The awards arise under the CFTC Whistleblower Program, created by Section 748 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and administered under the Commission’s Whistleblower Rules, 17 C.F.R. pt. 165 (Press Release; Order, p. 1). The program is funded entirely by sanctions paid by violators, and no money is taken from harmed customers (Press Release).

The matter is notable less for its dollar figure than for what the Order explains about Commission practice. It shows how the CFTC weighs a first tipster against claimants who provide more sustained help, when it will excuse a late-filed application, and how narrowly it reads the “unique hardships” factor that can raise an award. The sections below cover the announcement and program basics, the allocation among the five claimants, the deadline waiver for the first filer, the denial of the fifth claimant’s request for a larger share, and the Commission’s treatment of his or her identity-theft claim.

What did the CFTC announce in its $8 million whistleblower award?

The CFTC announced awards totaling more than $8 million to five whistleblowers whose information led to a successful enforcement action against a fraudulent scheme (Press Release). The Director of the Whistleblower Office, Raagnee Beri, said the awardees’ assistance “helped the CFTC bring and complete an enforcement action with a substantial recovery of funds for defrauded investors” (Press Release).

The Commission also described the program’s scale. Since its first award in 2014, the CFTC has paid more than $430 million to whistleblowers, tied to enforcement actions producing more than $3.7 billion in monetary sanctions (Press Release). Eligible whistleblowers may receive between 10 and 30 percent of the monetary sanctions collected, paid from the Customer Protection Fund rather than from harmed customers (Press Release).

Consistent with the confidentiality protections in the Commodity Exchange Act, the CFTC does not disclose the specific enforcement action or the exact award amount (Press Release). The public version of the Order likewise redacts the individual percentages and dollar figures (Order, p. 2).

How did the CFTC allocate the awards among the five whistleblowers?

The Commission divided the award between the whistleblower who first reported the fraud and four others who assisted more extensively (Order, p. 2-4). All five qualified because each voluntarily provided original information that led to the successful enforcement of the Covered Actions, which stem from the same misconduct (Order, p. 2-3).

Claimant 1 filed the tip that led the CFTC to open the underlying investigation but provided limited help afterward (Order, p. 2-3). The Order treats that early reporting as making Claimant 1’s information “more significant” under the award factors in Rule 165.9, 17 C.F.R. § 165.9 (Order, p. 4).

The other four claimants reported before the complaint in the first Covered Action and gave more sustained assistance (Order, p. 2-3). The Order notes that Claimant 2 “appropriately encouraged … others to assist the staff of the Commission” and that Claimant 3 helped in “identifying new and productive lines of inquiry,” while Claimants 4 and 5 conserved Commission resources (Order, p. 3). That sustained assistance was a countervailing factor weighed against Claimant 1’s first-tipster role (Order, p. 4).

The aggregate award and each claimant’s percentage are redacted in the public Order, and the dollar figures remain subject to the monetary sanctions actually collected (Order, p. 2, 4). The more than $8 million total comes from the Commission’s public announcement (Press Release).

Why did the CFTC waive the filing deadline for Claimant 1 under Rule 165.5(c)?

The Commission waived the deadline because Claimant 1 faced “extraordinary circumstances” in trying to file on time (Order, p. 3). Claimant 1’s award application arrived by fax less than an hour after the deadline, and Rule 165.5(c), 17 C.F.R. § 165.5(c), lets the Commission excuse a late filing in such circumstances (Order, p. 3).

The Order finds that Claimant 1 tried diligently to fax the application before and after the deadline but ran into unusual technical difficulties (Order, p. 3). It analogizes the situation to James v. Wilkie, 917 F.3d 1368 (Fed. Cir. 2019), where a claimant placed a benefits application in his mailbox to be postmarked on the deadline but the Postal Service did not pick it up (Order, p. 3).

Why did the CFTC deny Claimant 5’s request for a higher award percentage?

The Commission denied the request because Claimant 5 did not show that he or she deserved a larger share than the Preliminary Determination recommended (Order, p. 4-5). The amount of any award is “in the discretion of the Commission” under Section 23(c)(1)(A) of the Commodity Exchange Act, 7 U.S.C. § 26(c)(1)(A), and the Rule 165.9 factors are not ranked or assigned fixed weights (Order, p. 3).

