Kalshi's CEO points to a manipulation case to argue open trading catches insiders

Start with the dates, the only measure of speed in the record. Santos traded the contracts between February 12 and February 25, 2026 ^[5], and the CFTC announced its settlement on July 31 ^[4], 156 days after the last of those trades ^[16]. The coverage does not say when Kalshi first flagged them or how Perez was found.

Mansour's own account of detection is specific. He called the volume of transactions and public trading information a "blessing and a curse for prediction markets" ^[2]. He said Kalshi received approximately 100 complaints shortly after the suspicious activity became apparent ^[19], and, according to him, those reports helped Kalshi identify and investigate the transactions ^[20]. "You're committing crime in broad daylight," he said ^[3].

For Santos, that line fits. According to the CFTC, he made public statements about his attendance plans while holding positions that could benefit from price moves, and some of those statements were misleading ^[5][6]. (Manipulating a market by talking only works if people hear you, so the offender has to be loud.) Insider trading is the opposite case. The sources do not test this, but we think a person trading on private knowledge leaves behind only a price move, and a price move looks like any other bet until somebody ties the account to a job.

The counter-thesis is that Kalshi does not depend on the crowd at all. The company has introduced mandatory employer disclosures for traders ^[12] and runs additional checks on trading tied to government decisions, corporate announcements and other events where some participants may know the outcome before the public ^[13]. Those are identity checks, a different instrument from public trade data. If insiders are being caught, the credit may belong to the disclosure rule, or rather to the combination, and the one case Mansour cited does not separate them.

The two named penalties are hard to compare. Santos's order adds up to $35,069.98 ^[17], the $17,569.98 returned plus the $17,500 civil penalty ^[7], a little above the $35,000 in crypto.news's summary ^[15]. Perez faced $172,539 in disgorgement and penalties ^[9], about 4.9 times Santos's total ^[18], and unlike Santos he was cited for insider trading.

The surveillance claim and the jurisdiction fight are separate questions. Federal regulators and state authorities remain divided over who can legally oversee sports prediction markets ^[11], and Kalshi's one worked example for its surveillance claim is a manipulation order from the federal side of that dispute.

Mansour acknowledged the challenges of monitoring growing trading volumes ^[14], and about 100 complaints about one former congressman measure attention to that man at least as much as they measure surveillance. We would drop this view if the CFTC brings an insider-trading case where the first signal was a public price move on a government-decision contract, or if Kalshi shows that complaints and automated monitoring each caught a meaningful share of its cases.