Listing agents and fake volume
Ilia Nikolaevich Zavialov on scams around token listings: fake exchange agents, inflated volume and Operation Token Mirrors
Ilia Nikolaevich Zavialov on scams around token listings: fake exchange agents, emails from a supposed listing team and market makers selling inflated volume. Binance says it does not recognise intermediaries and does not charge a listing fee, and in the UK the FCA issued 2,329 warnings about unauthorised and likely fraudulent firms in 2025. In Operation Token Mirrors the FBI created its own token to expose market makers who painted volume. This guide explains how to check an agent and a market maker before paying and what to do if the money is already gone.
English version for the United Kingdom.
Why token listings became a field for scams
For a young crypto project a listing on a major exchange means liquidity, new holders and the market's trust. A team that spent months building the product wants that step badly and is ready to pay for it. The schemes around listings are built on exactly that wish.
The scam takes two main forms. The first is fake agents who promise a guaranteed listing for an upfront fee. The second is market makers who, under the name of liquidity support, sell inflated trading volume so that the token looks popular.
Ilia Nikolaevich Zavialov looks at both forms from the point of view of counterparty due diligence. A project that paid a fake agent loses money. A project that bought fake volume risks ending up in a criminal case, as happened to clients of several market makers in the United States.
Listing agents: what the exchanges themselves say
The easiest way to check an agent is to read what the exchange says about intermediaries. On 9 September 2025 Binance stated that it does not accept or recognise any third party individual or agency that applies for a listing or negotiates on a project's behalf, and that it does not charge a listing fee.
In the same notice Binance explains that under agreements with projects it receives tokens for airdrops and marketing, but only after an official announcement or a signed contract. Any arrangement that has not gone through those channels does not exist for the exchange.
On 17 December 2025 Binance repeated that no listing is ever guaranteed and that no fee is charged for project evaluations or listing applications, and offered whistleblowers a bounty of up to 5 million dollars. Coinbase states in its blog that it charges asset issuers neither listing fees nor application fees.
When an exchange says openly that it does not recognise intermediaries, anyone selling access to its listing team is selling something they do not have.
What a fake agent's pitch sounds like
The first contact usually happens on Telegram or at a conference. The person introduces themselves as a consultant, a former exchange employee or a partner of the listing team. They know the project's name, have seen its token on a decentralised exchange and offer to speed up the listing.
Then come the guarantees. A listing within two weeks, a personal contact inside the exchange, a special price for your project. Payment is requested in stablecoins to a personal wallet, often in stages: a review deposit, then a technical integration fee, then a marketing package.
Once the money arrives, contact either stops or a new obstacle appears. The exchange supposedly requires an extra audit, higher trading volume or a guarantee deposit. Every obstacle means another payment.
Urgency is a sign of its own. The agent explains that a slot in the queue opened up by chance and can only be held until the end of the week. A real exchange does not rush a project, because the project applies and only the exchange decides when to review the application.
Emails in the name of a listing team
The second version of the scheme works through email. The project receives a message supposedly from the exchange's listing team with an offer of a listing and a link to a form. The domain looks like the real one, the signature is neat, and at the end there is an invoice for reviewing the application.
OKX warns that it never sends emails from list@okx.com, an address used only to receive listing applications. An email that claims to come from that address is therefore already a sign of forgery.
A similar scheme runs on Telegram. An account with the exchange's name, logo and a listing manager title writes to founders directly. Such an account takes minutes to create and can only be checked through the exchange's own official channels.
The rule for a project team is simple. Applications go only through the official form on the exchange's website, opened by hand, and any incoming offer of a listing is checked through official support without replying to it.
Market makers: a legitimate service and its scam version
A market maker keeps buy and sell orders in the order book so that the token has liquidity and a tight spread. It is an ordinary service in financial markets, and exchanges often require new tokens to have such a partner.
The scam version sells volume. The market maker runs bots that trade the token with themselves, known as wash trading. The chart shows millions in volume with no real buyers behind it. Such volume misleads investors and the exchanges themselves.
Fake volume shows through several signs. Trading volume is high while the number of holders barely grows. Trades come at even intervals and in identical sizes. Once the market maker's contract ends, volume drops tenfold or more within a day.
For the project it looks attractive: the token climbs the rankings, aggregators write about it, the team has arguments for the exchange. Yet fake volume is market manipulation, and in the United States it already leads to sentences.
Operation Token Mirrors
On 9 October 2024 the US Department of Justice announced the results of Operation Token Mirrors. Eighteen individuals and companies were charged, more than 25 million dollars in cryptocurrency was seized, and bots responsible for wash trades in roughly 60 tokens were switched off.
The operation had an unusual feature. The FBI created its own cryptocurrency token, NexFundAI, and its own company in order to approach market makers as a client and record exactly what they offered. Several firms agreed to inflate the volume of that very token.
According to the Department of Justice, four defendants pleaded guilty, one more agreed to plead guilty, and three were arrested in Texas, the United Kingdom and Portugal.
Those charged included the market makers Gotbit, CLS Global, MyTrade and ZM Quant, as well as founders of several tokens who ordered such services. The case showed that liability falls on both the provider and the client.
