A federal insider-trading complaint, reconciled against the venue record
The CFTC's insider-trading complaint against Gannon Van Dyke describes the account's trading in approximations and floors. Press reports of the parallel criminal case carry sharper figures, attributed to prosecutors and to court filings. We pulled the named wallet's complete Polymarket trading record and reconciled all of it.
MSR FINDING RECORD — the citable finding, scope, and limits
- Case ID
- MSR-NOTE-03
- Domain
- Trading Conduct
- Status
- Published, Aug 18, 2026
- Finding
- The wallet
0x31a56e9e690c621ed21de08cb559e9524cdb8ed9(“Burdensome-Mix”), named in the CFTC's insider-trading complaint against Gannon Van Dyke, made 15 fills across 4 Venezuela-themed Polymarket markets between Dec 27, 2025 and Jan 3, 2026. Every figure in the complaint reconciles against the venue's own trading record: its approximations reproduce within rounding tolerance, its floors (“more than $404,000,” “more than 436,000 shares”) are exceeded by the exact amounts, and press-reported prosecution figures ($33,934 staked, $409,881 profit) reproduce to the dollar. - Scope
- One wallet, four markets, one federal complaint — CFTC v. Van Dyke, No. 1:26-cv-03369 (S.D.N.Y.), filed Apr 23, 2026 — and press reporting on the parallel criminal case. Nothing here concerns any other wallet, market, or defendant.
- Evidence
- Polymarket public data API: the wallet's complete trade, activity and position history, enumerated market by market to work around the API's measured 10,000-fill offset cap on the user-scoped endpoint. The CFTC complaint itself and CFTC Release 9217-26. Press reporting on the criminal case (crypto.news, Jul 21 and Aug 10, 2026).
- What this establishes
- The complaint's figures are not inflated relative to the venue record — if anything, its approximations understate the wallet's gains, since every stated floor is exceeded by the reconstructed amount. The press-reported prosecution figures match our independent reconstruction to the exact dollar.
- What it does not establish
- That this wallet belongs to Van Dyke — that identification rests on the address matching the complaint's partial redaction and its trading description, sourced to Lookonchain's January 2026 report; Lookonchain's original post could not be independently loaded (a mirror was used instead), so we make no independent identification of our own. Off-venue flows — deposits, withdrawals, the fiat-conversion path — are outside venue trade data; a $394 gap in the complaint's reported fiat-conversion total is disclosed, not explained. Nothing about the merits of the pending civil or criminal case.
- Data snapshot (UTC)
- As of Aug 15, 2026 — trade, activity, and position history as returned by Polymarket's public data API on that date. Venue records, not chain-verified.
- Method
- Same reconstruction as the Scorecard and Workpaper: every market the wallet ever touched enumerated from its full activity log, each re-fetched independently to exhaustion, and the merged set proven consistent with the user-scoped pull row for row. Cost basis and profit computed from every buy, sell and redemption.
- Cite as
- MSR Decode, “A federal insider-trading complaint, reconciled against the venue record,”
msrdecode.com/notes/vandyke-maduro, Aug 18, 2026. - Corrections
- Any factual correction to this note is logged, dated, at Record.
- Contact
- Chris Park · ceo@msrdecode.com · For journalists
What happened
On Apr 23, 2026, the CFTC filed a civil complaint against Gannon Van Dyke, alleging that a Polymarket wallet placed a series of well-timed bets on Venezuela-related markets in the days before Nicolás Maduro's fall from power. CFTC Release 9217-26 also notes that a parallel criminal indictment against Van Dyke was unsealed the same day. The complaint identifies the wallet by a partially redacted address — the first six and last four characters, with the middle asterisked out — and by the handle “Burdensome-Mix,” which it notes was used “among other handles.” The civil case was stayed on Aug 10, 2026.
What is being claimed
Two sets of figures, from two sources. The CFTC complaint states its own numbers as approximations and floors: a cost of “approximately $32,538” for “more than 436,000” shares in the largest position, redeemed for “more than $404,000 of profits”; three smaller Venezuela contracts earning “more than $5,000” combined. Separately, press reporting on the parallel criminal case — citing prosecutors and court filings the reporters did not themselves publish — states sharper figures: $33,934 staked across 13 trades between Dec 27 and Jan 2, and $409,881 in profit. The two are not obviously the same claim: the complaint's headline figure is scoped to a single market and stated as a floor; the press figure appears to cover all four markets and is stated as a point estimate.
