CLS Global FZC / ZM Quant Investment
Summary
CLS Global FZC LLC (UAE) and ZM Quant Investment Ltd (British Virgin Islands) were crypto market-making firms that provided market-manipulation-as-a-service to token issuers. Both were charged in October 2024 by the U.S. DOJ and SEC as part of Operation Token Mirrors, a coordinated FBI sting that used a fake token called NexFundAI to document wash trading solicitation in real time. CLS Global pleaded guilty in January 2025 and was sentenced in April 2025 to pay $428,059 and serve a three-year U.S. market ban; ZM Quant's criminal case (1:24-cr-10187, D. Mass.) remained pending as of mid-2025 with its two individual defendants, Baijun Ou and Ruiqi Liu, based outside the United States. The SEC voluntarily dismissed its parallel civil actions against both entities on March 31, 2026, consistent with the current administration's broader rollback of crypto enforcement actions initiated under the prior administration.
Connected Entities
1 entities · 10 linked investigations- + 3 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(13 events)
2018-01-01
CLS Global FZC LLC and ZM Quant Investment Ltd both reportedly entered the crypto market-making industry. Both firms' own websites describe operations beginning in 2018.
CLS Global and ZM Quant official websites2021-09-01
ZM Quant alleged to have begun providing wash trading services for Saitama and SaitaRealty tokens, a relationship that continued until approximately September 2023 and involved generating multi-billion-dollar artificial daily volume.
SEC complaint against ZM Quant (PDF)2023-05-26
ZM Quant allegedly increased SaitaRealty's transaction quantity by 412,000,000,000 percent in response to an exchange warning about low volume — a specific instance cited in the SEC complaint.
SEC complaint against ZM Quant (PDF)2024-05-01
FBI creates NexFundAI, an Ethereum-based token, and launches Operation Token Mirrors to document market-manipulation-as-a-service solicitations.
DOJ — Operation Token Mirrors press release2024-06-01
CLS Global connects with undercover FBI agents via a referral from an LBank staffer. CLS employee Andrey Zhorzhes explains the firm's wash trading algorithm during videoconferences through August 2024.
SEC complaint against CLS Global (PDF)2024-08-23
CLS Global begins executing wash trades on NexFundAI using 30 wallets. Over the following 26 days, the firm conducts 740 transactions generating approximately $595,000 in artificial volume — 98% of all NexFundAI activity in the period.
DOJ — CLS Global plea agreement announcement2024-09-01
Federal grand jury in Boston returns indictments against CLS Global (and separately a superseding indictment against ZM Quant, Baijun Ou, and Ruiqi Liu) for conspiracy to commit market manipulation and wire fraud.
DOJ — Operation Token Mirrors press release2024-10-09
DOJ unseals charges and announces Operation Token Mirrors publicly, simultaneously with SEC filing civil complaints against CLS Global, Andrey Zhorzhes, ZM Quant, Baijun Ou, and Ruiqi Lau. 18 individuals and entities charged in total. Over $25 million in cryptocurrency seized.
DOJ and SEC coordinated announcements2024-10-29
CLS Global issues public statement via GlobeNewsWire acknowledging the enforcement actions, denying intentional U.S. market operations, and committing to regulatory engagement.
CLS Global GlobeNewsWire press release2025-01-01
CLS Global FZC LLC pleads guilty in federal court in Boston to one count of conspiracy to commit market manipulation and wire fraud and one count of wire fraud.
DOJ — CLS Global plea announcement2025-04-02
CLS Global sentenced in U.S. District Court, Boston: three years of probation, $428,059 total payment (fine plus forfeited cryptocurrency), and prohibition from U.S. cryptocurrency markets for the probationary period.
Multiple news outlets citing DOJ sentencing2025-04-07
Final civil judgment entered against CLS Global in the SEC case: $425,000 civil penalty, $3,000 disgorgement, permanent injunction, and three-year compliance certification requirement.
Goodwin Law — Digital Currency Blockchain Quarterly Q2 20252026-03-31
SEC voluntarily dismisses civil enforcement actions against CLS Global FZC LLC and ZM Quant Investment Ltd, along with other Biden-era crypto enforcement cases, consistent with the current administration's policy of scaling back regulatory actions against crypto firms.
Morrison Foerster — Top 5 SEC Enforcement Developments for March 2026Decision Log
- hash: HJf5fks2AbCtfNWiXNNFf7CWWSL4fzYNskvWyDGeq35e
This investigation is cryptographically anchored to the Solana blockchain and source URLs are archived via the Internet Archive.
model: claude-sonnet-4-6
generated: 6/2/2026, 11:06:28 PM
last updated: 6/2/2026, 11:06:33 PM
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