Claimant 5 argued he or she was “the most significant whistleblower” and so should receive the largest award (Order, p. 4). The Order rejects that premise, explaining that Claimant 1’s information caused the opening of the investigation and supported a higher percentage for that claimant.

The Order grounds that allocation in prior precedent, quoting CFTC Whistleblower Award Determination No. 22-WB-01, 2021 WL 6753648, at 3 (Nov. 22, 2021), that a higher percentage for a first reporter is “appropriate because of the key role that Claimant 1’s information played in causing the Division to open the investigation” (Order, p. 5). The supporting declarations, even as redacted, did not establish that Claimant 5 was the most significant contributor (Order, p. 4).

Did the CFTC treat Claimant 5’s identity theft as a “unique hardship”?

No. The Commission found that Claimant 5’s alleged identity theft was neither a “unique hardship” nor “a result of” his or her whistleblowing, the two requirements in Rule 165.9(b)(2)(vi) (Order, p. 5-8). Claimant 5 pointed to a higher security deposit and the cost of credit monitoring but did not quantify or document those costs (Order, p. 5).

On the first point, the Order reads “unique hardship” to mean harm that is remarkable and characteristic of whistleblowing, such as termination or being blackballed from an industry, not “being the only one of its kind” (Order, p. 6). It contrasts CFTC and SEC matters recognizing job loss and unemployability as unique hardships with the more modest economic harms Claimant 5 described (Order, p. 5-6).

On the second point, the Order finds no causal link between the CFTC’s actions and the alleged identity theft (Order, p. 6-8). It notes that Claimant 5 had publicly posted the relevant information on social media and that the data was not the kind of high-risk, sensitive information, like Social Security numbers, that courts treat as creating a substantial risk of identity theft, citing McMorris v. Carlos Lopez & Assocs., LLC, 995 F.3d 295 (2d Cir. 2021) (Order, p. 6-7).

The Order also treats the mere sequence of events as insufficient, drawing on Daniel v. NPS, 891 F.3d 762 (9th Cir. 2018), where a court held that asserting a theft occurred after a disclosure “does not connect the dots” (Order, p. 7). A footnote adds that the Commission did not disclose any information that could reasonably be expected to reveal Claimant 5’s identity as a whistleblower under Section 23(h)(2), 7 U.S.C. § 26(h)(2) (Order, p. 4, n.3).

For more on this topic and related developments, see our Financial Markets Resource Center‘s overview of whistleblower programs. If you have questions, you can request a consultation.

Frequently Asked Questions

What did George Dowd present at the NBI Family Law Summit?

Mr. Dowd’s session addressed how family law practitioners can detect, value, and divide crypto and digital assets that may go unreported in a divorce. Through a live demonstration, the session covered practical methods for identifying hidden cryptocurrency holdings and overlooked digital assets, then valuing and dividing them during the dissolution process. George Dowd is the primary author of Digital Assets, Cryptocurrencies, and Blockchain (IICLE, 2022) and concentrates on digital asset and financial markets matters. His NBI faculty bio provides further background.

Who presented at the Family Law Summit?

The Family Law Summit brought together practitioners from several firms. Erika E. MacCormac of Winslow McCurry & MacCormac, PLLC served as moderator and led the program’s discussion. The faculty also included Hon. Jeanette A. Irby of Juridical Solutions PLC, Brian L. Sobol of Sobol Family Law PLLC, and Kathryn H. Mickelson of Beermann LLP. The full program agenda is available on the NBI website.

Learn more about crypto and digital assets

For more information on locating, valuing, and dividing cryptocurrency and digital assets, visit the firm’s digital asset resource center at digitalasset.law.

Frequently asked questions

The two moves work together. The index futures give market participants a single, financially settled contract tracking the largest cryptocurrencies by market capitalization, while the move to continuous trading lets participants trade and hedge crypto products at any hour, aligning exchange hours with the around-the-clock nature of crypto markets (Index Futures Release; 24/7 Trading Release). For traders, fund managers, and the futures commission merchants that serve them, the practical effect is broader regulated exposure to the crypto market and the ability to react to price moves on weekends.

This post explains what the Nasdaq CME Crypto Index futures are and when they launch, how the underlying Nasdaq CME Crypto Index is built and overseen, what the shift to 24/7 trading covers, and why both developments matter for the regulated crypto derivatives market.

What are Nasdaq CME Crypto Index futures, and when do they launch?

