Wash trading involves repeatedly buying and selling the same asset among collusive or self-owned accounts, creating artificially high trading volume and misleading price signals. By cycling funds through these orchestrated trades, criminals can transform illicit proceeds into ostensible trading gains or losses, obscuring the original source of funds. This technique frequently surfaces in equities, cryptocurrencies, and NFTs, where weaknesses in beneficial ownership disclosure and minimal KYC measures enable repeated self-dealing transactions. Criminals may use wash trading to manipulate valuations—either inflating asset prices to attract buyers or generating capital losses for tax purposes—while layering the illicit funds through multiple, rapid transfers. These schemes often rely on pseudonymous wallets or collusive addresses, making true ownership difficult to trace and undermining conventional oversight. As a result, wash trading presents a potent means of market manipulation and money laundering, compromising market integrity and creating significant challenges for investigators and regulators.
Wash Trading
Round-Trip Trading
Tactics
By executing frequent self-dealing trades among collusive or pseudonymous accounts, wash trading obscures the transaction path and complicates forensic tracing, achieving a clear layering effect of illicit funds.
Risks
Wash trading relies on inadequate customer identification and beneficial ownership transparency, enabling criminals to open multiple brokerage or exchange accounts under different credentials or pseudonymous wallets. By exploiting minimal KYC measures, criminals can mask the true ownership behind each account and orchestrate self-dealing trades without raising immediate suspicion. This is a secondary vulnerability complementing the product-driven nature of wash trades.
This technique exploits the inherent vulnerabilities of trading products (e.g., securities, cryptocurrencies, NFTs) that allow self-dealing trades to go unnoticed in real time. By repeatedly buying and selling the same asset among collusive accounts, wash trading leverages minimal scrutiny of artificially generated volume and price signals, obscuring the true source of funds. This is the primary vulnerability enabling manipulation of trading platforms and disguising illicit proceeds as legitimate gains.
Indicators
Repeated transactions between the same parties with no evident economic or commercial rationale.
Trades executed at prices that deviate significantly from the market price, especially when followed by offsetting trades.
Multiple transactions that net to zero or near-zero profit or loss over a short period.
Accounts that exhibit persistent high-frequency trading activity despite lacking the capital or business justification to support such trading volumes.
Trading volumes that spike near regulatory reporting deadlines, potentially inflating reported activity or prices.
Employment of trading accounts or entities in high-risk jurisdictions with weak oversight to facilitate repeated or self-dealing trades.
Frequent buy and sell transactions of the same asset within a short timeframe, resulting in minimal or no net change in position or beneficial ownership.
Sudden and repeated spikes in trading volume for an asset that do not reflect typical market conditions or news events.
Use of multiple accounts controlled by the same individual or group to trade the same asset back and forth.
Accounts involved in trading that have a history of being inactive or show sudden bursts of trading activity after a period of dormancy.
Significant discrepancy between an account’s trading activity and its declared financial profile or stated business operations.
Trading patterns that coincide with significant news or events that might influence the asset price, yet the trades do not align with overall market sentiment.
Unusual trading activity that occurs during off-market hours or at times of low market liquidity.
Use of seemingly independent wallets or trading accounts sharing the same IP addresses or device identifiers to execute offsetting trades.
Data Sources
- Provides data on AML/CFT regulatory environments, enforcement levels, and risk ratings across various jurisdictions.
- Flags accounts or entities operating in high-risk or weakly regulated jurisdictions where collusive wash trading may go undetected.
- Aids in prioritizing investigations by highlighting cross-border transactions involving higher-risk regions for potential wash trading.
- Captures IP addresses, device identifiers, login timestamps, and network session data.
- Reveals patterns of multiple trading accounts or wallets being accessed from the same devices or locations, indicating potential self-dealing.
- Enhances investigations by corroborating evidence of collusion through shared system access points.
- Contains verified identity data, beneficial ownership information, financial profiles, and business activity details.
- Enables comparison of declared financial resources against actual trading activity, helping uncover mismatched capital or business operations.
