Cryptocurrency Market Makers: Distinguishing the Real from the Fake – Tiger Research

Key takeaways

• The distrust towards market makers stems from price manipulation firms posing as market makers. The lack of clear qualification criteria has led to the indiscriminate use of the name.
• Legitimate market makers narrow spreads and act as constant trading counterparts, reducing transaction costs for investors. Projects should entrust independent market makers to avoid suspicions of price manipulation.
• Cryptocurrency market makers perform similar functions as those in traditional finance, but there is no system for formal contracts with exchanges, and contracts with issuers are not disclosed, operating in a fragmented market. Trading with their own funds is already legal, and the regulatory gap lies in contracts.
• The Digital Asset Basic Law presents the first opportunity to address this issue. However, while the proposal allows market making entrusted by exchanges, contracts entrusted by token issuers are only recognized for six months post-listing. The problematic issuer contracts must be brought into the regulatory framework.

1. Why are market makers perceived as 'forces' in the cryptocurrency market?

Anyone who has experienced the cryptocurrency market is familiar with a common situation: prices that soar immediately after listing suddenly plummet, and previously abundant trading volumes vanish in an instant. Cryptocurrency investors often cite market makers (MM) as the culprits behind these price fluctuations.

This negative perception has arisen from firms that manipulate prices under the guise of market makers. Due to such firms, the meaning of market makers has been distorted to signify price manipulation forces in the cryptocurrency market, leading to continuous investor losses globally.

In fact, the FBI has prosecuted firms engaged in 'service-type price manipulation,' and in South Korea, a group that manipulated trading volumes under the guise of providing liquidity has received prison sentences. However, these are illegal firms that merely offload quantities for a fee, not market makers fulfilling their original roles. The absence of clear qualification criteria has led to the indiscriminate use of the name market maker, ultimately undermining trust across the industry.

Such price manipulation activities only erode market trust and are unrelated to the true role of market makers, which is to provide liquidity.

2. Why are market makers needed in the market?

Market makers are key participants who provide liquidity by simultaneously presenting buy and sell quotes, facilitating transactions. It is essential to clarify their role to understand why they are needed. In South Korea, the term 'liquidity provider (LP)' is commonly used alongside 'market maker.'

Broadly speaking, liquidity provision is not limited to companies with specific qualifications. Orders that remain on the order book waiting for a match (maker orders) create trading counterparts for other investors. Therefore, any participant placing maker orders is, in a broad sense, providing liquidity. High-frequency trading (HFT) firms like Jump Trading, which trade with their own funds and fill the order book, also fall into this category.

Just as airport currency exchange counters guarantee exchanges at any time, markets with market makers do not require buyers and sellers to wait for each other. This benefit extends to both investors and token issuers.

2.1. What investors gain: Reduced transaction costs

The actual profit and loss for investors is not determined solely by fees. Factors such as whether orders are executed immediately at desired prices, whether large trades cause price fluctuations, and whether there are price differences between exchanges are more critical hidden costs.

What market makers do is ultimately fulfill these three conditions. They place tight buy and sell quotes, stand on the opposite side even when there are no trading counterparts, and align prices across exchanges. As a result, investors can trade at similar prices with lower costs whenever they wish.

• Reduced transaction costs: Narrowing the spread between buy and sell prices, reducing additional costs for large orders.
• Trading when desired: Always having trading counterparts available.
• Narrowing price differences between exchanges: Simultaneous quotes across multiple exchanges, leading to price convergence through arbitrage.

First, transaction costs decrease.

The difference between the buying and selling prices (spread) is also a cost. If the price to buy immediately is 1,010 won and the price to sell immediately is 990 won, simply reselling right after buying would result in a 2% loss. The loss increases with larger orders. After buying all the quantities at the first price, one must move on to the next price, which becomes progressively more expensive. When market makers place tight quotes, this difference narrows, and more quantities are available at each price level. Consequently, the losses seen during trading decrease.

Second, one can buy and sell whenever desired.

In investing, the ability to enter and exit at the desired moment is crucial. Tokens with low trading volumes require sellers to wait for buyers to appear, during which prices continue to fluctuate. Market makers consistently place quotes and act as trading counterparts. Therefore, even during times with minimal trading activity, sellers can find immediate buyers, and buyers can purchase without waiting.