Nasdaq CME Crypto Index futures are CME Group’s first market-cap-weighted futures contract, set to begin trading on June 8, 2026, subject to regulatory review (Index Futures Release). The contract is offered in both micro-sized and larger-sized versions, which CME presents as a capital-efficient way to gain exposure to the top cryptocurrencies through a single contract (Index Futures Release).

At expiration, the futures settle financially to the value of the Nasdaq CME Crypto Settlement Price Index, which measures the largest and most actively traded cryptocurrencies (Index Futures Release). As of May 14, 2026, the index included bitcoin, ether, SOL, XRP, ADA, LINK, and lumens (Index Futures Release). The contracts will be listed on and subject to the rules of CME (Index Futures Release).

CME described the product as a regulated, broad-based way to hedge or gain exposure to the overall crypto market, and reported that average daily volume across its cryptocurrency suite was up 43% year to date (Index Futures Release).

What is the Nasdaq CME Crypto Index, and how is it governed?

The Nasdaq CME Crypto Index is a multi-asset benchmark that CME added to its regulated cryptocurrency pricing products on February 2, 2026 (Index FAQ). CME describes these indices as standardized, institutional-grade benchmarks that aggregate trade flow from major regulated spot exchanges to produce a reference price (Index FAQ).

The suite includes two related measures. The Nasdaq CME Crypto Index is calculated in real time every second on a 24/7 basis, and the Nasdaq CME Crypto Settlement Price Index is calculated once a day and published at 4:00 p.m. New York time (Index FAQ). The settlement price index is the measure to which the new futures settle (Index Futures Release).

Governance runs through an oversight committee. CME explains that a committee of administrators including CME Group, CF Benchmarks, and Nasdaq reviews the methodology and practice standards to protect the integrity of the indices (Index FAQ). Use of the underlying data requires a Market Data License Agreement, with a separate agreement for derived works (Index FAQ).

What does CME Group’s move to 24/7 cryptocurrency futures and options trading involve?

CME Group launched continuous, 24/7 trading for cryptocurrency futures and options, which went live on Friday, May 29, 2026 (24/7 Trading Release). The exchange described the change as giving global participants always-on access to regulated digital asset risk management tools, bridging the gap between traditional regulated venues and the around-the-clock crypto market (24/7 Trading Release).

Over the first weekend, more than 7,200 cryptocurrency futures and options contracts traded, representing roughly $50 million in notional value, which CME pointed to as evidence of immediate liquidity and demand (24/7 Trading Release). The exchange said the volume drew on both retail and institutional firms (24/7 Trading Release).

The expansion also reached Bitcoin Volatility futures, which became available to trade 24/7 (24/7 Trading Release). CME describes these as regulated products designed to let investors trade their view on the 30-day implied volatility of bitcoin without taking a directional price position (24/7 Trading Release). Tim McCourt, Global Head of Equities, FX and Alternative Products at CME Group, called the always-on model “the next natural evolution for the marketplace” (24/7 Trading Release).

Why do these CME Group developments matter for the regulated crypto derivatives market?

Together, the two developments broaden the regulated tools available for crypto exposure and risk management. The index futures let participants take a single, financially settled position across the largest cryptocurrencies rather than trading individual coins, while the move to 24/7 trading removes the weekend gap between regulated derivatives and the spot market that trades continuously (Index Futures Release; 24/7 Trading Release).

CME tied both moves to rising demand, citing the 43% year-to-date increase in average daily volume across its crypto suite and the activity over the first 24/7 weekend (Index Futures Release; 24/7 Trading Release). Market participants should note that the index-futures launch remained subject to regulatory review as of the May 14 announcement (Index Futures Release).

For background on how regulated digital asset derivatives fit within the wider regulatory framework, see our digital asset resource center overview on digital asset regulation.

For more on this topic and related developments, see our resource center on futures and FX trading conduct at financialmarkets.law. If you have questions, you can request a consultation.

Frequently Asked Questions

The complaint alleges that the plaintiff was induced to send roughly $6.125 million through seventeen wire transfers, after which the defendants froze her account and demanded further payments she describes as bogus “fees” and “taxes” (Complaint, pp. 1, 5). She says she has recovered nothing, while her Trust Wallet still displays a frozen balance of $16,902,204.07 (Complaint, p. 6).