- Facilitates linking multiple accounts under the same beneficial owner to detect self-dealing trades.
- Provides on-chain records for cryptocurrency and NFT transactions, including wallet addresses, timestamps, and amounts.
- Detects repeated self-dealing or wash trading patterns in decentralized environments.
- Helps trace cross-wallet transfers that obscure the origins of funds and beneficial ownership.
- Provides detailed data on trades, including timestamps, trade prices, volumes, counterparties, and transaction IDs.
- Enables detection of repeated buy/sell patterns with minimal net changes in position, indicating potential wash trading.
- Supports analysis of anomalous trading volume spikes or offsetting transactions that suggest collusion or self-dealing.
Mitigations
Apply heightened scrutiny to customers or accounts that exhibit repetitive or offsetting trading patterns. Verify ultimate beneficial ownership across multiple accounts or wallets and confirm the economic rationale for such trades. This helps uncover undisclosed relationships and prevent wash trading activities disguised as legitimate transactions.
Require robust identification and verification of all trading accounts, ensuring disclosure of any overlapping beneficial ownership. For high-volume or frequently offsetting traders, demand documentation justifying trading activities to prevent covert self-dealing and market manipulation.
Implement specialized alerts and analytic models to detect short-interval buy-sell cycles among the same accounts or beneficial owners. Identify patterns of trades that offset each other with no legitimate profit motive, and flag abrupt volume spikes indicative of wash trading schemes.
Use specialized analytics to trace repeated self-dealing on blockchain-based platforms by correlating on-chain transactions and identifying common control of multiple wallets. This enables the rapid detection of cyclical transfers that are characteristic of wash trading in digital asset markets.
Restrict or suspend specific trading functionalities (e.g., high-frequency or offsetting orders) for customers exhibiting suspicious wash trading patterns. Require documented justification for high-volume or repetitive trades before allowing continued access to advanced trading features.
Conduct detailed reviews of trade logs, order books, and pricing data to identify artificially inflated volumes or systematic round-trip trades. By comparing trade timestamps, counterparties, and price deviations, institutions can pinpoint circular transactions that lack a genuine commercial basis and indicate wash trading.
Instruments
- Perpetrators create or control multiple NFT marketplace accounts, trading the same token among themselves to inflate perceived demand and valuation.
- These repetitive self-bids and sales mask illicit money movements as legitimate transactions for digital collectibles, allowing criminals to justify large sums received as NFT trading proceeds.
- The lack of transparent beneficial ownership in many NFT platforms makes it challenging to identify collusive participants executing wash trades.
- Criminals use multiple exchange accounts or pseudonymous wallets they control to execute coordinated buy/sell orders on the same cryptocurrency.
- This repeated self-dealing artificially boosts market volume and can manipulate asset prices, allowing illicit funds to be disguised as legitimate trading profits when withdrawn.
- The pseudonymous nature of crypto transactions and inconsistent KYC requirements facilitate rapid wash trading cycles that obscure the original illicit flow of funds.
- Criminals open or control multiple brokerage accounts or shell entities to repeatedly buy and sell the same stocks or bonds among themselves, artificially inflating perceived trading volume.
- By coordinating self-dealing trades at manipulated prices, they transform illicit proceeds into ostensible capital gains or losses, masking the original source of funds.
- Wash trading in securities leverages gaps in real-time oversight and beneficial ownership disclosure, making it difficult for regulators to distinguish legitimate trading from collusive transactions.
Service & Products
- Enables large, negotiated trades with reduced public visibility, allowing colluding counterparties to conduct repeated round-trip transactions off-exchange.
- By using OTC desks that may not always enforce stringent due diligence, illicit actors can obscure beneficial ownership and inflate trading volumes without drawing immediate scrutiny.
- Pseudonymous DeFi protocols allow users to orchestrate repetitive swaps of tokens among wallets they control, simulating market demand and obscuring actual ownership.
- The lack of a centralized intermediary and inconsistent KYC requirements facilitate circular trading aimed at blending illicit proceeds with purported trading gains.
