The 29 January 2018 anti-spoofing announcement

On 29 January 2018 the CFTC announced eight spoofing actions, releases 7682-18 to 7689-18, with a summary release 7681-18. Three banks settled the same day for $30 million, $15 million and $1.6 million. Six individuals, one with a software company, were sued; all five of those outcomes were agreed, with penalties from $0 to $300,000, and none was tried.

Published 2026-10-04 · 11 min read

On Monday 29 January 2018 the Commodity Futures Trading Commission (CFTC) put out nine releases about spoofing, bidding or offering with the intent to cancel before the order executes. One, number 7681-18, was a summary. The other eight, 7682-18 to 7689-18, were the actions: three bank orders that settled that day and five federal court actions against six individuals and a software company. Nine records in this library carry that filing date: the eight actions and the summary. This post reads the releases and the later documents that report how each action ended, and says what the day does and does not show. As with every record on this site, the checking was done by an AI agent, not by a lawyer; the method is in what reading every record found.

The summary and the eight actions

The CFTC’s summary release (7681-18) says the Commission announced, together with the Justice Department and the FBI’s Criminal Investigative Division, criminal and civil actions against three banks and six individuals. The summary lists only the CFTC’s own actions; it describes no criminal charge by name, and the library records it as an announcement, not a case, with no respondents, technique tag or money. The eight actions it summarises are below.

The library dates all eight on 29 January 2018, the day of the announcement. The later releases give the complaints’ own filing dates as 26 January for Flotron and for Vorley and Chanu, and 28 January for Zhao, Mohan and Edge, so “filed on 29 January” is the announcement date, not the court’s. Six individuals, as the summary counts, are Flotron, Vorley, Chanu, Mohan, Zhao and Thakkar; Edge Financial Technologies is a company charged alongside Thakkar.

The three bank orders

The three bank actions are different in kind from the rest. They were administrative orders that filed and settled the charges at once, so the CFTC’s text is a statement of findings, not an allegation. The original releases for these three report findings; the other five report allegations.

Deutsche Bank. The order finds that from at least February 2008 to at least September 2014 Deutsche Bank AG, through certain precious metals traders, ran a scheme to manipulate the price of precious metals futures using manual spoofing techniques on the Commodity Exchange, and, on other occasions, by trading in a manner to trigger customers’ stop-loss orders. The traders are found to have placed large orders they meant to cancel after a smaller order was resting on the other side. It finds that the securities subsidiary, Deutsche Bank Securities Inc., failed to supervise diligently, because its surveillance system flagged specific instances that it did not follow up in most cases. The penalty is $30 million, which the release says was substantially reduced for cooperation and remediation, and the order requires training and controls.

UBS. The order finds that from January 2008 to at least December 2013 UBS, through traders on its spot desk, attempted to manipulate the price of precious metals futures with manual spoofing, and attempted to do the same by trading to trigger stop-loss orders between December 2009 and February 2012. The penalty is $15 million, reduced because UBS reported the conduct itself, cooperated and remediated.

HSBC. The order finds spoofing, not manipulation, by one trader in the New York office, mainly in gold, from 16 July 2011 to August 2014. The penalty is $1.6 million, with a cease-and-desist order and required improvements to training and controls, and the release recognises the bank’s cooperation.

For none of the three did the releases we read say whether the firm admitted or denied the findings. The orders themselves are not linked from the library’s records and we did not find them, so what follows rests on the CFTC’s release text, and the figures above are as the releases state them.

The five court actions: what was alleged, and how each ended

The five federal complaints are allegations in the CFTC’s own words, and the library treats them as such. What each ended with is what the later documents say.

Andre Flotron. The complaint alleges that from about August 2008 to November 2013, as a precious metals trader at an unnamed bank, he placed large orders he meant to cancel, opposite smaller orders he wanted filled, and that in 2008 he taught another trader to spoof. A CFTC release of 7 February 2019 (7867-19) reports a final judgment and consent order of 5 February 2019 in the District of Connecticut: a $100,000 penalty and a one-year trading and registration ban. The order finds, on consent, spoofing and a deceptive scheme through it, and identifies the employer as UBS. Neither release reports the outcome of any criminal case.

