The Commodity Futures Trading Commission (CFTC) recently secured a multimillion-dollar judgment against Systematic Alpha Management LLC (SAM), its principal Peter Kambolin, and related entities. This enforcement action is highly notable, given the overall slowdown in new CFTC cryptocurrency cases throughout 2025. The defendants had previously pleaded guilty to orchestrating a fraudulent scheme involving cryptocurrency trading.

According to the CFTC’s announcement, SAM, acting both as a commodity trading adviser (CTA) and commodity pool operator (CPO), misallocated profitable trades between commodity pools and proprietary accounts, misled pool participants, and violated trade allocation rules. These actions occurred between January 2019 and November 2021. SAM was marketed as providing trading strategies in exchange-traded cryptocurrency and forex futures, but the reality was far different.

The court found that the defendants deceived investors and improperly handled trade allocations, leading to the settlement of over $2.8 million in restitution and penalties. This case demonstrates that even as crypto enforcement actions slow, the CFTC remains vigilant about fraud in cryptocurrency investment and trading products.

Recent trends point to increased scrutiny and enforcement in digital asset markets. Investigations now routinely leverage forensic blockchain intelligence to trace and recover misappropriated funds, uncovering schemes where assets were converted into cryptocurrencies and routed through complex networks to evade detection. The importance of collaboration between regulators, law enforcement, and financial institutions is more crucial than ever to dismantle fraudulent operations and hold wrongdoers accountable.

These developments reflect the CFTC’s ongoing commitment to protecting investors and supporting the integrity of commodity and digital asset markets. As the digital economy grows, robust enforcement mechanisms will remain a key component in maintaining market confidence and safeguarding investors against increasingly sophisticated fraudulent schemes.