--- title: "Regulatory and civil actions: CFTC, SEC and state regulators" language: en canonical: https://dossiertwist.com/dossiers/ftx-trading-ltd/regulatory-actions/ as_of: 2026-10-21 keywords: ["FTX Trading Ltd","FTX.com","FTX Trading Limited","Sam Bankman-Fried","Alameda Research","Paper Bird Inc.","Dotcom Silo","FTX Digital Markets","FTX Europe AG","FTX EU Ltd","FTX Japan","West Realm Shires","FTT","Chapter 11","FTX Recovery Trust","John J. Ray III","Caroline Ellison","Gary Wang","Nishad Singh","CFTC consent order"] --- # Regulatory and civil actions: CFTC, SEC and state regulators **Question.** Which regulators acted against FTX Trading Ltd. and its executives, and how did those cases end? **Answer.** The CFTC sued Bankman-Fried, FTX Trading Ltd., Alameda Research LLC, Caroline Ellison and Gary Wang in December 2022 and Nishad Singh in February 2023. FTX Trading and Alameda, under the debtors' control, consented to an order, entered on 7 August 2024, finding fraud and requiring $8.7 billion in restitution and $4 billion in disgorgement; under a related settlement the CFTC subordinated its own monetary claims to those of victims. Wang's case ended in 2026 with no money penalty and a five-year trading ban running from his initial consent order of December 2022, and, according to the CFTC, Singh did not contest liability. The SEC sued Ellison, Wang and Singh; without denying the allegations, they agreed to injunctions and officer-and-director bars in proposed consent judgments that the SEC filed in December 2025, subject to court approval. Washington State ordered FTX US to stop taking new business in November 2022. ## The CFTC case - Analysis: On 21 December 2022 the Commodity Futures Trading Commission filed an amended complaint in the Southern District of New York (No. 1:22-cv-10503) against Bankman-Fried, FTX Trading Ltd. d/b/a FTX.com, Alameda Research LLC, Ellison and Wang under the Commodity Exchange Act. On 7 August 2024 the court entered a consent order against FTX Trading and Alameda finding that, as a common enterprise, they employed a scheme to defraud FTX customers and made material misrepresentations, presenting customer assets as held in custody and segregated when they were in fact commingled and misappropriated. It orders them, jointly and severally, to pay $8.7 billion in restitution and $4 billion in disgorgement, imposes injunctions and trading and registration bans and requires cooperation in the CFTC's continuing case; under a related settlement the CFTC did not seek a civil penalty, subordinated its claims to victims' and directed disgorgement to a supplemental remission fund. [src-066] [src-027] [src-028] - Documented: On 7 August 2024 the court entered a consent order of permanent injunction and other equitable relief against FTX Trading Ltd. d/b/a FTX.com and Alameda Research LLC. The order finds that the two companies, acting together as a common enterprise, violated Section 6(c)(1) of the Commodity Exchange Act and CFTC Regulation 180.1(a)(1) and (3) by employing a scheme to defraud and engaging in practices that operated as a fraud on FTX customers and others, and that they made material misrepresentations and omissions to customers, presenting customer assets as held in custody and segregated when customer funds were in fact commingled and misappropriated. It orders them to pay, jointly and severally, $8,700,000,000 in restitution and $4,000,000,000 in disgorgement, imposes injunctions and trading and registration prohibitions, and requires their cooperation in the CFTC's continuing litigation. Under a related settlement approved by the Bankruptcy Court, the CFTC agreed not to seek a civil monetary penalty and to subordinate its monetary claims to those of victims, with disgorgement payments to go to a supplemental remission fund for victims. [src-027] [src-028] - Qualification: The CFTC consent order was entered with the consent of FTX Trading Ltd. and Alameda Research LLC without a trial on the merits; they admitted its findings of fact for the purpose of exceptions to discharge in bankruptcy and agreed that the findings would be taken as true in proceedings involving the CFTC, while keeping the right to take other positions in proceedings to which the CFTC is not a party. - Response: FTX Trading Ltd. and Alameda Research LLC, by then under the control of the debtors' management, consented to the order to settle all charges against them without a trial on the merits. - Analysis: The two companies, by then run by the debtors' management, consented without a trial