What we independently tested
We pulled the wallet's complete Polymarket record on 2026-08-15: 15 fills — 13 buys, 2 sells — across 4 markets, all Venezuela-themed, first fill Dec 27, 2025 at 00:05 ET and last fill Jan 3, 2026 at 19:03 ET. No fills in any other market appear anywhere in the account's Polymarket record, consistent with the complaint's own statement (¶57) that the wallet was not used “to engage in any other trading on Polymarket.com.”
| Market | Buys | Cost | Shares | Exit | Profit |
|---|---|---|---|---|---|
| Maduro out by January 31, 2026? | 7 | $32,538 | ≈436,760 | Redeemed ≈$436,760 | $404,221 |
| Trump invokes War Powers against Venezuela by January 31? | 3 | $250 | ≈5,372 | Sold ≈$2,715 | $2,465 |
| Will the U.S. invade Venezuela by January 31, 2026? | 1 | $1,000 | ≈17,858 | Sold ≈$3,143 | $2,143 |
| US forces in Venezuela by January 31, 2026? | 2 | $146 | ≈1,198 | Redeemed ≈$1,198 | $1,052 |
| Total | 13 | $33,934 | $409,881 |
Every figure the complaint states as an approximation reproduces within rounding tolerance — the largest position's cost is a whole-dollar match ($32,538), and its four accumulation tranches (¶50) each land within a few dozen shares of the complaint's stated size. Every figure the complaint states as a floor is exceeded: 436,760 shares bought against a stated “more than 436,000”; $404,221 in profit against a stated “more than $404,000”; $5,660 across the three side markets against a stated “more than $5,000.”
The complaint states that USDC from these markets was converted to fiat “totaling $444,209” (¶59). The venue-side proceeds in our record — two redemptions and two sales — sum to $443,815. The $394 residual is not reconcilable from venue trade data, which does not carry deposits, withdrawals or balances; we attach no explanation to it.
Against the press-reported prosecution figures, the complete record reproduces exactly: 13 buy fills between Dec 27 and Jan 2, total cost $33,934, total profit across all four markets $409,881. Lookonchain's January 2026 report put the wallet's profit at $409,900 — $19 above our computed total; we cannot determine how that figure was produced and make no claim beyond the size of the difference.
What the evidence establishes
The complaint's account-level figures hold in substance and are not overstated relative to the venue record — every approximation reproduces within rounding tolerance and every floor is exceeded by the reconstructed amount, never fallen short of. The press-reported prosecution figures, which we could not check against the underlying charging documents directly, reproduce to the exact dollar from the same complete pull. What the complete record adds beyond either source is precision and negative space: the exact per-market dollars behind each floor and approximation, the exact fill times and prices, and the verified absence of any other trading activity in this wallet's Polymarket history as of the pull date.
What remains unproven
Attribution. The government alleges the wallet is Van Dyke's; our checks show only that the address matches the complaint's partial redaction and its trade-by-trade description. We make no independent identification, and the underlying public report tying the address to Van Dyke (Lookonchain, January 2026) could not itself be independently loaded — we relied on a third-party mirror of it, not the original.
Off-venue flows. Bank transfers, deposits, withdrawals and the fiat-conversion path are outside venue trade data; aside from noting the $394 residual above, we make no claim about them. One further tension is unresolved for the same reason: the complaint describes the account's funding transfers as occurring “between December 30, 2025 and January 2, 2026” (¶49), while the wallet's first fill — a $96 buy in a side market — falls on Dec 27, predating that window. How that fill was funded is not visible in venue trade data.
The legal case itself. This note measures what the venue record evidences. We take no position on any element of the civil or criminal proceedings, which remain pending. Other wallets named in January reporting alongside this one are not addressed here; the CFTC and DOJ materials we reviewed charge only Van Dyke, and we make no claim connecting any other wallet to any person. Fees, gas and funding costs are also excluded — profit figures above are gross trading arithmetic only.
If you are a reporter covering this case, or checking any other specific prediction-market claim, send it my way — For journalists. No charge.
Sources
- CFTC v. Van Dyke, No. 1:26-cv-03369 (S.D.N.Y.), Complaint, filed Apr 23, 2026 — cftc.gov.
- CFTC Release 9217-26, announcing the complaint and noting the same-day unsealing of a parallel criminal indictment against Van Dyke.
- crypto.news, “Polymarket refers nearly 100 wallets amid $200M insider-trade concerns,” Jul 21, 2026, and “CFTC-Polymarket case paused over soldier's $400K bets,” Aug 10, 2026 — reporting the prosecution figures and the civil-case stay.
- Lookonchain, Jan 2026 report on the wallet's address and profit figure, mirrored at cryptoninjas.net (the original post could not be independently loaded).
- Polymarket public data API — the wallet's complete trade, activity and position history, retrieved Aug 15, 2026.