Market Manipulation. Search

Penalty estimator

This tool shows the historical distribution of civil penalties for a chosen manipulation technique, drawn from this site's own enforcement records. It is a description of what has happened, not a prediction of what will happen in any particular matter — penalties depend on cooperation, self-reporting, ability to pay and prosecutorial discretion, none of which is in this data.

What this is estimating, and what it is not

The figures come from 556 enforcement actions in this library where a civil monetary penalty was stated in the regulator's own release. For a chosen technique, the tool shows where past penalties actually landed — the median, the middle half of the distribution, and the extremes.

It is not a prediction. Penalties in comparable matters vary enormously, and the factors that drive the variation are largely absent from this data: whether the respondent self-reported, how they cooperated, what they remediated, their ability to pay, whether a criminal matter ran alongside, and how many statutory violations were counted. Two defendants doing very similar things can receive penalties an order of magnitude apart for entirely legitimate reasons.

Why the ratio of penalty to alleged gain is unreliable

The tool reports a median penalty-to-gain ratio where enough records carry both figures, and it should be read with more suspicion than the other numbers. Alleged gain is stated in only a minority of releases, and when it is stated the basis varies — sometimes the profit on the manipulative trades, sometimes the total proceeds of a scheme, sometimes a figure covering conduct broader than the manipulation itself. The sample size for each ratio is shown for that reason.

Why medians rather than averages

Because penalty distributions are extremely right-skewed. A handful of very large institutional settlements sit far above everything else, and they drag any average well above the value a typical action attracts. The median is the number that answers "what does one of these usually cost", and the interquartile range is the number that answers "how much does it vary".

Every technique, with its distribution

The same data the tool uses, rendered in full so the page is complete without JavaScript. Techniques with fewer than three penalty-bearing actions are excluded, because a median of two numbers is not a median.

Civil penalty distribution by technique
Technique Actions Lowest 25th pct Median 75th pct Highest
Insider Trading 120 $6.7k $47.2k $100k $242k $1.7bn
Ponzi Schemes 90 $7.5k $227k $1m $4.9m $5.9bn
Spoofing 63 $48.4k $175k $600k $1.8m $1.7bn
Price Manipulation 49 $35k $1.6m $30m $95.7m $1.7bn
Wash Trading 45 $100k $250k $600k $1.6m $325m
Paid Stock Promotion 40 $3.5k $100k $238k $775k $6m
Unregistered Distributions 33 $15k $50k $150k $750k $37.5m
Benchmark Submission Rigging 24 $250k $2.6m $77.5m $213m $1.4bn
Reverse Merger Schemes 15 $20k $45k $100k $240k $1.5m
Pump And Dump 11 $50k $125k $223k $430k $26.4m
Undisclosed Control Blocks 10 $10k $12.5k $31k $281k $1.6m
Cash Vs Derivatives Schemes 6 $350k $7.6m $33m $89m $1.7bn
Naked Short Selling Debate 6 $22.5k $28.8k $45k $50k $75k
Newsletter Scalping 4 $100k $100k $175k $305k $470k
Matched Orders 4 $30k $82.5k $160k $1.8m $6.5m
Layering 4 $50k $463k $800k $10.3m $38m
Marking The Close 4 $75k $75k $87.5k $130k $220k
Boiler Rooms 4 $10k $77.5k $2.1m $12.4m $37.5m
Front Running 3 $100k $100k $100k $800k $1.5m
FX Fixing 3 $400m $600m $800m $1.1bn $1.4bn
Settlement Price Manipulation 3 $400k $450k $500k $2.3m $4m
Free Riding And Parking 3 $10k $12.5k $15k $27.5k $40k

Underlying data: penalty distribution chart · the full case library as JSON