A&O Shearman | Government Regulatory Enforcement Blog | Foreign Nationals Charged In International Operation Targeting Wash Trading In Cryptocurrency Markets 
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  • Foreign Nationals Charged In International Operation Targeting Wash Trading In Cryptocurrency Markets 

    04/23/2026

    On March 30, 2026, the United States Attorney’s Office for the Northern District of California announced indictments of ten executives and employees of four cryptocurrency focused financial services firms. The firms purport to make markets in various cryptocurrencies. The indictments flow from an undercover operation by the Federal Bureau of Investigation and Internal Revenue Service Criminal Investigation targeting “wash trading” in cryptocurrency markets. The defendants are charged with implementing fraudulent schemes to inflate trading volumes in cryptocurrencies, resulting in artificially high market prices. If convicted, the defendants face a maximum sentence of 20 years in prison and a fine of $250,000 for each violation of 18 U.S.C. §§ 1343 and 1349.

    Wash trading is a form of market manipulation wherein a person enters into, or purports to enter into, transactions to give the appearance that purchases and sales have been made, thereby exerting upward (or downward) pressure on the price, but without incurring market risk or changing the person’s market position.

    The indictments allege that the defendants conspired to inflate cryptocurrency prices by creating the appearance of significant trading volumes through wash trading. The defendants then allegedly profited from their illicit wash trading by the sale of cryptocurrencies at inflated prices to unwitting investors. According to the indictments:

    The defendants acted as illicit market makers by “wash trading” the cryptocurrency to artificially inflate the trading volume and price. As described in the indictment, wash trading occurs when a single trader, or a number of traders, working in coordination, act as both the buyer and the seller in the same transaction or a series of transactions. This fraudulent trading tactic creates the appearance that these cryptocurrencies have more active, organic trading than really exists, thereby inducing investors to purchase the cryptocurrencies at artificially inflated prices.

    See https://www.justice.gov/usao-ndca/pr/ten-foreign-nationals-charged-international-operation-targetin…

    Global financial markets are aggressively incorporating digital assets into the frame and cryptocurrencies are at the forefront of this transition. As cryptocurrencies become more ubiquitous and available to retain investors, regulators and criminal authorities both within and outside the United States remain focused on ensuring the integrity and safety of these markets, while legislative bodies look to build regulatory structures to govern this still nascent asset class.