Kalshi's own surveillance desk supplies the CFTC with a second event-contract settlement in four weeks

Work the cooperation discount backwards and the agency's arithmetic shows up. A $65,000 civil penalty after a roughly 40 percent reduction implies a starting figure near $108,333 ^[14], which sits within about $800 of the $107,539.02 in profits Gabriel Perez was ordered to repay ^[16]: one times the gain, before credit for voluntarily sitting for an interview and accepting responsibility ^[4]. That interview was worth roughly $43,300 ^[15], and the number is now in a public order where the next defendant's counsel can find it.

The part with a recurring cost attached is who did the detecting. Kalshi's head of enforcement, Robert DeNault, said on X that the exchange's surveillance unit caught the trading, and the CFTC credited KalshiEX for its assistance ^[8]. The July 31 settlement with former congressman George Santos, over a contract on who would attend February's State of the Union, came out of a Kalshi referral as well ^[7]. Two for two, which is the self-regulatory arrangement securities exchanges have run for decades, and it means Kalshi is paying for a function whose output is enforcement referrals against its own paying customers. That spend buys no listings and no liquidity, and the same Friday it earned the agency's thanks, the Ninth Circuit held the company had not shown a likelihood that federal commodities law preempts Nevada's gambling rules ^[9].

Scale is worth holding against the deterrence claim. Perez opened his account on Dec. 8, 2025 and traded into March 2026, reading prepared remarks roughly an hour before delivery ^[3], which works out near $27,000 a month ^[18]; the Google engineer charged in May over internal search data allegedly made about $1.2 million on Polymarket ^[10], something like eleven times as much ^[19].

This is probably wrong, but I read the two orders as the CFTC deciding what counts as inside information on an event contract before its own rulemaking gets there, with an hour of advance access to official text as the working answer. The counter-thesis is that nothing has been established: both cases were handed over rather than found, Perez consented without admitting the findings ^[4], no venue has been charged for a surveillance failure, House Oversight Chairman James Comer's May requests for documents on identity verification, geoblocks and suspicious-trading detection remain requests ^[11], both platforms tightened controls in March on their own initiative ^[12], and the framework proposed under Chair Michael Selig is still a proposal ^[13]. Or rather, the more interesting version of the counter-thesis: the venues are policing hard precisely because the rules are unwritten, and a written rule could cost them less.

What would move me off it is an event-contract case the CFTC builds without a venue handing it over, or an order where the penalty runs above the gains instead of being discounted below them. Perez's all-in $172,539.02 is about 4.9 times what Santos paid ^[17], and both men are off CFTC-registered venues for three years ^[7], which is a price list more than a doctrine.