On June 25, 2026, the Department of Justice announced the guilty plea of Mingran Wang, the alleged founder and investment manager of Greenroots Capital Management, for an alleged multi-year securities-fraud scheme involving more than 3,000 instances of “spoofing.” Wang pleaded guilty in the U.S. District Court for the Northern District of California and agreed to forfeit more than $1.3 million in proceeds. In a parallel civil action announced the same day, the Securities and Exchange Commission charged Wang with the same scheme, alleging manipulation of more than 150 thinly traded American Depositary Receipts (“ADRs”). Wang consented to a settled judgment in the SEC case. Taken together, the actions underscore that spoofing remains an active enforcement priority for both the Department of Justice and the SEC, and the case is notable in several respects—including its focus on thinly traded securities, cross-brokerage trading structure, and unusually candid evidence of intent and concealment.

Spoofing is the practice of placing non-bona fide orders—which the trader at the time of placement intends to cancel before execution—to create a false impression of supply or demand and move a financial instrument’s price in the trader’s favor. According to the charging documents in this matter, which involved alleged spoofing in securities markets, between October 2021 and November 2024, Wang engaged in more than 3,000 instances of such trading, ultimately generating approximately $1.3 million in proceeds.

Central to the scheme was Wang’s choice of targets: thinly traded, illiquid ADRs that could make a spoofing scheme easier to execute. As the charging documents allege, compared to more actively traded securities with greater trading volumes, thinly traded securities often have fewer interested buyers and sellers and wider bid-ask spreads. In that context, even a small number of orders can move the National Best Bid or Offer, because each non-bona fide order represents a larger share of total apparent market supply or demand than it would in a more liquid security. In this case, the resulting leverage appears significant. For example, the SEC’s complaint alleges that on January 23 and 24, 2023, Wang’s trading reportedly accounted for 100% of the trading volume in one targeted ADR.

The structure of the scheme across different brokerage accounts is also notable. Wang allegedly separated the manipulation from the profit-taking, routing the two sides of his trading through different brokerage firms, using a single account at one brokerage for his spoof orders and three accounts at a second brokerage for his bona fide orders. He allegedly placed his non-bona fide “spoof” orders through an account at one brokerage and executed his genuine opposite-side trades through accounts at a second brokerage, frequently in an account held in his wife’s name. The government alleged this cross-brokerage structure helped conceal that a single trader controlled both sides of the strategy—another hallmark of spoofing in anonymous markets.

This case is also noteworthy for the documentary record Wang allegedly left behind. The government alleges investigators recovered notes from Wang’s personal computer instructing that the “[m]ost important thing is to hide,” with tactics including to “[r]andomize the pattern as much as possible,” reduce the frequency at the expense of gains, and “[r]otate on symbols.”   Other notes allegedly scripted a cover story for the cross-trading, contemplated claiming that he “[d]oesn’t know layering or spoofing or those things!!,” and assessed that the “[w]orst case” might be a monetary penalty and “[m]ost likely civil charges!!” A search of Wang’s residence also allegedly turned up two noteworthy books: A Convicted Stock Manipulator’s Guide to Investing and How Stocks Are Manipulated.

As to the resolutions, Wang pleaded guilty to one count of using interstate commerce for the purpose of securities fraud in violation of Section 17(a) of the Securities Act of 1933. He faces a statutory maximum of five years in prison and is scheduled to be sentenced on September 30, 2026. On the civil side, Wang consented to a judgment permanently enjoining him from violating the antifraud and anti-manipulation provisions (Sections 17(a)(1) and (3) of the Securities Act of 1933, and Sections 10(b) and 9(a)(2) of the Exchange Act and Rule 10b-5 thereunder), imposing a five-year brokerage-account notification requirement, and leaving disgorgement, prejudgment interest, and civil penalties to be set later.

The matter offers several practical takeaways. First, spoofing prosecutions remain robust and frequently proceed in parallel across civil and criminal regulators. The Criminal Division’s Fraud Section is prosecuting the DOJ case, continuing the Section’s prominent nationwide focus on spoofing and market manipulation, and has regularly brought spoofing matters in coordination with the SEC’s Division of Enforcement (whose Market Abuse Unit investigated the SEC case here) and, in the commodities and derivatives context, with the Commodity Futures Trading Commission. Second, illiquid instruments, such as thinly traded ADRs, continue to present heightened manipulation risk and corresponding regulatory scrutiny. Third, cross-account execution remains a prominent method of executing a spoofing scheme, highlighting compliance risks and challenges. Fourth, as Wang’s own files illustrate, contemporaneous notes, search histories, and similar materials can supply powerful evidence of fraudulent intent and concealment.

This post is based on a Sullivan & Cromwell LLP memorandum, “DOJ and SEC Bring Parallel Spoofing Actions Against Fund Founder and Investment Manager,” dated June 26, 2026, and available here.