WICS transforms financial product integrity from reactive, all-or-nothing approaches into a measurable, transparent, and rules-based framework that connects quantitative risk assessment with predetermined financial controls and settlement methodologies.
U.S. Patent Pending
From integrity measurement to financial settlement
WICS solves the problem of how to measure, manage, and financially account for manipulation risk and anomalous activity in event-driven financial contracts using transparent, predetermined, and proportional integrity controls.
The challenge
As markets expand into prediction markets, event contracts and novel indices, products increasingly depend on outcomes that are harder to validate, and that may be influenced by individual participants, concentrated groups or external sources.
Traditional instruments rest on established markets and independently verifiable reference values. Many new ones do not. That raises questions every product designer, exchange and participant should be able to answer.
An event may be accurately reported while the activity that produced it was influenced or manipulated. Accurate reporting of an outcome does not, by itself, establish the integrity of the underlying event.
The problem WICS solves
Under CFTC Designated Contract Market Core Principle 3, an exchange may list only contracts that are not readily susceptible to manipulation. As markets list contracts on events, statistics and data that participants can influence, that obligation becomes harder to meet, and the operational tools for meeting it have not kept pace.
Exchanges must evaluate susceptibility before listing and keep managing it for as long as a contract trades. For event-driven products there is often no standard, quantitative way to measure it, document it, or show how it is controlled.
When an outcome is anomalous or possibly manipulated, the response is typically post hoc: an investigation, a discretionary determination and a binary result.
Prediction markets and event-based financial contracts increasingly rely on outcomes that may be susceptible to manipulation or anomalous activity. Existing settlement approaches can be reactive, inconsistent, and binary, creating uncertainty for exchanges and market participants.
WICS provides a proprietary, quantitative integrity-control framework that evaluates susceptibility to manipulation and applies predetermined, graduated adjustments to financial indices and settlement values when specified integrity thresholds are triggered.
WICS helps exchanges and financial product developers design more transparent, resilient, and predictable financial contracts while strengthening market integrity and supporting regulatory compliance.
How a DCM lists a sports event contract today1
It picks the data source, settlement terms and surveillance on its own.
It certifies under Rule 40.2 that the contract meets the CEA.
Listing can follow one business day after filing, with no CFTC approval first.
No uniform event-contract test: The CFTC requires each DCM to determine whether a contract is “not readily susceptible to manipulation,” but has not prescribed a single event-contract-specific methodology for making that determination.
No standardized evidentiary framework: Rule 40.2 and Appendix C require explanation, analysis and supporting evidence, but DCMs may apply different analyses and controls to similar event contracts.
Regulatory exposure remains: An inadequate certification can be stayed, withdrawn and resubmitted, and a false certification can trigger Commission proceedings or enforcement.
Self-certification places the initial compliance judgment with each DCM; the CFTC has not established a uniform event-contract methodology that makes those judgments analytically consistent.
1. Source: CFTC Regulation 40.2 (listing products by certification); CFTC Staff Advisory 26-08, DCMs and Event Contracts (12 Mar 2026); CFTC Advance Notice of Proposed Rulemaking on prediction markets (Mar 2026).
CFTC enforcement, prediction markets, 2026
The Division of Enforcement cited real cases of a trader influencing an outcome and another trading on material nonpublic information. Insider-trading, fraud and manipulation rules apply, and DCMs must run their own surveillance and enforce their rules.
The CFTC alleged George Santos traded on whether he would attend the State of the Union while making public statements about his plans that moved prices in his favor.
The CFTC charged a White House teleprompter operator with using advance knowledge of presidential remarks to trade mention-market contracts.
These are the risks WICS scores before settlement: how much one actor controls each input, and who is close enough to the event to know or shape it first.
Charges are allegations. Source: CFTC Division of Enforcement Prediction Markets Advisory (25 Feb 2026); CFTC orders re: G. Santos (31 Jul 2026) and G. Perez (28 Aug 2026).
Sports betting integrity, 2025
The controls exchange filings cite are already standard in sports betting. Manipulation still gets through.