on the merits; they admitted the findings only for exceptions to discharge in bankruptcy and agreed they would be taken as true in proceedings involving the CFTC, keeping the right to take other positions elsewhere. The CFTC charged Singh on 28 February 2023 with fraud by misappropriation and with aiding and abetting the fraud of Bankman-Fried, FTX Trading and Alameda; according to the CFTC he did not contest liability and agreed to a proposed consent order, which was not retained. Wang consented to judgment on liability on 23 December 2022; a supplemental consent order of August 2026, citing his cooperation and criminal sentence, imposed no restitution, disgorgement or penalty but barred him from trading on or subject to the rules of registered entities for five years from the initial consent order of December 2022. [src-027] [src-028] [src-065] [src-066] ## The SEC actions - Analysis: The SEC sued Ellison and Wang on 21 December 2022 (No. 1:22-cv-10794) and Singh on 28 February 2023 (No. 1:23-cv-01691). Its complaint describes Ellison as employed at Alameda from about March 2018, co-chief executive from about October 2021 and sole chief executive from about August 2022, and Wang as co-founder and chief technology officer of FTX and co-founder and 10% owner of Alameda; both were dismissed on or about 18 November 2022. On 19 December 2025 the SEC filed proposed final consent judgments in which, without denying the allegations, the three agreed, subject to court approval, to permanent antifraud injunctions, five-year conduct-based injunctions and officer-and-director bars of ten years for Ellison and eight years for Wang and Singh. The retained records do not show the date the judgments were entered. [src-023] [src-062] ## State action and other proceedings - Analysis: On 22 November 2022 the Washington State Department of Financial Institutions issued a temporary order to cease and desist (No. C-22-3487-22-TD01) under the Uniform Money Services Act against West Realm Shires Services, Inc., d/b/a FTX US, a licensed money transmitter, alleging that as of 10 November 2022 it had suspended payments to customers and prevented transfers and withdrawals; it required the company to stop accepting new business from Washington residents while letting them withdraw their assets. It is a temporary order based on the department's allegations, and no final order was retained. FTX Trading Ltd.'s statement of financial affairs also lists 67 pending legal actions, mostly trademark oppositions and cancellations over FTX marks in at least ten countries, and an intellectual property dispute with Bybit Fintech Limited in Singapore. [src-038] [src-011] - Documented: FTX Trading Ltd.'s statement of financial affairs lists 67 pending legal actions: an intellectual property dispute involving Bybit Fintech Limited before the Singapore High Court (HC/OC 320/2022) and 66 trademark disputes, mostly oppositions and cancellations concerning FTX marks in countries including Paraguay, the United Kingdom, Turkey, Japan, India, Brazil, Vietnam, New Zealand, Argentina and Taiwan, with parties such as Fastrax S.A., The Financial Times Limited, Türkiye Finans Katılım Bankası, Horiba, Swift Media Entertainment and Coinhub Group. [src-011] - Qualification: Doc 2001 (filed 31 July 2023) un-redacts the debtors' schedules and statements; the count is of the rows listed under Question 7. ## Sources - [src-066] Supplemental consent order against Zixiao "Gary" Wang, CFTC v. Bankman-Fried et al., U.S. Commodity Futures Trading Commission, 2026-08-17 - [src-027] Consent order of permanent injunction against FTX Trading Ltd. and Alameda Research LLC, CFTC v. Bankman-Fried et al., No. 1:22-cv-10503 (S.D.N.Y.), U.S. Commodity Futures Trading Commission, 2024-08-07 - [src-028] CFTC release: court orders FTX and Alameda to pay $12.7 billion, U.S. Commodity Futures Trading Commission, 2024-08-08 - [src-065] CFTC charges FTX's former director of engineering Nishad Singh, U.S. Commodity Futures Trading Commission, 2023-02-28 - [src-023] Complaint, SEC v. Caroline Ellison and Zixiao "Gary" Wang, No. 1:22-cv-10794 (S.D.N.Y.), U.S. Securities and Exchange Commission, 2022-12-21 - [src-062] Litigation Release No. 26450: final consent judgments against Ellison, Wang and Singh, U.S. Securities and Exchange Commission, 2025-12-19 - [src-038] Temporary order to cease and desist, No. C-22-3487-22-TD01 (West Realm Shires Services, Inc., d/b/a FTX US), Washington State Department of Financial Institutions, 2022-11-22 - [src-011] Court record source · src-011