Cease and Desist Order

A cease and desist is cheap for a regulator to issue and awkward for a recipient to ignore, which is why it usually opens an enforcement sequence rather than closing one. It creates a dated record that the operator was told, which matters later when a court is asked whether conduct was knowing.

Recipients have three broad options: comply and withdraw, negotiate a standstill while a related case is decided, or sue the regulator for an injunction on the ground that the order is unlawful. The third has become standard among prediction market operators, and it carries a hidden cost, since a party that repeatedly agrees to pause proceedings can find a court unwilling to accept that it faces urgent and irreparable harm.

An order is not a judgment. It reflects the regulator's view, and its practical force depends on what the regulator is willing to do next.