The filing matters because it lays out, in unusual detail, how a “pig butchering” investment scam can move money out of U.S. banks and into accounts abroad, and which legal theories a victim may use to try to recover it. The sections below cover the parties and the platform, how the scheme allegedly unfolded, where the money went, the claims asserted, and the emergency relief requested.

Who are the parties in Yeung v. Long, and what is the Vctzxsha.com platform?

The complaint names one individual, six business or online defendants, and Doe defendants. The lead defendant, Oscar Wenxuan Long, allegedly contacted the plaintiff through LinkedIn on or about June 17, 2025, posing as a former Senior Vice President of Drug Discovery at Genentech with fifteen years of experience who had relocated to Los Angeles (Complaint, p. 4).

Vctzxsha.com is described as a business entity of unknown form that operated an online cryptocurrency trading platform accessible through Trust Wallet (Complaint, p. 3). The complaint alleges Long owned or controlled it, that it held itself out as operating under United States law, and that it was not registered or licensed as a cryptocurrency exchange, broker-dealer, or money transmitter under federal or California law (Complaint, pp. 3-4). The remaining corporate defendants, including DEXOTECH I.T LTD, BIXTECH SMC LTD, RUQTECH SMC LTD, MOVO TECH SMC LTD, and PT PERDAGANGAN DUNIA KATULISTIWA, are alleged to be shell entities used as conduits to launder and conceal the funds (Complaint, p. 5).

How did the alleged cryptocurrency scam unfold?

The complaint describes a relationship that began on LinkedIn, moved to WhatsApp, and then steered the plaintiff to a fake trading platform. Long allegedly built trust through professional-looking posts and messages and used several U.S. phone numbers before pitching Vctzxsha.com as a real-time long/short cryptocurrency platform offering 15% returns per successful trade with near-instant settlement (Complaint, pp. 4-5).

Relying on those representations, the plaintiff says she made seventeen wire transfers totaling about $6,125,000 between August 1, 2025 and February 5, 2026 (Complaint, p. 5). When she tried to withdraw funds on or about January 2, 2026, the defendants allegedly demanded and received a $1.06 million “service fee” and a $1.57 million “short-term capital gains tax” (Complaint, pp. 5-6). They then claimed the account required a “large remittance review” of about ten business days, but the account stayed frozen (Complaint, p. 6). Long allegedly went silent after saying he was in Hong Kong “moving funds back to the U.S.,” and later attempted a follow-on recovery scam by soliciting an additional $2,000 in cryptocurrency for a supposed finance consultant in New York (Complaint, p. 6).

For more on how these schemes are structured, see our resource center overview of pig butchering scams.

Where did the wire transfers go, and how much money is at issue?

The exhibits trace wires from the plaintiff’s Wells Fargo and Citibank accounts to bank accounts in Uganda and Indonesia. The Wells Fargo records show transfers to Ugandan entities at Stanbic Bank Uganda Limited in Kampala, including DEXOTECH I.T LTD (account 9030026711141), BIXTECH SMC LTD (account 9030026637448), RUQTECH SMC LTD (account 9030026940728), and MOVO TECH SMC LTD (account 9030027296865) (Ex. A, C, E; Complaint, p. 4). The Citibank records show transfers to Indonesian recipients, including PT PERDAGANGAN DUNIA KATULISTIWA, at PT Bank Rakyat Indonesia in Jakarta (account 176701000357305) (Ex. I; Complaint, p. 4).

The exhibits also include app screenshots that, according to the filing, show the platform’s “customer service” chat directing the plaintiff to wire money to U.S. individuals and companies at domestic banks (Ex. T, U). Several wire forms list purposes such as “for AI purchase” and “payment for services,” and a number of beneficiary names in the exhibits go beyond the entities named as defendants (Ex. A, O). The complaint alleges the funds were misappropriated and that no legitimate trading platform existed (Complaint, p. 6).

For more on tracing and recovering misappropriated digital assets, see our resource center page on crypto fraud and asset recovery.

What claims and legal theories does the complaint assert?

The complaint pleads seven causes of action against all defendants. They are fraud, conversion, unjust enrichment, violation of California’s Unfair Competition Law (Bus. & Prof. Code § 17200 et seq.), violation of the California Consumer Legal Remedies Act (Civ. Code § 1750 et seq.), breach of contract and the implied covenant of good faith and fair dealing, and civil conspiracy (Complaint, pp. 6-7).