2.2. What token issuers gain

For token issuers, listing is not the end but the beginning. Tokens must continue to be traded post-listing for users and investors to engage, and for the tokens to be valued appropriately. Market makers maintain this market on behalf of the issuers. Token issuers gain two benefits through market makers.

• Ensuring consistent trading: Mitigating significant price fluctuations even with small orders.
• Avoiding suspicions of price manipulation: Independent market makers manage quotes while token issuers only lend quantities.

First, they obtain a market where tokens are consistently traded. Listed tokens are evaluated daily in the market. Users buy tokens to use services, and investors buy and sell based on potential. For these participants to engage freely, tokens must be recognized at their true value. Tokens with low trading volumes experience significant price fluctuations even with small orders, and such volatility increases anxiety and damages the reputation of token issuers, regardless of their actual performance.

Second, they can avoid suspicions of price manipulation. If token issuers buy and sell their tokens directly, they are easily suspected of manipulating prices. Therefore, trading is entrusted to independent market makers, and token issuers only lend quantities. Normal contracts also include clauses to prevent price manipulation.

In summary, investors can significantly reduce the trading costs they bear while executing trades in a timely manner, and token issuers can create a trading environment where their assets circulate stably. The spread that market makers receive from buying and selling is a kind of service fee borne by market participants wishing for immediate transactions. Only when these trading costs are gradually reduced through autonomous competition in the market will all members of the ecosystem benefit.

3. What distinguishes cryptocurrency market makers?

The functions of cryptocurrency market makers are not different from those of traditional financial market makers. However, the difference lies in the regulations of the markets and countries in which they operate. Stock market market makers work under formal contracts with exchanges and refined regulations. In contrast, there is currently no system to handle contracts between market makers and exchanges or issuers in the cryptocurrency market.

3.1. Who performs these roles?: Traditional market makers are licensed financial institutions, while cryptocurrency market makers have no contractual qualification requirements

In traditional finance, market makers have a clearly defined official role by law. Financial institutions that pass the review enter into formal contracts with exchanges and receive benefits such as reduced fees in exchange for submitting quotes as promised. Exchanges transparently disclose who the market makers are for each asset, and there are long-established legal standards that clarify what constitutes 'normal market making'.

However, the situation in the cryptocurrency market is entirely different. While the role of market makers is the same, there is essentially no 'framework' in which market makers enter into formal contracts with exchanges and exchange obligations and rewards.

The decisive differences between the two markets can be summarized in two main points.

• First, the absence of rules regarding contracts. There is no established framework defining what constitutes normal market making, who can become a market maker by contracting with an exchange, what obligations they bear, and what rewards they receive.
• Second, the unique structural risks of the cryptocurrency market. It is common for exchanges to take on the role of market makers themselves or for market makers to secretly enter into contracts with token issuers. Given this situation, major financial authorities around the world are focusing on urgent measures, such as preventing exchanges from operating market makers together and requiring the transparent disclosure of secret contracts, rather than creating entirely new systems from scratch.

The South Korean market faces the same challenges. While it strictly prohibits exchanges from acting as market makers, there is a lack of criteria or formal procedures to judge what constitutes proper market making.

It is important not to misunderstand this point. The area where rules are lacking pertains to the official contracts that market makers enter into with exchanges or securities firms. This contract is also where licensing is required. The act of placing bids and trading with one's own funds is already a legal activity, regardless of licensing. The EU MiCA does not require a license for market making with one's own funds within an exchange, only imposing requirements when providing services to customers.

3.2. Who and What Contracts Are Made?: Traditional Finance with Exchanges, Cryptocurrency with Exchanges and Token Issuers

The most notable difference between cryptocurrency market making and traditional finance is the prevalence of contracts with token issuers.

Among these, the 'contract-free self-capital model' is different in nature. It does not enter into contracts with anyone and does not receive compensation. Trading is done according to one's own strategy with one's own funds, and liquidity arises as a result. This falls under the broad definition of liquidity provision and is already a legal activity that does not touch upon licensing. The token lending model also resembles self-capital trading in essence if the market maker bears the trading judgment and price risk directly without the issuer directing individual trades.

