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Kalshi Employee Trade Surveillance Expands as $36B Lawsuit Looms

Kalshi employee trade surveillance Kalshi employee trade surveillance

Kalshi employee trade surveillance is expanding fast, with a new partnership between the prediction market operator and compliance technology provider Comply placing event contracts inside the same monitoring systems that regulated firms already use for stocks, bonds, and crypto positions.

Comply works with more than 5,000 primarily financial firms. The integration will feed Kalshi trading data directly into Comply’s regulatory software, letting employers track whether employees are holding event contract positions and whether those positions comply with internal policies.

How Kalshi Employee Trade Surveillance Works

The compliance stack Kalshi is assembling is broader than this single deal. In June 2026, StarCompliance and Kalshi announced what they described as the financial industry’s first enterprise-grade global compliance solution purpose-built for prediction market employee monitoring, with features covering automated surveillance across on-chain and off-chain prediction market ecosystems, configurable alerts, centralised case management, and audit tracking.

Then on 10 August 2026, Kalshi announced a multi-year partnership with Nasdaq Market Surveillance to support real-time detection of market abuse, manipulation, and insider trading, including delivery of Kalshi’s trade data to the Commodity Futures Trading Commission (CFTC) in the agency’s required format.

Comply already covers prediction market trades on Polymarket through a partnership with ZenLedger, a cryptocurrency tax and accounting firm. The Kalshi integration extends that reach across the two largest platforms in the space. Combined trading volume across Kalshi and Polymarket exceeded $40 billion in 2025, with Kalshi accounting for almost $23 billion of that, according to KPMG as reported by ICLG News.

Kalshi also expects the Comply system to extend to its planned perpetual futures products once those contracts are live. The monitoring would place prediction market positions alongside conventional regulated assets in the same employee disclosure workflow that banks and asset managers already operate.

The $36 Billion Question: Federal or State?

None of this compliance build-out exists in a vacuum. New York Attorney General Letitia James sued Kalshi on 31 July, seeking at least $36 billion in damages, penalties, and other relief. The 32-page complaint, filed in New York County Supreme Court, alleges Kalshi operated without a state licence and failed to prevent users under the age of 21 from signing up, according to Courthouse News Service. James is seeking to halt all of Kalshi’s contracts ‘relating to sports, culture, elections and other events.’

The legal timeline matters here. In October 2025, the New York State Gaming Commission issued Kalshi a cease-and-desist over its sports contracts. Kalshi sued in the Southern District of New York, arguing CFTC jurisdiction pre-empts state authority. The district court refused a preliminary injunction in July 2026; Kalshi appealed. The AG’s July lawsuit is a separate proceeding, according to ICLG News.

Kalshi removed the AG’s complaint to the U.S. District Court for the Southern District of New York shortly after it was filed. New York Supreme Court Justice Melissa A. Crane subsequently treated the state’s request for a preliminary injunction as moot. The procedural move does not dismiss the underlying allegations.

Governor Kathy Hochul had already signed an Executive Order in April 2026 banning state employees from insider trading using prediction markets, a signal that Albany views event contracts as within its regulatory reach, according to the New York Attorney General’s office.

Santos Case Raised the Stakes

The CFTC’s enforcement action against former U.S. Representative George Santos illustrates exactly what Kalshi employee trade surveillance is designed to catch. The CFTC’s order is the agency’s first-ever enforcement action alleging market manipulation in a prediction market, finding Santos violated Section 6(c)(1) of the Commodity Exchange Act by trading an event contract ‘where he could influence the outcome of the underlying event.’

Santos took an initial ‘Yes’ position on 12 February 2026 on a contract tied to his attendance at the 2026 State of the Union address, held on 24 February, and continued buying through 22 February. Early that day, he posted on social media asking whether he should ‘wear a muted or serious suit to the SOTU… or a bedazzled one?’, and the ‘Yes’ contract price rose sharply in the same window, according to Akin Gump’s analysis of the order. Kalshi’s in-house integrity monitoring had pushed Santos’ odds of attending to at least 75%, according to Yahoo Finance.

Under the 31 July order, Santos agreed to return $17,569.98 in trading gains, pay a $17,500 civil penalty, and accept a three-year ban from trading through CFTC-registered entities. He admitted no findings or legal conclusions. Kalshi had referred Santos’ activity to regulators.

The Comply partnership extends that referral logic upstream: giving institutional employers a direct feed of employee prediction market activity before a position becomes a regulatory case. Whether that compliance posture is enough to satisfy New York’s definition of a licensed operator is the question the courts will answer first.

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