For jurisdiction, the plaintiff invokes diversity of citizenship under 28 U.S.C. § 1332 and federal question jurisdiction under 28 U.S.C. § 1331, the latter tied to claims she says implicate wire fraud and securities laws (Complaint, p. 2). The complaint also alleges the platform operated as an unregistered cryptocurrency platform and money transmitter in violation of the Bank Secrecy Act (31 U.S.C. § 5311 et seq.) and FinCEN regulations, and that it failed to register with FinCEN (Complaint, pp. 3, 6).

What emergency relief is the plaintiff seeking in Yeung v. Long?

The plaintiff asks the court for immediate emergency relief in the form of a temporary restraining order and preliminary injunction freezing all assets traceable to her funds, including cryptocurrency wallets and bank accounts (Complaint, pp. 2, 7). She also requests leave to serve the platform and the Doe defendants by alternative means, including email, LinkedIn, WhatsApp, website contact portals, and blockchain wallet addresses tied to the transactions (Complaint, pp. 7-8).

Beyond the injunctive relief, the prayer seeks compensatory damages of $16,902,204.07 or the amount proven, punitive damages, restitution and disgorgement, attorney’s fees and costs where recoverable, and prejudgment and post-judgment interest (Complaint, p. 8). The plaintiff also demands a jury trial (Complaint, p. 8). The complaint and its exhibits are available on the public docket at CourtListener.

Learn More

For more on this topic and related developments, see our resource center at digitalasset.law. If you have questions, you can request a consultation.

Frequently Asked Questions

This matters because perpetual contracts have, until now, traded almost entirely outside the United States. The statement explains that uncertainty about how these products fit within U.S. law pushed their market overseas, and the CFTC’s aim is to give them a clear, regulated path to develop at home instead (Policy Statement, p. 2; p. 6). The agency released the statement together with an order approving the first U.S. perpetual futures contract, one tied to the spot price of bitcoin, and used the statement to explain how it will handle perpetual contracts on other assets (Policy Statement, p. 1; p. 3, n.4).

This post explains what the CFTC said: why it acted now, how perpetual contracts differ from ordinary futures, the manipulation concerns their design creates, and why the agency wants to review these products before they launch. One point is worth making at the start: the policy statement is guidance, not a binding rule, so it does not change the law or create new legal obligations (Policy Statement, pp. 3-4).

Why did the CFTC issue a perpetual contracts policy statement?

The CFTC acted because the market for these products had developed almost entirely offshore. The statement explains that perpetual contracts “have become a dominant form of crypto derivative trading in global markets,” but that, “given the regulatory uncertainty concerning the appropriate classification of these types of contracts,” the market “has largely developed outside of the United States, with the majority of trading occurring on offshore trading venues” (Policy Statement, p. 2).

The CFTC had spent about a year preparing for this step. On April 21, 2025, Commission staff asked the public for input on trading and clearing perpetual-style derivatives, CFTC Release No. 9069-25, along with a companion request on round-the-clock (24/7) trading, CFTC Release No. 9068-25 (Policy Statement, p. 2, nn.1-2). The statement also points to the President’s Working Group on Digital Asset Markets report of July 30, 2025, which urged the CFTC and the U.S. Securities and Exchange Commission to use their existing authority to give faster, clearer guidance for new derivatives products, including perpetual contracts (Policy Statement, p. 3, n.3).

The bitcoin order issued the same day set the boundaries of the statement. That order let a regulated exchange (a designated contract market) list a perpetual contract tied to the spot price of bitcoin, and the policy statement covers everything the order does not, namely perpetual contracts on other kinds of assets (Policy Statement, p. 1; p. 3, n.4).

How do perpetual contracts differ from traditional futures contracts?

The main difference is simple: a perpetual contract never expires. The statement defines perpetual contracts as “derivative contracts that have no fixed expiration date, and which rely on a periodic funding rate mechanism, rather than a fixed expiration date, to maintain relative price parity with the underlying asset’s spot price” (Policy Statement, p. 2).

An ordinary futures contract stays close to the market price because it expires on a set date. A perpetual contract has no expiration, so it uses a recurring payment between buyers and sellers to keep its price in line. As the statement explains, “When a perpetual contract trades above the spot price, the traders with long positions make payments while the traders with short positions receive payments; and vice versa” (Policy Statement, p. 4). Those payments give traders a reason to trade against any gap between the contract price and the real market price, which pulls the two back together (Policy Statement, p. 4).