The problems arise particularly in contracts with issuers that measure performance by trading volume. According to industry insiders, such contracts differ from exchange-led contracts in terms of funding sources and risk-bearing entities, covering a wide range from spread setting to strategies for responding at listing and lock-up release points. However, contract structures that take trading volume as the main performance indicator carry a high risk of inducing wash trading, and the fact that the contract details are not disclosed externally is cited as a major limitation.

3.3. In What Markets Are Trades Made: Traditional Finance in a Single Market, Cryptocurrency in Fragmented Markets

Stocks are traded at a designated time on a single exchange, with exchanges and clearinghouses preventing price volatility and settlement risks. In contrast, cryptocurrencies are fragmented across exchanges worldwide, operating 24/7 without any mechanisms to mitigate these risks. This fragmented liquidity provision poses risk factors for market makers.

First, the cryptocurrency market, which operates 24/7, is divided among numerous exchanges worldwide, leading to frequent price imbalances. Market makers spread their assets across multiple exchanges to correct these imbalances, but if network issues such as withdrawal and deposit suspensions occur, this market correction function can be paralyzed in an instant.

The extremely limited means to hedge risks is also a problem. Without safety devices like circuit breakers and rampant high-leverage futures trading, market makers take opposite futures positions to prepare for price fluctuations.

As revealed during the $19 billion chain liquidation event on October 2025, when the exchange's automatic debt reduction (ADL) system is activated, even normal hedge positions of market makers can be forcibly terminated. As they lose even the minimal defensive barriers, the market shock and chaos escalate uncontrollably as they hastily withdraw their quotes.

Above all, the fundamental issue lies in the lack of a central clearinghouse (CCP) in the settlement structure. Unlike the traditional financial system, which guarantees transactions and settlements, cryptocurrency market makers must trade while directly depositing assets with each exchange. Therefore, if an exchange collapses, like FTX in 2022, market makers face a catastrophic crisis where they cannot recover any of their assets and incur total losses.

4. Five Limitations of the Current Market Maker Industry

The role of market makers is essential for smooth asset trading. However, if indiscriminate market-making activities are left unchecked, they can significantly undermine market stability. Now is the time to accurately diagnose the structural problems facing the cryptocurrency market and find practical solutions.

The five limitations discussed in the following sections are not flaws inherent to the function of market makers. They arise because there are no clear standards or monitoring systems to distinguish between normal liquidity provision and illegal market manipulation. Ultimately, current cryptocurrency market makers must establish proper standards in the market.

4.1. Normal Risk Management Is Misunderstood as Market Manipulation

Normal risk management activities of market makers can easily be misunderstood as market disruption or manipulation from an external perspective. Industry insiders have identified four representative risk management activities that are prone to misunderstanding.

If what is normal is not defined, such misunderstandings can occur even in markets with established systems.

A representative example is the Korean stock market. In 2021, the Financial Supervisory Service deemed frequent quote corrections and cancellations by nine securities firms' market makers as market disruption and notified them of a fine of 48.7 billion won, leading to an immediate halt in market making. About a year later, in July 2022, the Securities and Futures Commission concluded that corrections and cancellations for compliance and risk management were unavoidable, and that the correction and cancellation rates (95.68~99.55%) were similar to that of the New York Stock Exchange (about 94.6%) and that there were no prior standards, leading to a conclusion of no wrongdoing. Although it was not illegal, the market operated without market makers for a year until the conclusion was reached.

In the cryptocurrency market, the lack of clear standards leads to conflicting claims of liquidity provision and market manipulation regarding the same trades in court. Even normal market makers cannot predict the legality of trades, leading to their withdrawal from the market.

The solution is to establish standards for normal activities in advance. The criteria should not be based solely on the frequency of cancellations but should consider the intent to execute trades, aligning with the approach taken by the U.S. during the 2010 flash crash, which only prohibited extreme price quotes. Industry professionals also view compliance with contracts and risk management regulations, actual price risk reduction, and the purposefulness based on two-way quotes as core criteria.

• Was it executed within the pre-defined contracts and internal risk management regulations?
• Did the action actually reduce the market maker's price risk?
• Was it conducted based on two-way quotes without the intention of pushing the price in one direction?

