The Legal and Economic Implications from Recent UK Spoofing Cases


The authors discuss the FCA’s increased enforcement focus on spoofing cases.

In recent years, the UK Financial Conduct Authority (FCA) has intensified its efforts in securities and commodities markets to detect and pursue the type of disruptive trading behaviour called “spoofing.” This emphasis coincides with a similarly increasing focus by the US Commodity Futures Trading Commission and the US Department of Justice. As of mid-2020, more than forty enforcement actions targeting spoofing had been filed against individuals and companies by US regulators, and more than five had been filed by UK regulators.

Spoofing can take different forms, but usually involves the placing of non–bona fide orders, often of large quantity, on one side of the market while trying to execute a bona fide order on the other side of the market. Once the bona fide order has been executed, the trader quickly cancels the non–bona fide orders.In this article, authors Yan Cao, Marlene Haas, and Greg Leonard of Cornerstone Research and Gregory Mocek of Allen & Overy discuss two early cases of enforcement of spoofing laws by UK authorities that provide guidance in evaluating subsequent conduct: the FCA’s investigation of Michael Coscia and FCA v. Da Vinci Invest Limited.

This article was originally published by the Journal of Financial Compliance in February 2021.

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

The Legal and Economic Implications from Recent UK Spoofing Cases


  • New York

Yan Cao

Vice President

  • Washington

Marlene Haas


  • Washington | London

Greg Leonard

Senior Vice President