In short, the funding rate does the job that an expiration date does for a normal futures contract. The statement calls it a tool that “functions as a replacement to the traditional expiration-based convergence mechanism upon which a futures contract typically relies” (Policy Statement, p. 5).

What concerns do perpetual contracts raise under DCM Core Principle 3?

Because a perpetual contract never expires, it is harder to guard against manipulation, and that is the CFTC’s main concern. Under DCM Core Principle 3 (7 U.S.C. 7(d)(3)), a regulated exchange may list a contract only if it is not easily manipulated. For an ordinary futures contract, regulators mainly need the settlement price to be reliable at one moment, when the contract expires; a perpetual contract has no such moment, so its reference price must stay reliable the entire time it trades (Policy Statement, p. 5).

The statement makes this point directly, connecting the manipulation concern to its decision to require advance review:

Perpetual contracts raise novel and complex questions relating to market structure, customer protection, resilience during periods of market stress, and consistency with the Core Principles applicable to registrants under the CEA. For example, a perpetual contract’s design and characteristics raise important considerations with respect to DCM Core Principle 3, which requires that a DCM list only those contracts that are not readily susceptible to manipulation.⁷ For a traditional, cash-settled futures contract, the susceptibility-to-manipulation analysis directed at the cash settlement reference price is an analysis of one moment in time: the settlement reference price must be reliable at expiry. For a perpetual contract, however, the reference must be reliable at every funding interval, without interruption, for as long as the contract remains active.

It is therefore the Commission’s view that perpetual contracts that reference asset classes that are not contemplated in the Order should be submitted for Commission review and approval pursuant to the voluntary product approval process under Commission Regulation 40.3.

Policy Statement Concerning the Listing of Perpetual Contracts (p. 5)

Why does the CFTC favor Regulation 40.3 review over 40.2 self-certification for perpetual contracts?

The CFTC wants to review these products itself before they go live. Normally, under Regulation 40.2 (17 CFR 40.2), an exchange can certify on its own that a new product follows the law and then list it without waiting for approval. The CFTC decided that perpetual contracts are new and complicated enough that the public is better protected if the agency reviews them first, through the approval process in Regulation 40.3 (Policy Statement, pp. 5-6).

The agency also pointed to the benefits of reviewing products in advance. Advance review, the statement says, “promotes transparency, facilitates engagement between Commission staff and registrants during product development, and provides greater regulatory clarity” for companies trying to bring new products to market responsibly (Policy Statement, p. 6).

The CFTC also signaled that it will treat different assets differently. A footnote calls perpetual contracts on agricultural products “likely particularly ill-suited” to this design, while perpetual contracts on equity securities or narrow-based security indexes “would benefit from review by the Commission and the U.S. Securities and Exchange Commission” (Policy Statement, p. 3, n.5). The agency added that it may revisit perpetual contracts later through separate guidance or a formal rule, but it made no commitment either way for now (Policy Statement, pp. 6-7).

For more on this topic and related developments, see our resource center at digitalasset.law. If you have questions, you can request a consultation.

Frequently Asked Questions

What confidential Google data did Spagnuolo allegedly misappropriate?

The complaint centers on Google’s “Year in Search” results, which it describes as commercially valuable proprietary data. Spagnuolo, identified as “a staff software engineer at Google” since approximately 2014, allegedly “misappropriated confidential and valuable nonpublic information from his employer” and used it to place “Google-related bets on Polymarket, a prediction market platform” (pp. 2, 3).

The complaint emphasizes the data’s sensitivity, explaining that “because the commercial impact of the campaign depends on the element of surprise and the coordinated nature of its public reveal, the top-trending search information is valuable” (p. 3). Access within Google was reportedly limited, and the internal tool through which Spagnuolo viewed the data “bore a banner that stated, in part, ‘Google Confidential’ in red text” (p. 3).

How did the alleged Polymarket scheme work?

The complaint alleges a temporal correlation between Spagnuolo’s access to Google’s internal data and his wagers. Polymarket, a Manhattan prediction marketplace operated by Blockratize, Inc., began offering binary event contracts in October 2025 on who would rank among the most searched people on Google for 2025 (pp. 3-4). After accessing the data on or about October 15, 2025, the AlphaRaccoon account began betting the following day (p. 6).

