CLS Global FZC / ZM Quant Investment
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anchored·2ctrx7…drmxSummary
CLS Global FZC LLC (UAE) and ZM Quant Investment Ltd (British Virgin Islands) are crypto market-making firms charged in October 2024 as part of DOJ Operation Token Mirrors, an FBI undercover sting that created a fake token called NexFundAI to expose market-manipulation-as-a-service. Both firms are alleged to have generated billions of dollars in artificial trading volume through algorithmic wash trading on behalf of token promoters. CLS Global pleaded guilty to criminal charges in January 2025 and was sentenced to pay $428,059 in April 2025; parallel DOJ criminal proceedings against ZM Quant (case 1:24-cr-10187) remain on record as of June 2026. The SEC voluntarily dismissed its civil enforcement actions against both entities on March 31, 2026, reflecting a policy shift under the current administration, though those dismissals do not constitute a finding of innocence and do not affect the DOJ criminal proceedings.
Connected Entities
1 entities- + 4 more
Connected Through
1 shared actor · 1 investigationDistinct actors this investigation shares with others — holders, traders, and named parties. Shared infrastructure (exchanges, pools) is excluded.
- □CLS Global FZC / ZM Quant Investmentorganization
Timeline(14 events)
2018
CLS Global FZC LLC founded in Dubai, UAE. ZM Quant Investment Ltd. begins crypto market-making operations from British Virgin Islands, with Hong Kong-based personnel.
Company profiles and SEC complaintsSeptember 2021
ZM Quant alleged to have begun wash trading for Saitama Inu (SAITAMA) token on behalf of promoters (approximate start date per SEC complaint).
SEC Complaint: ZM Quant Investment Ltd.26 May 2023
ZM Quant alleged to have executed SaitaRealty trades increasing the token's transaction quantity by approximately 412,000,000,000% within 24 hours following exchange warnings about low volume.
SEC Complaint: ZM Quant Investment Ltd.March 2024
Undercover FBI operatives conduct a video teleconference with ZM Quant employees Baijun Ou and Ruiqi Lau, who describe multi-wallet wash trading methodology for NexFundAI token.
DOJ District of Massachusetts press release31 May 2024
ZM Quant generates approximately $4,600 in artificial NexFundAI trading volume on Uniswap over nine hours, representing 83.6% of the token's trading activity during that period.
SEC Complaint: ZM Quant Investment Ltd.July 2024
Undercover FBI agents begin video teleconferences with CLS Global. Employee Andrey Zhorzhes joins a Telegram group with undercover operatives posing as NexFundAI promoters and describes the firm's wash trading algorithm.
DOJ District of Massachusetts press release23 August 2024
CLS Global begins conducting manipulative wash trades for NexFundAI on Uniswap.
SEC Complaint: CLS Global FZC LLC and Andrey Zhorzhes18 September 2024
CLS Global's NexFundAI manipulation window ends. Total artificial volume generated: approximately $595,000, representing 98% of all NexFundAI trading activity during the period.
SEC Complaint: CLS Global FZC LLC and Andrey Zhorzhes19 September 2024
Federal grand jury in Boston returns sealed superseding indictment against ZM Quant Investment Ltd., Baijun Ou, and Ruiqi Lau (case 1:24-cr-10187). CLS Global and Andrey Zhorzhes separately indicted (case 1:24-cr-10293).
CourtListener docket: United States v. ZM Quant Investment LTD9 October 2024
DOJ publicly announces Operation Token Mirrors charges. SEC files civil fraud charges against CLS Global, ZM Quant, Gotbit, and named individuals under Press Release 2024-166. Indictments unsealed.
SEC Press Release 2024-166; DOJ District of Massachusetts21 January 2025
DOJ announces CLS Global FZC LLC has agreed to plead guilty to one count of conspiracy to commit market manipulation and wire fraud and one count of wire fraud.
DOJ District of Massachusetts: Cryptocurrency Financial Services Firm Agrees to Plead Guilty2 April 2025
Boston federal court finalizes CLS Global's criminal sentencing: $428,059 total payment, three-year probation, prohibition from U.S. cryptocurrency markets.
Crypto Daily: CLS Global Concludes $428,059 Settlement with Massachusetts Federal Court7 April 2025
U.S. District Court for the District of Massachusetts enters consent final judgment in the SEC civil case against CLS Global FZC LLC: $425,000 civil penalty, $3,000 disgorgement, $80.39 prejudgment interest, and permanent injunctions from future violations.
SEC Litigation Release LR-2628731 March 2026
SEC voluntarily dismisses remaining civil enforcement actions against ZM Quant Investment Ltd. (including Baijun Ou and Ruiqi Lau) and against Andrey Zhorzhes in the CLS Global civil matter, as part of broader administration policy shift. DOJ criminal proceedings are unaffected.
Morrison Foerster: Top 5 SEC Enforcement Developments for March 2026Decision Log
- hash: 7G6qLyS9Poy6uTJNy91ZtBEUWQWwQAS1RsuueDAwztQk
This investigation is cryptographically anchored to the Solana blockchain (1 event). 20 of 23 cited source URLs have an Internet Archive snapshot.
model: claude-code-investigator
generated: 6/3/2026, 12:18:38 AM
last updated: 7/28/2026, 1:48:30 AM
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