Case studies

Cryptocurrency Exchange Collusion

When a new cryptocurrency experienced sudden delisting from multiple exchanges, their Counsel urgently engaged an FRA partner to help investigate potential antitrust or collusive behavior.


An FRA Partner, while Head of Regulatory Affairs at a well-known online gaming company, was retained through Counsel to a new cryptocurrency. The cryptocurrency had recently been listed by many cryptocurrency exchanges and suddenly delisted by a small group of exchanges around the same time. In a short timeframe, the client wanted to understand if there was any anti-trust or collusive behavior by these exchanges against the cryptocurrency.


The FRA Partner led a team in conducting a deep dive investigative research project into several of the exchanges that delisted the client looking for relationship linkages between them. This project included mining social media accounts owned by the exchanges and their founders and conducting discreet source inquiries both domestically and abroad. The team built a timeline of key events that supported the fact that there appeared to be indicia of collusion between and among these exchanges.


The team drafted an extensive report highlighting the key facts obtained relating to these exchanges and their founders. The report contained indicia of apparent collusion by the exchanges against the client in a clear and concise manner, which was provided to the DOJ and FBI for further investigative action.