After the internal leader changed, the complaint states that “by this time, Google’s internal Year in Search data reflected that ‘d4vd’ had replaced Kendrick Lamar as the ‘#1 searched person on Google’ for 2025” (p. 6). Investigators describe wagers structured to exploit that foreknowledge, including approximately $937,688 against Bianca Censori and $509,149 against Donald Trump as the top searched person (p. 6). In total, the account “risked approximately $2,754,092 on approximately 25 Google Year in Search 2025 outcomes that the market treated as unlikely,” and after Google’s December 4, 2025 release it “profited approximately $1.2 million” (pp. 4, 6). A footnote adds that the results page briefly “went live between approximately five and six hours earlier than anticipated” before being taken offline (p. 4, n.1).

How did investigators link the AlphaRaccoon account to Spagnuolo?

Investigators attributed the account to Spagnuolo through cryptocurrency tracing. The complaint describes funds flowing through a swapping service to a payment processor, where transactions “were received by account in the name of ‘Michele Spagnuolo,'” an account opened using an Italian Government identification card (p. 5). The money-laundering count rests on subsequent concealment, including swaps through a decentralized service and a transfer to a service that “adds privacy protection to cryptocurrency transactions through removal of wallet addresses from the blockchain” (p. 7).

The complaint also notes a reputational dimension to the concealment, observing that “after Discord and X communities discussed AlphaRaccoon, and speculated its user was a Google insider, the ‘AlphaRaccoon’ username was removed from the Polymarket account” (p. 7).

Why is this charged as commodities fraud rather than securities fraud?

The lead count rests on the Commodity Exchange Act because the trades are charged in connection with a swap rather than a security. Count One alleges that Spagnuolo used a “manipulative and deceptive device” in contravention of 17 C.F.R. § 180.1, the CFTC’s anti-fraud rule, “knowing that he had obtained material nonpublic information in breach of a duty” (p. 1). That misappropriation theory ties the three counts together, and each count also cites 18 U.S.C. § 3238, the venue provision for offenses committed outside the jurisdiction of any single district (pp. 1-2).

What penalties do the charges carry?

According to the U.S. Attorney’s Office, the Commodity Exchange Act count carries a maximum of 10 years in prison, and the wire fraud and money laundering counts each carry a maximum of 20 years (Press Release). The office, which announced the charges through U.S. Attorney Jay Clayton and FBI Assistant Director in Charge James C. Barnacle, Jr., states the matter is being handled by its Securities and Commodities Fraud Task Force (Press Release). Spagnuolo, described as a 36-year-old Italian citizen residing in Switzerland, was presented before Magistrate Judge Netburn (Press Release).

Anyone facing scrutiny over prediction market trading, digital asset transfers, or the handling of an employer’s confidential information has reason to seek counsel early. To discuss a specific situation with a Chicago attorney, you can request a consultation. For a deeper reference on these issues, see our financial markets resource center.

Key Authorities

• Commodity Exchange Act, 7 U.S.C. §§ 9(1), 13(a)(5)
• CFTC Rule 180.1, 17 C.F.R. § 180.1
• Wire fraud, 18 U.S.C. § 1343
• Money laundering, 18 U.S.C. § 1956
• Extraterritorial venue, 18 U.S.C. § 3238
• Aiding and abetting / principal liability, 18 U.S.C. § 2

Frequently Asked Questions

The agreement matters because event contracts tied to professional hockey now trade on CFTC-regulated exchanges, and both the regulator and the league have an interest in guarding against manipulation, insider trading, and fraud in those markets. The MOU sets up a formal liaison channel and an information-sharing framework, but it creates no legally binding obligations and does not require either side to hand over information (MOU, p. 2).

The sections below describe what the parties agreed to, why they signed, how the MOU connects to prediction markets, and the limits the document places on itself.

What did the CFTC and NHL agree to in the May 2026 MOU?

The MOU is a statement of intent to discuss, cooperate, and exchange information on shared concerns, mainly the integrity of professional hockey and the related event contract markets (MOU, p. 1). It anticipates that cooperation will happen primarily through informal consultations, with other arrangements added as the parties develop them (MOU, pp. 1-2).

Under the cooperation article, representatives of both sides will endeavor to meet as mutually agreed to identify and discuss issues that may affect hockey integrity and the related event contract markets (MOU, p. 2). Each side will also try to share information on request, preferably in writing and routed through designated contacts, while aiming to keep administrative burdens low (MOU, p. 2).

