Not fraud
Fraud has a victim — a person, an account, an institution from whom value is taken. SFMA
can have a victim too, but its target is the market itself, the institution as a system,
or the macroeconomic surface a country sits on. The damage is measured in stability and
confidence, not in stolen balances.
Not AML
AML follows the proceeds of past predicate crime through the financial system. It is
retrospective by construction — the crime happened, the money is moving, the AML programme
tries to interdict it. SFMA is forward-looking: it watches for coordinated activity that
is preparing or executing a market-level effect, not laundering its proceeds.
Not market abuse (MAR)
Market-abuse regimes — MAR-style insider-dealing and instrument-level manipulation rules —
are about specific instruments and specific counterparties. SFMA is broader and systemic:
coordinated activity across instruments, venues, currencies and actors, intended to move a
market or a national balance sheet rather than to harvest mispricing on a single
instrument.
Not market manipulation in the narrow sense
Pump-and-dump, spoofing, layering and similar are tactical patterns; they can serve SFMA,
but a single instance of any of them is not SFMA. SFMA requires the coordination, the
systemic target, and the intent to disrupt stability or function — not just a price move.
Not classic sanctions evasion
Sanctions evasion seeks to move value past a regulatory wall. It overlaps with SFMA when
the evasion is itself part of a destabilisation effort, but the two are not equivalent.
Most sanctions-evasion screening fits inside AML / sanctions disciplines, not inside SFMA.
Not surveillance
SFMA detection works on the transactional and market patterns that regulated financial
institutions already collect under their existing mandates. It does not extend the data
the institution holds, and it does not import data from outside the regulated frame. It is
a different reading of existing data — not a new data acquisition.