For example, if one sells spot while buying the same amount of futures during a market fluctuation, it may outwardly appear as a selling pressure, but it is a normal hedge that offsets the overall position's risk. In contrast, selling a large amount of spot while spreading negative rumors without hedging is hard to view as risk management. If such criteria are publicly announced by regulatory authorities and exchanges, legitimate suppliers can operate without legal uncertainties, and illegal activities can be more clearly filtered out.

The problems arising from the lack of criteria do not end with legitimate companies being suspected. Conversely, it also becomes easier for non-market maker firms to pose as market makers.

4.2. Volume Manipulation Firms Posing as Market Makers

If the previous discussion highlighted the issues of legitimate market makers being suspected, there is also the problem of non-market maker firms posing as market makers. Many incidents remembered as 'market maker's faults' are cases where entirely different businesses operated under this name.

Gotbit is a representative example. According to U.S. prosecutors, Gotbit sold a service that inflated trading volume through a program that repeatedly bought and sold among multiple accounts from 2018 to 2024. The goal was to raise the cryptocurrency market cap ranking of customer tokens and list them on major exchanges. The founder pleaded guilty and was sentenced to eight months in prison, and the company had approximately $23 million worth of cryptocurrency confiscated.

Current market makers pointed out that their business model was fundamentally about creating fake trading volume without supporting price risk. In a market that only looks at trading volume, such firms may appear to perform better.

Therefore, the criteria for evaluating market makers should shift from trading volume to whether actual trades can be executed. Trading volume can be inflated through wash trading. Current market makers only reference trading volume as a result and instead look at the following:

• How thick are the orders within 1-2% of the current price?
• How much does the price drop when trading a certain amount?
• How long are buy and sell quotes placed simultaneously?

No matter how abundant the trading volume appears, if the order book is thin and minor orders can significantly shake the price, it indicates a lack of actual liquidity. Ultimately, the key criterion is whether external participants can smoothly execute their desired quantities at reasonable prices. When exchanges and issuing entities carefully select market makers based on these essential evaluation factors, firms that aim solely for illegal price manipulation will gradually be expelled from the market.

Registration or approval can be required from firms that enter into contracts with exchanges or issuers and sell services under the name of market makers. Firms like Gotbit, which sold services for money from issuers, can be filtered out from the outset by setting requirements at the contract stage. There is no need to bind participants trading with their own funds to approval. As seen in Chapter 3, the EU MiCA also requires licenses only for customer-facing services, not for market making with one's own funds within exchanges.

4.3. Distorted Interests with Unclear Contracting Parties

Even if capable firms are selected, if the structure of who contracted with whom is opaque, fatal problems can arise. In the cryptocurrency market, it is often unclear who the contracting parties are between token issuers and market makers. This lack of transparency can lead to absurd structures where one firm acts as an agent for both sides of a transaction.

The MOVE case exemplifies this. The Movement Foundation entrusted 66 million tokens, which is 5% of the supply, to the intermediary Rentech, claiming to be a subsidiary of Web3Port, for liquidity provision. However, it was revealed that Rentech was named as an agent for the foundation once and as an agent for Web3Port at another time in the contract. This meant the same firm was present on both sides of the transaction.

This volume was dumped into the market shortly after listing in December 2024, with almost no buy orders. Binance expelled the market maker and froze $38 million in profits. Coinbase subsequently halted MOVE trading. The foundation stated that this sale occurred without their consent. Although it was named a liquidity provision contract, what actually happened was a unilateral disposal of the token issuer's volume rather than a two-way quote.

Therefore, the essence of proper market making lies in fair contract terms and transparent contractual relationships.

First, let’s look at the content aspect. Contracts of normally operating market makers have two firm principles. The market maker bears actual price risk, and the token issuer does not interfere with the market price.

In the case of token lending, the market maker provides two-way quotes with borrowed tokens and its own funds. After the contract ends, the same quantity is returned, and there are no instructions to lead the price in any direction during that time. To ensure this, the contract must include the following essential items:

• Prohibition of wash trading
• Prohibition of actions that push the price in a specific direction
• Upper limit on the price difference between buy and sell
• Minimum quote volume

Even in call option contracts, if the market maker sets the usual quotes themselves and the token issuer only sets the option conditions without directing individual trades, the same principles are upheld.

