Regulatory Roundup: Remisier Ramps, Retail Rallies and Regulatory Reprimands

Regulatory Roundup: Remisier Ramps, Retail Rallies and Regulatory Reprimands

Remisiers, dealer representatives, introducing agents and securities representatives are called a variety of names and serve a similar function across many countries. They work for a broker, normally through commission, to bring in clients and trading by forming a distributed relationship-driven sales channel that funnels retail order flow into a broker.

In this month's analysis we’ll examine some of the unique challenges of a remisier model and a recent case that emphasizes market manipulation pretending to be normal retail activity, which is precisely what makes it so effective.

Understanding the Remisier Model and Where it Thrives

A remisier is essentially a trading-world connector because it serves as a registered dealer's representative who brings clients and orders to a brokerage firm. In a day-to-day reality, they often act as the client's main point of contact by helping onboard accounts, passing orders and keeping the relationship running smoothly. Remisiers are usually paid through a commission split, meaning they earn more when their clients trade more.
 

In a day-to-day reality, they often act as the client’s main point of contact by helping onboard accounts, passing orders and keeping the relationship running smoothly. 

The remisier model is pretty common, and Switzerland has the quintessential setup. We see similar setups in other European countries like Luxembourg and Italy. The model is also fairly common in East and Southeast Asia, with similar models in Hong Kong, Singapore and Malaysia. In the U.S., however, it is not common at all. The most similar arrangement is a futures commission merchant (FCM) introducing broker.

Across markets, the common thread lies in the human distribution channel between clients and market access. Brokers value remisiers because they offer a relatively low-cost, easily scalable sales channel. Clients value them because they provide a single point of contact who can guide them through the often obscure trading process.

Bursa Malaysia’s Remisier Manipulation Scheme 

In December last year, Bursa issued an enforcement action against two Remisiers after its market surveillance team detected irregular trading patterns and proactively investigated the activity. There are a few interesting aspects to the case. First, the remisiers failed to disclose that they were acting as representatives for two different brokers. This created a clear conflict of interest and allowed them to spread their activity out, making it harder to detect. Investigators also found numerous instances of trading between accounts handled by a remisier but held across different brokerages.

Most fundamentally, the remisier coordinated trading across their clients' accounts, both through personal relationships with investors and by directly entering orders into those investors’ trading accounts. Some of this activity was traced through IP logging.

With this level of control, they engaged in a 12-month long market manipulation scheme. They repeatedly pushed up the price of a few chosen stocks, cross-traded between accounts to create the false illusion of activity and placed fake orders to layer the book, cancelling them just before they could trade to fabricate demand.
 

They repeatedly pushed up the price of a few chosen stocks, cross-traded between accounts to create the false illusion of activity and placed fake orders to layer the book, cancelling them just before they could trade to fabricate demand.

Bursa responded clearly, publicly reprimanding the individuals, imposing fines and blacklisting them from future activity. The exchange used the case to stress the importance of market integrity and the unique role that remisiers serve in their markets.

The Unique Risk Profile of Remisiers

Although similar in some ways, remisiers have a different risk profile from brokerage dealers. Many of the same incentive challenges exist, as they are generally paid on trading volume, which encourages activity regardless of client need. But remisier-driven manipulation tends to be more retail-activity driven, as the Bursa case illustrates. It often involves coordinated trading across multiple small retail accounts, with smaller order sizes and without access to the same tools that a dealer has, such as direct market access (DMA) or algorithmic trading.

This means that while dealers can exploit their access, speed and scale to manipulate markets, remisiers rely on relationships and their ability to coordinate activity across many smaller accounts. That limitation, however, can make detection harder, because the activity resembles normal retail activity. If dealer-driven manipulation looks like a single shark pushing through the sea, remisier-driven manipulation looks more like a school of sardines moving in sync.
 

If dealer-driven manipulation looks like a single shark pushing through the sea, remisier-driven manipulation looks more like a school of sardines moving in sync.

Old‑School Networks, Modern Market Abuse 

The Bursa remisier manipulation case is a reminder that market abuse isn't always high-tech or high-speed. Sometimes it comes from something much more old-school, like a human distribution network capable of coordinating retail accounts in a way that manufactures demand, shapes price action and creates the illusion of genuine market interest. 


January 2026 Capital Markets Regulatory Updates

22 January 2026: The Bermuda Monetary Authority (BMA) released its 2026 Business Plan outlining its commitment to strengthening Bermuda's regulatory framework through technology‑driven innovation, enhanced transparency and governance, sustainability initiatives, prudent oversight of AI, global regulatory collaboration and improved industry readiness

20 January 2026: The U.S. Commodity Futures Trading Commission (CFTC) Chairman Michael S. Selig announced a shift from enforcement‑led oversight toward tailored rulemaking for crypto, perpetuals and prediction markets, launching the Future‑Proof program and an Innovation Advisory Committee.

19 January 2026: The China Securities Regulatory Commission (CSRC) outlined 2026 priorities at its annual work conference, pledging to prevent sharp market swings while deepening reforms across ChiNext, STAR, the Beijing Stock Exchange and the bond/futures markets, with a continued crackdown on fraud, manipulation and insider trading.