US commercial sports betting handle in 2025, up 11% on 2024
suspicious-betting alerts reported worldwide in 2025, up from 232 in 2024
matches proven corrupted in 2025 from operator betting data
Monitoring is catching more every year. It still runs beside settlement, so an alert cannot stop a bet that has already paid.
1. American Gaming Association, Commercial Gaming Revenue Tracker, full-year 2025 (Feb 2026).
2. International Betting Integrity Association, 2025 Sports Betting Integrity Report (3 Feb 2026).
The gap in today's filings
Event-contract self-certifications typically cite the controls an exchange already has. What they seldom show is how those controls address the event itself: who can influence it, how, and what happens at settlement if they do.
Objective data, position limits, KYC, surveillance, collateral and compliance review.
Who can influence the outcome, how manipulation could occur, why the settlement source resists it, and how the contract design mitigates those risks.
A quantitative, documented answer to each of those questions before listing: controllability of the outcome, reliability of the settlement source, and the design controls that address the risks.
Platform surveillance for wash trading, spoofing and front-running, plus position limits, alerts, audit trails, halts and discipline.
How those controls catch manipulation of the event or settlement itself, including an official result reported accurately but influenced, and how they fit each contract.
Integrity gates and data validation applied to the event and settlement data, contract by contract, so an accurately reported but influenced result can be identified and handled under predetermined rules.
General prohibitions, surveillance, investigations and disciplinary procedures.
How participants are protected from insider access, participant control of the event, restricted persons and informational advantages in each product.
A contract-by-contract assessment of who could hold insider access, influence the event or hold an informational advantage, with the treatment of qualifying integrity events disclosed before trading.
Filings describe general exchange compliance but don't connect it to each contract's manipulation, settlement and participant-protection risks: the contract-specific "how and why" the CFTC now expects in a Part 40 filing.
WICS is designed to supply that connection, product by product.
The combined offer
Extended to every kind of event contract, plus what exchanges and regulators need to rely on it:
Baselines and thresholds set by formula from objective data, not by discretionary judgment.
Predetermined integrity gates and rule-based responses for single-outcome event contracts.
Susceptibility and controllability assessment to test and strengthen a contract before listing.
Margin and settlement marks derived from a mechanical formula, not from the market being settled.
Assessments, triggers and calculations documented as the contract runs, ready for review and filings.
Where the integrity check sits
Review happens before money moves. A suspect value never reaches any venue, so nothing has to be clawed back.
Regulatory solution
WICS moves manipulation-susceptibility controls from post hoc to ex ante. Integrity is measured before a contract is listed and monitored throughout its life, and the responses to specified integrity conditions are defined in advance. WICS combines quantitative assessment, predetermined controls, data-integrity protocols and configurable financial adjustment mechanisms within a single methodology.
WICS provides a documented methodology for product design, risk assessment, surveillance, and settlement governance, supporting exchanges' efforts to meet applicable CFTC core principles.
Supported by
Measures susceptibility to manipulation, controllability, and anomalous activity using weighted integrity scores and coefficients.
Establishes predefined thresholds, methodologies, and adjustment mechanisms before contracts are traded, so controls are ex ante rather than post hoc.
Validates reference values and enables graduated adjustments to index values and financial settlement amounts rather than relying exclusively on binary accept-or-cancel decisions.
Turns integrity analysis into better contract design, so exchanges can list new event-driven products with susceptibility controls built in from the start rather than added after problems arise.
Evaluate susceptibility to manipulation, external influence, anomalous activity and weaknesses in underlying data.
Convert integrity characteristics into measurable scores, coefficients and weighted assessments.
Define objective thresholds, validation requirements and predetermined responses.
Evaluate observations against established integrity parameters.
Where contract terms provide, apply predefined, graduated adjustments to values or settlement.
Measure · Quantify · Control · Validate · Settle
Market integrity & regulatory applications
WICS is a proprietary quantitative integrity-control framework designed to help financial exchanges evaluate, demonstrate, and manage compliance with regulatory requirements that listed contracts not be readily susceptible to manipulation, while integrating predetermined integrity controls into financial product design, valuation, and settlement.
In the United States, the CFTC oversees designated contract markets and other derivatives-market participants under the Commodity Exchange Act. WICS supports the systematic assessment and documentation of integrity risks relevant to those responsibilities.