The press release describes the same arrangement in operational terms, explaining that the two sides have committed to share information and coordinate to protect the integrity of both professional hockey and the related event contracts offered on CFTC-regulated exchanges, with each designating representatives who will communicate regularly (Press Release).

Why did the CFTC and the NHL enter into the MOU?

Both organizations share an interest in integrity, and each concluded that cooperation could serve its own mission. The CFTC’s stated mission is to promote the integrity, resilience, and vibrancy of U.S. derivatives markets, and it oversees exchanges, clearing organizations, and intermediaries to protect the public from fraud, manipulation, and other abuses (MOU, p. 1). The NHL works to protect the integrity of professional hockey and public confidence in the league (MOU, p. 1).

The MOU rests on the idea that the integrity of the sport and the integrity of the related event contract markets can each affect the other, which is the common ground the parties built on.

The CFTC and the NHL (collectively, the “Parties”) recognize that discussions, cooperation, and exchange of information concerning issues of common interest, such as maintaining and protecting the integrity of professional hockey and the event contract markets related thereto, both of which may have a direct impact on the integrity of the other, may be beneficial to their respective missions. Accordingly, the Parties enter into this MOU to establish liaisons and facilitate such engagement.

Memorandum of Understanding Between the CFTC and the NHL (p. 1)

In the press release, Chairman Selig described the agreement as a step toward improving data sharing between professional sports leagues and the Commission and toward protecting prediction market participants from insider trading, fraud, and other abuses (Press Release). Commissioner Bettman said the MOU strengthens the league’s existing integrity monitoring and reflects a shared commitment to transparency and oversight (Press Release).

How does the CFTC-NHL MOU relate to prediction markets and event contracts?

The MOU connects to prediction markets because the “event contract markets” it repeatedly references are the regulated prediction market products that let participants trade on the outcome of events, including sporting events (MOU, p. 1). The CFTC framed the agreement as a measure to “maintain fair and transparent prediction markets” alongside protecting the sport itself (Press Release).

Event contracts on sports outcomes raise the same integrity concerns as the underlying games, because non-public information about players, lineups, or officiating could be used to trade unfairly. By creating a channel for the league to flag integrity issues to the regulator, and for the CFTC to do the same, the MOU is meant to help both sides identify and address those risks (Press Release).

For background on how the CFTC approaches these products, see our prediction markets resource page at the Financial Markets Law Resource Center.

Is the CFTC-NHL MOU legally binding, and what limits does it set?

The MOU is not legally binding and creates no enforceable rights. It states that it does not create any legally binding obligations, confers no rights on third parties, and creates no rights enforceable against the parties or their officers or employees (MOU, p. 2). It also does not modify the CFTC’s ability and responsibility to enforce the Commodity Exchange Act and the agency’s regulations (MOU, p. 2).

The document does not override existing law. It does not supersede applicable laws or regulations, including Section 8 of the Commodity Exchange Act (7 U.S.C. § 12) and the Privacy Act of 1974 (5 U.S.C. § 552a) (MOU, p. 2). Neither side is required to create, maintain, or share information, and any decision to share rests in the sole discretion of the providing party (MOU, p. 2).

Information shared under the MOU is treated as confidential and remains the record of the providing party (MOU, p. 3). The MOU also limits how the NHL may circulate CFTC information internally: the league may share it with its Board of Governors and NHL Enterprises, L.P., but not more broadly, for example with the NHL Players Association or the member clubs, unless the CFTC agrees in writing, though both sides expect such agreement when the information relates to an active NHL integrity matter (MOU, p. 3).

Who administers the CFTC-NHL MOU and how long does it last?

Each side named a point of contact to run the relationship. The CFTC designated Tyler Badgley, its General Counsel, and the NHL designated Conal Berberich, Senior Vice President and Deputy General Counsel, with each able to add up to two staff contacts (MOU, p. 4).

The MOU took effect upon signature and remains in place until either party ends it with 30 days’ written notice (MOU, p. 4). It may be amended by written request and the other side’s written concurrence, and information already provided continues to be governed by the MOU’s terms even after termination (MOU, pp. 4-5).

Learn More

For more on this topic and related developments, see our financial markets resource center at financialmarkets.law. If you have questions, you can request a consultation.

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