securities fraud related to fraudulent schemes at Celsius, misleading customers about the company's success and manipulating the price of CEL token.

The SEC charged Morgan Stanley Smith Barney LLC for inadequate supervision leading to financial advisors misappropriating millions of dollars from clients. MSSB agreed to a $15 million penalty, undertakings, and a compliance review.

The SEC settled charges with two financial firms for failing to provide accurate securities trading data over several years. Each firm agreed to pay a $900,000 civil penalty, with findings revealing numerous inaccuracies and omissions in their blue sheet submissions.

The SEC charged Deutsche Bank Securities Inc. for failing to file certain Suspicious Activity Reports (SARs) in a timely manner. Deutsche Bank Securities has agreed to pay a $4 million civil penalty to settle the SEC’s charges.

The SEC charged a Florida man for manipulating securities prices in a fraudulent spoofing scheme, netting him over $380,000 in profits. The SEC charged the individual for violating antifraud provisions, resulting in a settlement where he agreed to pay $381,718 in disgorgement, $57,570.48 in prejudgment interest, and a $150,000 penalty.

The SEC charged Tai Mo Shan Limited with misleading investors about the stability of Terra USD (UST). The Commission further charged Tai Mo Shan with offering and selling securities in unregistered transactions by acting as a statutory underwriter with respect to certain of its offers and sales of LUNA, a crypto asset issued by Terraform and offered and sold as a security.

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