Assess underlying events, variables and reference values before new products are introduced.
Document the factors associated with a product's potential vulnerability to manipulation or influence.
Identify where predetermined safeguards and validation requirements can be built in.
A structured methodology for internal product reviews and documented assessments.
Clear measurement methods, reference-data requirements and predefined provisions.
Communicate how measurement and settlement methodologies work before contracts are entered.
The core principles most relevant to event contracts, and the contract-specific evidence WICS produces for each.
Core Principles 2, 3, 4, 5 and 12 are CEA section 5(d)(2), (3), (4), (5) and (12). Rulemaking is still open. Source: CFTC Staff Advisory 26-08, DCMs and Event Contracts (12 Mar 2026); CFTC Advance Notice of Proposed Rulemaking on prediction markets (Mar 2026).
Core Principle 3 is the primary objective WICS is designed to support. Its analysis and documentation may also be relevant to Core Principles 2, 4, 5 and 12: rule enforcement, market-disruption prevention, position limits or accountability, and participant protection.
Depending on the product, WICS analyses may inform internal reviews associated with CFTC Part 40 product-submission procedures.
WICS is not a regulatory approval mechanism. Its use does not establish that a contract complies with applicable law, eliminate susceptibility to manipulation, or replace required regulatory assessments.
WICS cannot make an otherwise impermissibly manipulable contract eligible for listing simply by applying an adjustment.
The WICS methodology
Each component can be used on its own or combined according to the characteristics of the underlying product. Factors, weightings, calibration and adjustment schedules are proprietary and are shared only in confidential commercial discussions.
Assessing the integrity characteristics of financial products
A proprietary assessment of whether an event, variable, index or product can support reliable measurement and settlement, applied before an instrument is introduced.
In WICS, "sustainability" means the durability and reliability of a product's integrity characteristics, not environmental sustainability.
Quantifying susceptibility to external influence
Some events are substantially independent of market participants; others can be affected by parties with an economic interest. The Controllability Coefficient is a proprietary measure of that distinction.
Usable as an independent risk indicator or combined with other WICS metrics.
Predetermined conditions for additional controls
Predefined conditions that distinguish ordinary fluctuation from conditions warranting a specified response, from further review to a predetermined adjustment.
Not every gate requires a financial adjustment; some serve only assessment, monitoring or validation.
Proportional responses to defined integrity conditions
A configurable mechanism that applies predetermined, proportional adjustments when qualifying conditions occur, bridging integrity measurement and financial settlement.
What makes WICS different · The WICS value chain
Identifying unusual behavior and deciding how it should affect a financial contract are separate challenges. WICS connects them through predetermined methodologies, making it valuable both as a product-development methodology and as a financial settlement-control framework.
The underlying event or variable is evaluated before listing.
Findings become weighted integrity scores.
The potential for interested parties to influence the outcome is measured.
Integrity gates and responses are defined and disclosed in advance.
Observations are checked against the established requirements.
Settlement reflects rules everyone knew in advance, with graduated adjustments where provided.
Surveillance focuses on improper trading and market abnormalities. WICS extends the focus to the underlying events and variables themselves: their controllability, data independence and measurement reliability.
It is designed to complement established surveillance and compliance systems, not replace them.
When exceptional circumstances arise, remedies are often limited to accepting, rejecting or canceling. WICS adds graduated integrity adjustments, so that where contract terms permit, a reference value or obligation can be modified proportionally.
Integrity rules and adjustment parameters are established before an event occurs, emphasizing consistency, documentation and advance disclosure.
Participants can evaluate the consequences of specified integrity conditions before taking on exposure.
How WICS works
Define the underlying variable and assess its integrity characteristics before the product is introduced.
Apply WICS scoring and establish the product's predetermined integrity controls.
Evaluate observations and reported outcomes against those controls as the contract runs.
Apply any predetermined response, calculate the applicable value and keep an auditable record.
Graduated settlement methodology
Consider a hypothetical contract that settles on the movement of an underlying index. Rather than accepting the entire unadjusted movement or canceling the contract, a predefined methodology produces a graduated financial result.
| Unadjusted index movement | 10 points |
| Contractual value per point | $100 |
| Qualifying integrity condition | Triggered |
| Predetermined adjustment factor | 50% |
| Adjusted index movement | 5 points |
Actual adjustment schedules, calculations and settlement consequences depend on the applicable product methodology and contractual terms. The example does not suggest that any particular adjustment would be permissible for every regulated financial instrument.
