Cross-Market Manipulation Under the Microscope


The authors discuss illustrative cross-market manipulation enforcement cases and their implications for market participants in the EU, UK and US.

European regulators recently announced plans to step up their focus on cross-market manipulation surveillance under the Market Abuse Regulation (MAR). In a cross-market manipulation scheme, traders are alleged to place orders or to trade in one financial product with the intent of impacting the market of a related product or the same product traded on a different venue. Following a request by the European Commission, the European Securities and Markets Authority (ESMA) published a Consultation Paper on MAR addressing this type of conduct. Among other topics, the Consultation Paper discusses the possibility of establishing an EU framework for cross-market order book surveillance in relation to market abuse. A similar approach has also been put forward by the UK’s Financial Conduct Authority (FCA).

These recent increased cross-market surveillance efforts should be of note to market participants across the EU, UK and US. In this article, authors Marlene Haas and Greg Leonard discuss two early cases of enforcement of cross-market manipulation by UK and US authorities that can provide guidance in evaluating future matters.

This article was originally published by Compliance Monitor in September 2020. This article was reprinted in the London International Disputes Week 2021 blog.

The views expressed herein do not necessarily represent the views of Cornerstone Research.

Cross-Market Manipulation Under the Microscope


  • Washington

Marlene Haas


  • Washington | London

Greg Leonard

Senior Vice President