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SESC recommends ¥760,000 fine over ten-day order-matching scheme in a Tokyo Standard-market stock

Japan's securities watchdog says a trader crossed its own buy and sell orders over ten sessions to fake demand and move the market price of a share on the Tokyo Stock Exchange's Standard market, yet the resulting surcharge recommendation is just ¥760,000.

Sep 16, 20263 min read
Illustration of stacked buy and sell order bars on an electronic order book with a rising price line, representing a self-matched trading scheme.

Japan's Securities and Exchange Surveillance Commission (SESC) has recommended a ¥760,000 surcharge payment order against a trader who spent ten trading sessions crossing buy and sell orders in its own name to fake demand for a share on the Tokyo Stock Exchange's Standard market. The recommendation, sent to the prime minister and the head of the Financial Services Agency on September 15, 2026, covers trading in a company the release names and identifies by its Standard-market code, 3802.

Ten sessions, one order book

Between roughly 2:25pm on May 30, 2024 and 3pm on June 12, 2024, the trader placed sell orders to match its own buy orders, entered market or above-last-price limit buy orders to snap up other investors' sell orders and lift the price, and stacked layers of buy orders to make the stock look more actively traded than it was. Over that stretch the trader entrusted 73,500 shares of buy orders, actually bought 120,500 shares and sold 113,500 shares. The SESC found this conduct was carried out with the aim of inducing trading and moving the stock's market price, the legal threshold for manipulation under the Financial Instruments and Exchange Act.

A fine sized to the profit, not the market

The SESC calculates surcharges under Article 174-2 of the Act by pricing the gain from matched trades plus any leftover position. On the 113,500 shares where a buy matched a sell, the sell-side value of ¥50,895,400 exceeded the buy-side value of ¥50,220,100 by ¥675,300. The statute also treats 23,100 shares the trader already held at the start of the scheme as deemed purchases, valued at the opening price of ¥431. Adding those to the 120,500 shares actually bought puts deemed purchases at 143,600 shares, some 30,100 more than the 113,500 shares sold. That statutory excess is priced at ¥463, the highest reference price recorded in the month after the scheme ended, adding a further ¥90,800. The two components sum to ¥766,100, which the statute rounds down to the nearest ¥10,000, producing the ¥760,000 figure the SESC has recommended.

How the ¥760,000 surcharge was calculated
Figures from the SESC's calculation annexes to its September 15, 2026 recommendation.
ComponentAmount / Volume
Buy orders entrusted73,500 shares
Shares actually bought120,500 shares
Shares sold113,500 shares
Sell-side value (matched volume)¥50,895,400
Buy-side value (matched volume)¥50,220,100
Matched-volume gain¥675,300
Deemed excess volume (statutory)30,100 shares
Excess-volume component (at ¥463 high)¥90,800
Total before rounding¥766,100
Final surcharge (rounded down)¥760,000

What the release leaves open

The SESC's public release does not name the individual or corporate trader facing the recommended order. That is standard at this stage: naming and any final order rest with the Financial Services Agency and the prime minister's office. The release describes the target stock as one that "had been listed" on the TSE Standard market, phrasing the underlying Japanese text uses without further explanation, so this account does not assume the company remains listed today. The SESC says the case was built using information supplied by Japan Exchange Regulation, the exchange group's self-regulatory arm.