Cross-Market Manipulation Allegations: Economic Implications


The authors discuss enforcement actions of cross-market manipulation from recent years and how they may shed light on the evaluation of future matters.

Cross-market manipulation surveillance recently has garnered an increasing share of the international regulatory spotlight. Regulators around the world, including the U.S., are highlighting their continued focus on cross-market manipulation. This type of market abuse is perceived to be more difficult to detect than matters in which the focused conduct is contained within a single market (such as spoofing).

In a cross-market manipulation scheme, traders allegedly place orders or undertake other activity in one product on an exchange or other trading venue with the intent of artificially impacting the related product trading on a different exchange or through a different venue. These related products have prices that are related to or correlated with the economics of the first product, or they may be derivatives linked to the first product.

Enforcement actions of cross-market manipulation from previous years shed light on how future matters potentially can be evaluated. In this article, authors Greg Leonard, Yan Cao, and Marlene Haas discusses two such actions and their economic implications.

This article was originally published by The World Financial Review in June 2022.

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

Cross-Market Manipulation Allegations: Economic Implications


  • Washington | London

Greg Leonard

Senior Vice President

  • New York

Yan Cao

Vice President

  • Washington

Marlene Haas