ZM Quant: market maker deal terms and record
ZM Quant was charged by the SEC with civil fraud on 9 October 2024 for alleged wash trading, including on a token the FBI created for a sting. These are charges, not findings; we have not found the outcome.
Charged by the SECPublic deals on record: 1.
Profile
| Deal models | paid volume generation |
| Legal record | SEC civil fraud charges, 9 Oct 2024: alleged wash trading and manipulation, including on an FBI-created token. Outcome not found as of 19 Oct 2026. |
Source: www.sec.gov, grade 5, primary document, checked 2026-10-19.
Public deals
undisclosed clients, 2019-2024
| Structure | wash trading services (criminal charges) |
| Details | Same DOJ/SEC action. Employees allegedly pitched wash trading on video calls, describing use of multiple wallets to make trading look organic. Bots generated quadrillions of transactions and billions in artificial daily volume. |
| Outcome | SEC civil fraud charges, 9 Oct 2024. SEC alleges wash trading and price manipulation for promoters, and a similar scheme on a token created at the direction of the FBI. Outcome not found as of 19 Oct 2026. |
| Source | SEC press release, grade 5, primary document, checked 2026-10-19 |
How market-maker deals usually look
The industry default is a token loan plus a call option. Across about 40 public DAO deals, loans ran at 1% to 5% of circulating supply for 12 to 24 months, with the strike set 25% to 100% above the TGE price, median 50% (WuBlockchain and the Wallfacer deal tracker, grade 4). A second source puts loans at 0.5% to 2% of supply; we show both, because the market has no agreed norm.
Want to see what an option is worth to the desk? Try the option calculator, or read our sample term sheet review. How rarely launches disclose these deals at all: 4 of 57.
Someone offering "volume support" or "market making" for a fee? Send us the offer; we check it within one business day.
Allegations are reported as allegations, with the outcome where one exists. A written comparison against public data, not legal or investment advice. We take no money from market makers.