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On-chain trading leaves compliance teams in the dark

September 24, 2026
compliance

An alleged insider trading case involving two former Robinhood engineers has put a spotlight on a problem many compliance teams have yet to solve: employees are increasingly trading in places that traditional brokerage feeds cannot see.

According to StarCompliance, on 15 September 2026, federal prosecutors charged Hefu Chai and Huaisong “Jerry” Xiang with commodities fraud and wire fraud, according to an announcement from the US Attorney’s Office for the Southern District of New York.

The pair are accused of using confidential knowledge of upcoming Robinhood Crypto token listings to trade before those listings were made public, with each allegedly making more than $50,000.

For compliance professionals, the most telling detail is not the alleged misconduct itself but the venue where it took place.

Prosecutors say both engineers had access to non-public listing information and were barred from trading the relevant tokens around announcement windows. Rather than buying the tokens outright, however, they allegedly traded perpetual futures on Hyperliquid, a decentralised derivatives exchange.

Perpetual futures let traders bet on an asset’s price movements without holding the asset itself, a distinction that can place activity outside the scope of conventional monitoring.

Most personal account dealing programmes are built on employee disclosures, brokerage feeds, pre-clearance and restricted lists. Yet staff activity can now span decentralised exchanges, crypto derivatives, prediction markets and numerous wallets. A policy may well forbid such trading, but the more pressing issue is whether a firm has any real ability to detect it.

Regulators are clearly widening their focus. In August 2026, the CFTC brought and settled charges over the misuse of material non-public information to trade prediction market event contracts. The Robinhood case now shows comparable risks emerging in crypto derivatives on decentralised platforms. The instruments and venues shift, but the underlying conduct risk stays the same.

Traditional controls remain vital, though they may offer only a partial view once activity moves on-chain. Employees can operate several wallets, shift assets across blockchain networks, or trade derivatives tied to a digital asset without ever owning it.

The pool of employees who pose a risk is also growing. Engineers, product specialists and others may gain early sight of listings, launches or other market-sensitive developments, even if they have never been classed as access persons.

Against this backdrop, firms should test their employee compliance frameworks against three questions. First, are derivatives and event contracts covered, with perpetual futures and prediction market contracts treated under the same risk framework as the underlying asset or event? Second, can the firm see beyond a disclosed wallet, using on-chain monitoring to trace activity across linked wallets and transactions?

Third, are the right employees in scope, including those with early insight into digital asset listings, product roadmaps or event contract launches?

Read the full StarCompliance post here.

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  • TAGS
  • CFTC
  • Compliance
  • Crypto
  • DeFi
  • derivatives
  • Digital assets
  • Fintech
  • Hyperliquid
  • insider trading
  • personal account dealing
  • prediction markets
  • RegTech
  • Robinhood
  • Robinhood Crypto
  • US Attorney's Office
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