Fraudulent behavior or plain illegal commercial conduct, a traditional competitive issue, is a topic of concern also in DFS: some examples are insider trading, market manipulation and false advertising. As an example, 48% of those that visited a pseudo-fraudulent crypto exchange website, created by the Brazilian Securities and Exchange Commission, would have bitten the hook and deposited their resources in a fake institution1. Authorities should not refrain from administrative or even criminal measures against illegal market conduct, risking a reputational crisis for both businesses and the authority.
1. Pakistan Today (2025), “Easypaisa set to drive Pakistan’s fintech revolution with backing from Telenor and Alipay”, https://profit.pakistantoday.com.pk/2025/01/30/pak-china-collaboration-easypaisa-becomes-pakistans-first-digital-bank/ (accessed on 26 August 2025).
Country Examples
The P2P lending platform Ezubao was exposed as a Ponzi scheme, listing mostly fake loans and defrauding nearly 900,000 investors of approximately $9 billion. This high-profile case highlighted severe market conduct failures and triggered sweeping regulatory reforms in the sector1.
1. BR Research (2018), “Alipay in Pakistan?”, Business Recorder, https://www.brecorder.com/news/405127/ (accessed on 26 August 2025).