Flexible implementation
Not every product requires the same controls. Financial adjustments are an optional application, not a mandatory feature.
Evaluate a product's integrity without changing its valuation or settlement.
Apply predetermined metrics and thresholds to observe qualifying changes.
Review and validate underlying measurements and reference values.
Build integrity considerations into specifications and calculations.
Apply contractually authorized adjustments when conditions occur.
Applications & engagement
Just as financial products incorporate pricing models, volatility assumptions and reference-data methodologies, WICS establishes integrity as a measurable financial input. Because it focuses on an underlying variable, its integrity characteristics and its financial consequences, it is not limited to prediction markets, binary contracts or exchange-traded instruments.
Separating independently verified events from those dependent on discretionary conduct or concentrated information.
Quantitative product assessments and a shared language for product, risk, surveillance and compliance teams.
Swaps, futures, options, collars and bilateral contracts referencing measurable variables.
Documented validation, with separate unadjusted and adjusted values for auditability.
Validation conditions and fallback methods for observations affected by equipment failure or inconsistent sources.
Reliability, controllability and verifiability of game outcomes and statistics. WICS does not itself determine whether a contract is permissible.
Data assessment, threshold structures and predetermined calculations for measured triggers.
Reference-data integrity and predetermined settlement methodologies for clearing organizations.
Regularly updated susceptibility scores, controllability assessments, threshold monitoring, anomaly indicators and supporting reports, without building the infrastructure in-house.
WICS scoring, product-assessment, threshold and graduated-adjustment methodologies for internal product-development and risk processes.
Enterprise, product-specific or institutional licensesIndependently verified reference values, integrity status indicators and predefined settlement notifications that multiple products can reference.
Data subscriptions, API or per-productEvaluation of proposed event contracts, susceptibility analysis, redesign of higher-risk structures and design of graduated settlement provisions.
Engagements and partnershipsSelected WICS calculations and controls built into existing exchange, data, surveillance and settlement platforms.
Technology licensing and supportCollaboration with exchanges, technology providers, data providers and research organizations on new applications.
Negotiated arrangementsMost institutions begin with a stand-alone product assessment. Tell us about the contract you are designing.
Contact WICS →Institutions can begin with stand-alone product assessment, with no integration into live settlement systems, and expand from there.
Screening, quantitative scoring and supporting documentation.
Controlled pilots of assessments, data validation, integrity gates and reporting.
Automated scoring, configurable thresholds and integrity notifications.
Selected applications in settlement calculations, subject to testing, legal review and regulatory requirements.
Enterprise licensing, recurring data services and integration partnerships.
Integrity as shared financial infrastructure
Markets often support many instruments that reference the same underlying event, measurement or index. WICS performs integrity assessment and reference-data validation at the level of the underlying measurement, so each authorized product can rely on a common verified value while keeping its own terms, payoffs and settlement periods.
Integrity assessed and data validated once, at the source.
Public-interest factors
How WICS products answer two public-interest factors in the CFTC's June 2026 proposed rule on event contracts.1
Most event contracts can't name a commercial hedger.
The proposal cites a sports team's effect on local hotels and restaurants.
A cleared, published departure index shows whether the team is beating its own history, which predicts attendance and spending better than one game's result.
WICS products are designed to meet the public-interest factors on top of the manipulation test.
1. Source: CFTC Notice of Proposed Rulemaking amending Regulation 40.11 and adding Appendix F to Part 40, event contracts (10 Jun 2026). Proposal is not final and may change.
Why it matters
For exchanges, clearing organizations, product developers and market participants, WICS helps address integrity considerations before they become unexpected operational or settlement issues.
The framework supports integrity management but does not eliminate manipulation risk or override applicable regulatory requirements.
Value across the product lifecycle
Evaluate underlying integrity characteristics.
Quantitative measurements and defined thresholds.
Data validation and integrity notifications.
Predetermined methods for specified conditions.