James Vorley and Cedric Chanu. The complaint alleges spoofing from May 2008 to at least July 2013 at a large financial institution, in COMEX gold, silver, platinum or palladium futures, and that they spoofed in coordination with others and taught another trader. A CFTC release of 7 April 2022 (8511-22) reports final judgments and consent orders from the Northern District of Illinois: $150,000 each, five-year bans on trading and registering, and cease-and-desist requirements. Note the narrower period: the orders find conduct from about July 2011 to July 2013 at “Bank A”, not from May 2008. The release does not give the date the orders were entered. The library stores $300,000, the sum of both.

Krishna Mohan. The complaint alleges that over roughly three weeks in November and December 2013 Mohan, trading a former employer’s accounts, placed iceberg orders and opposite-side visible orders he meant to cancel, a pattern it puts at about 1,500 times and more than 36,000 instances in the E-mini Dow and E-mini Nasdaq markets. It also alleges documents in his online storage describing spoofing strategies. Those figures are the complaint’s. On 25 February 2019 the CFTC instead issued an administrative order (7877-19) in which Mohan admits thousands of acts of spoofing at a proprietary trading firm between September 2012 and March 2014, is banned for three years and must cease and desist. The order reserves any monetary sanction because he agreed to cooperate, and the federal action was dismissed without prejudice. We did not check whether a sanction was later set. The release adds that he had pleaded guilty in the Southern District of Texas to one count of conspiracy to commit wire fraud, spoofing and commodities fraud, and was awaiting sentencing.

Jiongsheng Zhao. The complaint alleges that from at least July 2012 to at least March 2017 Zhao, in Australia, spoofed the E-mini S&P 500 market, in a pattern it puts at about 2,300 times and 3,100 instances. A CFTC release of 11 June 2021 (8395-21) reports a consent order of 4 June 2021: a five-year trading ban, $21,000 in disgorgement, and cease-and-desist. It finds repeated spoofing on thousands of occasions across the same period. There is no civil penalty. The release also reports that Zhao pleaded guilty to one count of spoofing in a separate criminal action and was sentenced on 4 February 2020; the length of the sentence is not stated. It adds that the CFTC resolved charges against a proprietary trading firm, Propex Derivatives, on 21 January 2020, in connection with his spoofing; that matter has no record here.

Jitesh Thakkar and Edge Financial Technologies. This is the odd one out, because the respondents are alleged to be the toolmakers. The complaint alleges that from October 2011 Thakkar and Edge built a custom trading application for an unnamed trader, “Trader A”, who cooperated with the CFTC, including a “Back-of-Book” function that repeatedly nudged his order back in the queue and cancelled it as soon as any part filled, and that Trader A used it to spoof the E-mini S&P between 30 January and 30 October 2013. On 13 August 2020 the CFTC filed an agreed motion for a consent order against Edge and dismissal of the case against Thakkar, and the court entered the Edge consent order on 14 September 2020. We read that order. It finds Edge liable as an aider and abettor of Trader A’s violations, orders $24,200 in disgorgement and a $48,400 penalty, enjoins Edge, and bars it from selling or holding the application. Edge consented without admitting or denying the allegations, other than jurisdiction and venue. The dismissal of Thakkar rests on the CFTC’s motion; the dismissal order was a separate exhibit that the library’s record did not read, and neither did this post.

The money

The CFTC penalties across the eight actions come to $47,048,400, of which the three banks account for $46.6 million, or about 99%. Disgorgement adds $45,200, from Edge and Zhao. Four cautions.