- Direct, user-to-user trades can be arranged between collusive parties to repeatedly buy and sell the same cryptocurrency, generating fictitious trading activity.
- Limited oversight or inconsistent identification checks on some P2P platforms facilitate coordinated wash trades, masking the illicit origin of proceeds.
- Criminals open or control multiple brokerage accounts and execute frequent buy/sell orders of the same stock between accounts they secretly own, creating illusory volume.
- This activity can distort market prices and mask illegal funds as legitimate capital gains or losses once the trades settle.
- Criminals may create multiple exchange accounts under different identities and trade the same digital assets among these accounts, artificially inflating volume and obscuring the true origins of funds.
- The rapid nature of crypto transactions combined with minimal KYC in some jurisdictions enables repeated self-dealing trades, disguising illegal proceeds as legitimate trading gains.
- Provide convenient, remote access for rapid securities trading, enabling perpetrators to enter matched orders across multiple accounts under different credentials.
- High-frequency self-dealing trades can simulate legitimate market activity, facilitating integration or layering of criminal funds without raising immediate red flags.
- Criminals list digital items (e.g., NFTs) and repeatedly bid on their own auctions using multiple pseudonymous accounts, artificially inflating perceived value and trade volume.
- The rapid transactions and lack of transparent beneficial ownership disclosures enable layering of illicit funds, reframing them as auction proceeds.
Actors
Traders knowingly use wash trading to:
- Execute repeated buy-and-sell orders of the same security or asset between accounts they control.
- Manipulate reported gains or losses, concealing the illicit origin of funds once they withdraw or reinvest proceeds.
Such actions obscure transactional flows and challenge financial institutions' detection of suspicious trading patterns.
Brokers can be exploited when:
- Criminals open or control multiple brokerage accounts to place matching buy-and-sell orders among themselves.
- High-volume, offsetting trades pass through broker platforms, appearing as normal client activity but actually masking illicit funds.
Financial institutions relying on broker records may struggle to identify collusive trading without deeper beneficial ownership checks.
Professional money launderers organize wash trading schemes by:
- Setting up multiple accounts, wallet addresses, or shell structures to cycle illicit funds through repeated trades.
- Coordinating rapid, offsetting transactions that mask the true origin of money and generate fictitious trading profits.
Financial institutions struggle because these intermediaries actively design complex layering strategies that resist standard detection measures.
Virtual asset users exploit pseudonymous wallets or multiple exchange accounts by:
- Repeatedly trading the same cryptocurrency or token among addresses under their control.
- Creating artificial transaction volume to transform illicit proceeds into apparently legitimate trading gains.
Financial institutions face difficulty linking the same underlying controller behind multiple wallets, hindering transaction monitoring.
Peer-to-peer exchange operators are exploited when:
- Users arrange repetitive crypto trades under the guise of legitimate user-to-user activity.
- Limited oversight or lax identification checks allow accounts under common control to inflate trading volumes.
This environment complicates financial investigations, as multiple small trades can mask larger laundering objectives.
References
FATF (Financial Action Task Force). (2023, February). Money Laundering and Terrorist Financing in the Art and Antiquities Market. FATF. https://www.fatf-gafi.org/publications/Methodsandtrends/Money-Laundering-Terrorist-Financing-Art-Antiquities-Market.html
AUSTRAC (Australian Transaction Reports and Analysis Centre). (2017, July). Australia's securities & derivatives sector money laundering and terrorism financing risk assessment. AUSTRAC. https://www.austrac.gov.au/business/how-comply-guidance-and-resources/guidance-resources/australias-securities-and-derivatives-sector-risk-assessment-2017
Al Shamsi, M., Smith, D., & Gleason, K. (2023). Space transition and the vulnerabilities of the NFT market to financial crime. Journal of Financial Crime.https://www.emerald.com/insight/content/doi/10.1108/jfc-09-2022-0218/full/html
Lange, A. (2022). Financial crime in the metaverse is real – how can we fight back?. Wolf Theiss. https://www.wolftheiss.com/insights/financial-crime-in-the-metaverse-is-real/