Why projects buy fake volume
The case materials state the motive plainly. The founder of MyTrade described one purpose of wash trading as generating volume large enough for exchanges to waive listing fees.
A CLS Global employee promised NexFundAI help with volume so that the token would meet exchanges' listing requirements. Inflated volume was sold as a ticket to an exchange, and that is how clients understood it.
There is a simpler motive too. Heavy volume in the first weeks after launch helps early holders sell their tokens at a higher price. When buyers realise the trading was painted, the price falls and they carry the losses.
The logic is clear, yet it works against the project. Exchanges, regulators and analysts can see a token trading with itself, and the record of ordering such a service stays in the correspondence with the market maker for good.
How the cases ended
On 2 April 2025 CLS Global was sentenced to pay 428,059 dollars and to three years of probation with a ban on operating in US cryptocurrency markets.
Gotbit is forfeiting about 23 million dollars in cryptocurrency, and its founder Aleksei Andriunin, extradited from Portugal, received eight months in prison. On 6 August 2026 the founder of MyTrade was sentenced to a 10,000 dollar fine.
For teams considering a market maker these sentences mean one thing: a contract that promises volume can become evidence in a criminal case. What needs checking is exactly what the provider offers to do with the token.
Other promises around listings
A whole market of related services surrounds listings, and part of it runs on the same scheme. A guaranteed place in aggregator rankings, a package of crypto media articles with a promise of an exchange listing, a smart contract audit that a specific exchange supposedly demands.
What these offers share is that the seller promises a decision made by someone else. Rankings depend on the aggregator, listings on the exchange, articles on the editors. A person selling a guaranteed outcome of someone else's decision either has opaque arrangements or has none at all.
The check is the same as with an agent. Ask the third party directly whether it works with this intermediary and get the answer through an official channel. For crypto B2B deals such a check takes a day and costs far less than an upfront payment.
How to check an agent or a market maker
Start with the legal entity. A genuine market maker has a registered company with an address and directors that can be found in public registers. The contract is signed with that company, and payment goes to its account, never to a manager's personal wallet.
Ask them to describe their methodology. A legitimate market maker talks about spreads, order book depth and risk limits. Anyone who promises a specific daily volume in dollars is in effect offering to paint the trading.
Check any claimed ties to an exchange through the exchange itself. If the exchange says it does not recognise intermediaries, the question is closed. If the agent shows correspondence with a listing team, write to the exchange's support and ask whether such a person works there.
Ask for references from projects that really were listed with this partner and contact them directly, through the contacts on their official websites.
If the money has already been paid
Collect all correspondence, wallet addresses, transaction hashes, company names and profiles of the people you negotiated with. These details will be needed by the exchange, analytics firms and the police.
Report it to the exchange the agent claimed to represent, through its official support. Binance offers whistleblowers up to 5 million dollars for valid information about such schemes, so exchanges have a stake in these reports.
Do not pay people who offer to recover the money for a fee after the loss. After a listing scam teams often hear from supposed lawyers or analysts, and that is sometimes the same scheme continuing.
What UK teams should know
The Financial Conduct Authority published 2,329 warnings about unauthorised and likely fraudulent firms in 2025, more than a year earlier. An intermediary offering paid access to exchanges or trading services should be checked against the FCA register and its warning list before any payment.
Since 4 December 2025 fraud in England, Wales and Northern Ireland is reported to Report Fraud, which replaced Action Fraud, at reportfraud.police.uk or on 0300 123 2040. Keep the wallet addresses, transaction hashes and company details for the report.
A founder in London, Manchester, Edinburgh or Bristol should also keep the details of any company registered in another country: international cases like Token Mirrors start from individual reports.
Listing scams: what is offered, what exchanges and courts say and how to check
| Offer | What exchanges and courts say | How to check |
|---|---|---|
| Guaranteed listing | Binance: no listing is guaranteed | Official application form |
| Fee for the agent | Binance and Coinbase charge no fee | Exchange support |
| Email from a listing team | OKX: never sends from list@okx.com | Do not reply |
| Volume for a listing | Token Mirrors: 18 charged | Market maker methodology |
| Payment to a wallet | Contract with a company only | Company register |
| Rushed payment | The queue is not for sale | Project references |
Questions and answers
- Can a listing on a major exchange be bought through an agent?
- No. Binance says it does not recognise third parties applying on a project's behalf and does not charge a listing fee. Coinbase says it charges neither listing nor application fees.
- How do I check an email from an exchange's listing team?
- Do not reply. Contact the exchange's official support through its website, opened by hand. OKX, for example, warns that it never sends emails from list@okx.com.
- How is a legitimate market maker different from a scam?
- A legitimate one supports liquidity and talks about spreads and order book depth. The scam version promises a specific trading volume generated by bots trading with themselves.
- What was Operation Token Mirrors?
- A 2024 FBI and Department of Justice operation in which the FBI created its own token, NexFundAI. Eighteen individuals and companies were charged and more than 25 million dollars was seized.
- What should a project do after paying a fake agent?
- Keep the correspondence and transactions, report to the exchange through official support and to Report Fraud at reportfraud.police.uk.