Order and Trade Data Analysis in Recent Spoofing Investigations


In this article from the Journal of Financial Compliance, the authors examine recent spoofing enforcement actions by the UK Financial Conduct Authority.

Data analysis has become an increasingly important part of recent UK Financial Conduct Authority (FCA) market abuse enforcement actions, particularly with respect to spoofing investigations. Absent other evidence of manipulative intent, the FCA may seek to infer such intent from order and trading activity where there appears to be no legitimate explanation for it.

In this article, authors Marlene Haas and Greg Leonard of Cornerstone Research and Oliver Pegden of Clifford Chance examine recent enforcement actions by the FCA in relation to spoofing, and in particular the FCA’s use of trading data analysis to support its findings.

As this article explains, any such inference must be based on sound analysis. There must be clarity around the sample on which an observed pattern is based as well as any sampled trading which does not appear to fit the observed pattern and which might therefore point away from manipulative intent.

This article was originally published by the Journal of Financial Compliance in May 2024.

Order and Trade Data Analysis in Recent Spoofing Investigations


  • Washington | London

Greg Leonard

Senior Vice President

  • Washington

Marlene Haas