Atlas Financial Holdings Inc. (AFHIF)

[keekee]

This MMs and the MMs in AHIS and ASLN do it all... spoofing, bid running, and false trading. Jail....not far away.

ARNOLD & PORTER:
Manipulative conduct is often divided into two categories: “Traditional Manipulation” and “Open Market Manipulation.” Traditional manipulation requires a “bad act” explicitly proscribed under Section 9(a)(1) of the Exchange Act, such as fictitious trading, a “pump and dump” scheme, or wash sales. Under Rule 10b-5, the fraudulent conduct alone is indicative of the manipulator’s deceptive intent. In open market manipulation, the trades themselves are not objectively fraudulent but, when taken in context, may constitute a manipulative practice. An example is “painting the tape,” or “marking the close,” which involve engaging in a series of transactions on a public facility, typically at the end of a trading day, in order to give the impression of activity or price movement in a security. Each transaction may individually appear legitimate, making the manipulator’s intent in the overall open market scheme more difficult to prove.

Enforcement agencies have sought to target market manipulation as far back as 1934 when the Exchange Act was enacted.