Next is making contracts visible. At a minimum, exchanges and regulatory authorities should be able to verify which market makers are present with what volumes and conditions, and whether intermediaries are not representing both sides simultaneously. This is the information Binance will require from token issuers starting in March 2026. Furthermore, just as exchanges disclose market makers for specific stocks in the stock market, investors should also be able to know which market makers are involved.

4.4. Conflicts of Interest When Market Makers Are Under the Same Roof as Exchanges

If a market maker is an affiliate of an exchange, the conflicts of interest become even greater. When one company operates an exchange, custody, and proprietary trading, affiliate market makers are likely to receive privileges not available to other users.

FTX and Alameda Research are representative examples. Alameda acted as a major market maker for FTX and received credit limits and privileges not available to other users. U.S. authorities determined that FTX customer deposits flowed to Alameda to cover investments and losses. The two companies went bankrupt together in 2022. The issue was not the status of being a market maker itself. It was that the credit and discretion associated with that status were used to misappropriate customer assets without any oversight.

Thus, the solution is not to outright ban affiliate market makers, but to separate and monitor the organizations. The International Organization of Securities Commissions (IOSCO) identified this conflict of interest as a key issue in its 2023 recommendations, and Hong Kong has translated this into a system. The Hong Kong Securities and Futures Commission (SFC) allowed market making by exchange affiliates starting in February 2026, with three conditions:

• Market making organizations must be functionally separated from the exchange
• Clear operational boundaries must be established between the two
• An independent professional institution's inspection report must be submitted to the authorities before starting market making

This is a way to draw lines and monitor to prevent privileges and information sharing. If domestic exchanges engage in market making through affiliates or related parties, the same principles must be applied from the outset.

4.5. Market Makers Without Obligations Exit First in Crises

While the previous four cases highlight limitations in ordinary situations, the last item reveals problems that emerge during extreme market downturns.

Most cryptocurrency market makers do not have mandatory obligations to uphold in a declining market. When losses accumulate, the decision to withdraw quotes acts as a rational response, leading to order gaps that can cause the market to collapse rapidly. The incident on October 10, 2025, serves as a representative example. At that time, many cryptocurrencies plummeted by 40% to 70%, and industry insiders assessed that the withdrawal of quotes by market makers was a decisive factor.

To prevent exits during a crisis, clear obligations and appropriate incentive structures must accompany them. In fact, entities adhering to mandatory norms displayed entirely different behaviors during crises. According to interviews with industry insiders, in the case of certain cryptocurrencies that plummeted due to macroeconomic downturns, market makers temporarily widened the buy-sell spread while maintaining quote placements to prevent trading interruptions. This difference stemmed from compliance with contractual obligations and risk management guidelines.

Traditional stock markets have institutionalized such mechanisms. The Korea Exchange imposes an obligation on market makers to submit quotes for specific stocks at least 80% daily and 90% quarterly, providing incentives only to those who comply. Penalties are imposed for non-compliance, and exceeding a certain level results in contract termination and a one-year disqualification.

A standard for measuring compliance is also necessary. Current market makers judge recovery after market shocks not by price rebounds but by whether trading functions have resumed.

• Is the gap between buy and sell prices narrowing again?
• Are the previously missing quote volumes being filled again?
• Are price differences between exchanges converging?
• How long does it take to return to normal?

If these indicators are used as compliance criteria and compensated accordingly, market makers will have more reasons to stay during crises than to leave.

From Regulation to Management

The distrust towards market makers in the domestic market is not unfounded. However, as seen in the previous section, the issue did not lie with the function of market makers. Anyone can claim to be a market maker, and there is no defined structure for what is normal.

Domestic laws still leave this structure intact. However, it is crucial to pinpoint where the gaps are. Activities that involve trading with one's own funds and filling quotes are still legal. The same applies to cases where tokens are borrowed for operation. Such activities can be punished if they constitute market manipulation like any other trading, but they are not problematic solely because they involve proprietary trading. The gray area lies outside of this, in the contractual aspect.

• There is no channel to enter into official contracts with exchanges. The current cryptocurrency user protection law prohibits market manipulation without exceptions for market making. Therefore, if an exchange enters into a quote obligation contract with a market maker, the trading under that contract risks being treated as market manipulation.