19 January 2026: The Dutch Authority for the Financial Markets (AFM) announced that in 2026 it will intensify supervision of digital resilience and the responsible use of AI, while strengthening its approach to financial crime with a targeted focus on investment fraud and money laundering.

14 January 2026: The Autorité des Marchés Financiers (AMF) set its 2026 priorities to strengthen confidence in financial markets by advancing a robust Savings and Investment Union, enhancing market attractiveness and resilience, supporting sustainable finance and providing a regulatory framework for innovative finance.

14 January 2026: South Korea's Financial Services Commission (FSC), Financial Supervisory Service (FSS) and Korea Exchange expanded their joint stock‑manipulation response team from one to two units, increasing headcount from 37 to 62 and adding digital‑forensics capacity to speed investigations.

12 January 2026: The German Federal Financial Supervisory Authority (BaFin) approved DZ Bank’s MiCA/MiCAR authorisation for "meinKrypto," enabling retail crypto trading (BTC, ETH, LTC, ADA) through the VR Banking App across cooperative banks, expanding regulated access to digital assets.

12 January 2026: The U.K. Financial Conduct Authority (FCA) reported that firms selling complex exchange‑traded products to retail investors are falling short in areas such as appropriateness tests and risk disclosures.

6 January 2026: Saudi Arabia’s Capital Market Authority (CMA) opened the Tadawul main market to all categories of foreign investors from 1 February 2026, abolishing the Qualified Foreign Investor regime while retaining a 10% cap per non‑resident investor and a 49% aggregate foreign‑ownership limit.

6 January 2026: The AMF and the Autorité de Contrôle Prudentiel et de Résolution (ACPR) warned the public about several unauthorized entities offering investments in France in the unregulated Forex market and crypto‑asset derivatives.


Latest Fines and Enforcement Actions

  • The U.S. Department of Justice announced that a former Doximity executive pleaded guilty to securities fraud for trading ahead of earnings using non‑public information, generating over $2.5 million in illicit gains.

  • The CFTC obtained federal court orders imposing civil monetary penalties and trading bans on two individuals for spoofing in the precious metals futures markets while employed at a major bank. 

  • The CFTC secured a federal court order requiring a Florida man and Omerta Capital LLC to pay disgorgement and civil monetary penalties for misappropriating confidential information and engaging in fictitious trading.

  • The CFTC charged an Oklahoma man and his company, Wolf Capital Crypto Trading LLC, with fraud and registration violations for allegedly soliciting over $10 million for an unregistered commodity pool.

  • The CFTC issued a no‑action letter granting Bitnomial Exchange/Clearinghouse targeted relief from certain swap reporting/recordkeeping for event contracts, clarifying conditions for fully‑collateralized, cleared prediction‑market offerings.

  • The U.S. Securities and Exchange Commission (SEC) charged three brothers and associates with a $41 million insider‑trading and manipulation scheme, alleging use of stolen clinical data and a fake press release to move Olema and Opiant stocks while also trading on healthcare M&A tips.

  • The Hong Kong Securities and Futures Commission (SFC) reprimanded and fined Saxo Capital Markets HK Limited HK$4 million for multiple regulatory failures after the firm allowed retail clients to trade complex virtual asset-related products over four years.

  • The Securities and Futures Commission (SFC) convicted a retail trader of seven counts of false trading for using "scaffolding" and wash‑trade tactics to create artificial prices in six Hong Kong‑listed shares.

  • The SFC obtained an interim High Court injunction freezing up to HK$85.2 million of assets linked to suspected manipulation of Wan Cheng Metal Packaging shares, part of proceedings against an alleged ramp‑and‑dump syndicate.

  • The FCA fined an oil‑rig consultant £309,843 for using confidential drilling information to conduct insider trades in multiple oil and gas companies between 2018 and 2022, profiting £128,765 before receiving a settlement‑discounted penalty.

  • The FCA fined former Carillion finance directors £232,800 and £138,900 for reckless conduct that contributed to misleading market statements before the firm's collapse.

  • The Securities and Exchange Board of India (SEBI) barred 26 individuals and imposed ₹1.85 crore in penalties after finding they used coordinated deceptive trading to artificially inflate the price and volume of SME‑listed DU Digital Global shares.

  • The Canadian Investment Regulatory Organization (CIRO) issued reasons in a settlement fining Haywood Securities C$100,000 for failing from 2014–2022 to adequately supervise end‑of‑day high/low close trades and related orders for CSE‑listed issuers.

  • The U.S. Financial Industry Regulatory Authority (FINRA) fined BNP Paribas Securities $125,000 for multi‑year Large Options Position Reporting failures—842 OTC options positions in 167,520 instances—and related supervisory gaps, issuing a censure alongside the penalty.

  • FINRA fined three Cetera broker‑dealers $1.1 million after finding failures from March 2019 to August 2021 to detect/report suspicious penny‑stock activity and to supervise consolidated reports. 


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