Documented assessments and calculation records.
The value of product redesign
When a proposed contract presents elevated manipulation or settlement risk, the choice need not be limited to accepting the original design or abandoning the idea. WICS provides a quantitative basis for evaluating alternative structures that preserve useful economic exposure while improving integrity characteristics.
The objective is not simply to identify problematic contracts. It is to support the development of better-designed ones.
Concentrated control and a single point of failure for settlement.
Similar economic exposure, with integrity risk spread across many sources.
Bars illustrate relative manipulation susceptibility, conceptually. A redesigned product still requires independent legal, regulatory and risk assessment.
WICS Leadership
Advance financial products through systematic integrity measurement, transparent methodologies and predetermined controls.
Provide a flexible framework for evaluating integrity risk, strengthening reference data and defining contractual outcomes.
Quantitative discipline, transparency, documentation and adaptability to each market and product.
White papers
Explore WICS research and industry white papers examining emerging regulatory challenges, market integrity, susceptibility to manipulation, derivatives innovation, and evolving financial market structures. Our publications analyze current legal and regulatory developments and present innovative approaches to strengthening financial product design, transparency, and market resilience.
Register once to download any WICS white paper.
Divided Courts, an Expanding CFTC Record, and the Missing Contract-Level Integrity Test
The circuit split over sports event contracts, the CFTC’s 2025–2026 record, enforcement and integrity evidence, and the gaps that remain under Core Principles 3 and 4, followed by a proposed response.
Download white paperQuantitative screening, objective triggers and rule-based settlement controls
How WICS scores and screens contracts before listing, monitors designated signals during a contract’s life, and applies predefined settlement controls, with illustrative economics and governance safeguards.
Download white paperFrequently asked questions
WICS stands for Weighted Integrity Control Systems. It is a proprietary framework for evaluating the integrity characteristics of measurable events, underlying variables, reference values and financial contracts, integrating weighted scoring, controllability assessment, predetermined thresholds, data-validation protocols and configurable financial adjustment mechanisms.
It addresses how to measure, document and manage integrity risks in products whose values depend on potentially manipulable, anomalous or unreliable information, and how specified integrity conditions should affect financial calculations and settlements.
Not primarily. WICS is built around the integrity of underlying events, measurements and reference values. It can complement surveillance systems with tools for product assessment, data validation and predetermined contractual controls.
No. WICS is product-agnostic, with potential applications in derivatives, indices, reference-data methodologies, insurance-linked and weather instruments, structured contracts and other measurable financial products.
The Sustainability Score evaluates the reliability, durability and integrity of an underlying product or variable. The Controllability Coefficient evaluates the ability of individuals, organizations or other actors to influence an underlying event or measurement. Both can feed a weighted integrity assessment.
A predetermined condition that triggers a specified response when defined requirements are met, such as validation, further review, escalation or an authorized contractual calculation.
No. Depending on the product and its rules, WICS may support assessment, monitoring, validation or predetermined adjustments. Any cancellation or other consequence depends on the governing product terms.
Not necessarily. A score or triggered threshold does not by itself establish that anyone manipulated a market or event. A determination of unlawful manipulation is a separate legal and evidentiary matter.
WICS helps identify and manage specified vulnerabilities but cannot guarantee manipulation will not occur. Its value lies in structured assessment, transparency, defined controls and the financial treatment of qualifying conditions.
Yes. WICS can be used independently for product assessment, monitoring, documentation or data validation. Financial adjustments are optional.
No. WICS is an analytical and product-design methodology. Its use does not guarantee regulatory acceptance, product eligibility or compliance with applicable law, and it does not replace legal analysis or compliance obligations.
No. It is designed to complement existing governance, risk management, surveillance and compliance frameworks with additional quantitative tools and predetermined methodologies.
Integrity by design
Financial markets depend on confidence in the information, measurements and methodologies that determine contractual values. WICS connects quantitative assessment, weighted scoring, integrity gates, data validation and predetermined financial controls across the entire product lifecycle.
WICS welcomes discussions with exchanges, financial institutions, technology providers, product developers and other organizations interested in measurable integrity controls and financial product innovation.
Quantifying Integrity · Strengthening Markets · Enabling Innovation