• There is no licensing or registration system for contractual market makers.

• It is difficult for corporations to open accounts and trade on domestic won exchanges.

Ultimately, what lies outside the system domestically is not the liquidity provision activities themselves but the channels to officially contract and manage them. Contractual market makers have no way to be managed within the system, and only post-facto regulation remains. Major countries are already restructuring their systems to align with this trend. Regulations on unfair trading are being elevated to the level of traditional finance, creating a framework within which market participants can operate.

• EU: Starting from December 30, 2024, when MiCA is fully implemented, cryptocurrency market manipulation will be prohibited. Market making with one's own funds within exchanges is not subject to licensing. Licenses are attached to points providing services to customers. Major market makers like Keyrock and Flowdesk received licenses in June 2026 for customer-facing services.
• Hong Kong: Reporting a lack of liquidity in exchanges, market making by exchange affiliates was allowed in February 2026. However, they were required to separate market making organizations from exchanges.
• Japan: In July 2026, a revised bill regulating cryptocurrencies under the Financial Instruments and Exchange Act was passed, which included a new prohibition on insider trading.

Although the starting points for major countries differ, they clearly share the same direction. Unfair market manipulation practices will be strictly regulated to the level of existing financial sectors, while sound liquidity providers will be legitimately recognized within the institutional framework.

The task that the domestic market must aim for also lies in seeking this balance point. Unconditional distrust or blind advocacy for market makers cannot be a desirable solution. The required direction for institutional reform to address the structural limitations mentioned earlier can be summarized as follows:

1. Embed the criteria that distinguish normal from deviant in law. It can start from the criteria already used in the industry. Whether market makers bear price risks directly, whether there is no intent to push prices in one direction, and whether external investors could actually buy and sell. Having criteria in advance ensures that normal risk management is not misunderstood as market manipulation.
2. Define the qualifications of market makers entering into contracts. Registration and approval requirements should be placed at the point where contracts are made with exchanges or issuers. This way, firms manipulating trading volumes under the guise of market makers can be filtered out at the contract stage, while broad liquidity provision with proprietary funds remains open as it is now.
3. Make contracts visible. At a minimum, exchanges and supervisory authorities should know which market makers are entering with what volumes and conditions. Investors should also be aware of which market makers are involved.
4. Prevent conflicts of interest. If market making occurs within the same group as exchanges, organizations should be separated and subjected to external scrutiny, similar to Hong Kong.
5. Provide obligations and rewards together. By imposing obligations to maintain quotes, as in the Korea Exchange's market maker system, and providing corresponding rewards, market makers will have reasons to remain in the market during crises.

Therefore, now is the right time to establish these legal and institutional frameworks correctly.

• The Digital Asset Basic Law proposed in June 2025 contains provisions excluding market making entrusted by exchanges from market manipulation.
• In September 2026, the head of the Financial Services Commission stated in a public forum that they would consider the necessity of introducing a market making system.
• The chairman of the Financial Services Commission responded in October 2026 during the National Assembly audit that the contents of the bill were already prepared and in the final stages of consultation. The government aims to enact it within the year.

The remaining question is not whether to allow market makers, but under what criteria to allow them. One point that should not be overlooked here is that the currently disclosed bill is centered around a stock market model of market making entrusted by exchanges. However, many of the issues previously discussed arose not from exchanges but from contracts made with token issuers. If the handling of contracts with token issuers is omitted, the largest blind spot outside the system will remain intact.

The opening of the corporate market is also intertwined with this legislation. The Financial Services Commission announced in February 2025 that it would pilot allowing cryptocurrency trading for approximately 3,500 listed companies and professional investors. However, guidelines have not yet been finalized, and the timing of the announcement is being considered in conjunction with the Digital Asset Basic Law. If the rules for the market where corporate funds will enter are not established to include market makers within those rules, liquidity provision will remain outside the system even after the market opens.

The domestic cryptocurrency market must change its perspective on market makers in order to properly accept institutional funds. Merely cracking down will not keep legitimate market makers in the market, nor will it filter out companies that are only using borrowed names. The Digital Asset Basic Act presents the first opportunity to shift market makers from being subjects of regulation to subjects of management.

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