1. The bank figures were cut, by the CFTC’s own account. All three releases say the penalty was reduced for cooperation, and for UBS also for self-reporting. The size of the discount is not stated, so the $30 million, $15 million and $1.6 million are not what the conduct would otherwise have drawn.
2. The individuals’ sums are small against the banks, and two are not penalties. Zhao’s is disgorgement, and Mohan’s order reserves money, so the chart’s zero is “not yet set”, not “nothing”. The Vorley and Chanu figure is two penalties of $150,000. The Edge figures are the company’s, not Thakkar’s.
3. Nothing is counted twice. The summary record carries no money, so each figure sits on one record only, and we do not add the summary’s text to the other records’ totals.
4. Penalties are not losses. Nothing in these records measures harm to other traders.

The comparison with the larger JPMorgan matter of 2020 is instructive but limited: that order’s penalty alone was $436 million. We draw no conclusion about trend from two matters. For how the sums sit in the whole library, see what sanctions the records show.

The criminal side

The summary says the day was a joint civil and criminal announcement, and each of the eight releases thanks the Justice Department and the FBI for help. The CFTC documents we read give outcomes for only two of the criminal matters: Mohan pleaded guilty in Texas to a conspiracy count and was awaiting sentence in February 2019, and Zhao pleaded guilty to one count of spoofing in Illinois and was sentenced on 4 February 2020, without the sentence being stated. For the three banks, Flotron, Vorley, Chanu and Thakkar, the CFTC releases that we read report no criminal outcome. That is not evidence that there was none, only that these documents do not say, and the library holds no Justice Department document for any of them. The criminal-parallel post explains why a civil record’s reference to a criminal matter is not a record of its result.

What the day established

It established, in three consented orders, that three banks had spoofing by their metals traders found against them on one day. The orders came with training and controls requirements, and the two larger ones with manipulation or attempted manipulation findings alongside spoofing.

It showed the CFTC’s early theory of who is responsible. The release quotes the Enforcement Director saying the Commission would pursue those who teach spoofing, who build the tools and who aid and abet it, as well as those who place the orders. The complaints against Flotron and against Vorley and Chanu allege teaching, and the complaint against Thakkar and Edge alleges tool-building. That is a statement of what the agency said it would do, and the outcomes are the evidence of what it got.

It produced agreed outcomes and no trial. Every outcome the records report was agreed: three bank settlements, three court consent orders (Flotron, Vorley and Chanu, Zhao), one administrative settlement with a cooperator (Mohan), one court consent order against a company (Edge), and an agreed motion to dismiss the claims against Thakkar. No court ruled on a disputed point in these actions.

What it did not establish

• It does not show that spoofing increased in 2018. The date is the day an agency chose to announce. The by-year post counts these eight records in 2018, where they are half of its 16 spoofing records for the year; without them 2018 would show 8. That is a count of announcements, not of conduct.
• Complaints are allegations. The volumes (1,500 patterns, 36,000 instances, 2,300 patterns) are the CFTC’s pleading, and the consent orders found narrower periods or fewer specifics in some cases; Vorley and Chanu are the clearest example.
• No finding on the aiding-and-abetting theory was litigated. Edge consented without admitting or denying it, and the case against the individual developer was dropped on the CFTC’s motion.
• The bank orders were read through releases only. We did not find the orders themselves, so the details of what they say about admissions and individual traders are unverified here.

Every record and the techniques

The records are linked in the table above: the announcement, Deutsche Bank, UBS, HSBC Securities (USA), Mohan, Thakkar and Edge, Zhao, Vorley and Chanu and Flotron. The conduct is explained on the spoofing and price manipulation technique pages; the tags are the library’s reading, since the agency charges statutory provisions. The wider picture is in spoofing enforcement since 2015 and how spoofing gets caught. To report an error, use the link on a record’s page or write to [email protected] with the slug and a link to the document.

Techniques referenced

• Spoofing — Spoofing is placing orders a trader intends to cancel before execution, to create a false impression of supply or demand and move the price toward a smaller genuine order on the other side.
• Price manipulation — Price manipulation is trading intended to create an artificial price — one that does not reflect genuine supply and demand — and it is the general charge a regulator brings when the conduct does not fit a more specific named technique.

Cases referenced

Reviewed October 4, 2026. Spotted an error? Tell us.