Polymarket’s Corporate Structure Is a Mystery—Even to Some of Its Former Employees

There’s no shortage of bonkers details about Polymarket. The government alleges that both a special forces soldier and a longtime Google employee used the prediction market to amass small fortunes by insider trading; CEO Shayne Coplan had his apartment raided by FBI agents, who entered via battering ram; and one of its executives reportedly paid influencers through his personal PayPal account to hype up the company.

But one of the biggest oddities about Polymarket has remained somewhat overlooked: What’s going on with the Panama-based company it set up to comply with a settlement it made with the federal government? And why, as WIRED’s reporting suggests, do some employees of the Panamanian company appear to have worked from New York?

The prediction market with ties to Donald Trump Jr. has an unusually convoluted setup. In 2022, federal regulators said it was operating as an unlicensed derivatives exchange, kicked it out of the country, and barred it from serving US-based customers. Prior to the ban, Adventure One QSS, a corporate entity in Panama, was established, as first reported by Sportico. Adventure One QSS was based offshore so that it could take over operational responsibilities for Polymarket’s flagship platform. A different US-based outfit, Polymarket US, was established in 2025 and is overseen by an entity called QCX LLC. To this day, Polymarket US is the only Polymarket platform that can legally serve US customers.

Despite this structure, WIRED found that Adventure One QSS had staff working out of the US. Former Polymarket employees tell WIRED that some Adventure One QSS staffers have resided in New York, including some who worked from the company’s Manhattan-based headquarters.

These employees did not travel to Panama, report to anyone in Panama, or interact with Panama-based colleagues—because, they say, there were no colleagues there. Instead, they say, the Adventure One QSS staff was spread out across a number of other countries, including the US.

The finer points of this structure are important. The 2022 settlement fined Blockratize—a corporate entity associated with Polymarket—$1.4 million and ordered it to “wind down” offering markets that violated the Commodity Exchange Act. The agreement also required the company to stop violating the CEA and other Commodity Futures Trading Commission regulations. Former CFTC employees see the location of Adventure One’s staff as relevant to the agreement. “We would have really liked to know that the people purportedly in Panama weren’t actually in Panama,” one former CFTC lawyer tells WIRED.

As Sportico reported, Adventure One QSS did initially name Panama residents on its incorporation papers in 2021, including Mario Ernesto García de Paredes, a lawyer referred to as the company’s “resident agent.” A woman named Diana Munoz was listed as the company president for two months before being replaced by Polymarket CEO Shayne Coplan, who is based out of New York. Another man who appears to be based in Panama, Omar Camargo, was listed as secretary. García de Paredes did not respond to WIRED’s requests for comment, and Munoz and Camargo could not be reached for clarification about their roles. Munoz and Camargo appear to have worked together before; they are listed as executives in securities filings connected to a company called Internet Art Foundation.

WIRED’s reporting aligns with previous coverage from NPR, which found that the company’s headquarters in a skyscraper in Panama City was empty and that the company did not have Panama-based staff. In contrast, Adventure One QSS workers in the United States have allegedly been productive and present. One former Polymarket staffer said that the workers in New York who “touched code,” set up event contracts, or otherwise dealt with the offshore platform were all technically working for Adventure One QSS, “but there was no barrier” dividing the corporate arms in practice.

Blockratize and Adventure One QSS are not completely intertwined; New York Stock Exchange parent company Intercontinental Exchange has announced it would invest up to $2 billion into Polymarket, but it’s actually invested only in Blockratize and not Adventure One QSS, for example. And Adventure One QSS staffers in the US did not have permanent desks in the New York office. A former employees described a workplace in which Adventure One team members were expected to perform specific tasks related to the offshore platform, while the Blockratize team, which was far larger, focused on the company’s newer US-licensed platform, marketing, and other concerns. The workers felt unsure of why the workplace was structured in this way.

It’s not unusual for businesses to incorporate in Panama, which has an appealing tax system for multinationals, strong privacy laws, and easy registration requirements. In this instance, though, Polymarket was specifically spurred by its 2022 settlement agreement with the CFTC.

According to Joseph Konizeski, former chief trial attorney in the CFTC’s division of enforcement, Polymarket needed to take a number of steps to properly move its operations to Panama to adhere to the settlement. “That would have required them to hire new staff offshore, move their corporate infrastructure offshore, and stop accepting funds from US customers,” he tells WIRED.

The CFTC declined WIRED’s requests for comment about Adventure One QSS’s setup and whether it fulfills the terms of the agreement. Polymarket declined to comment. The CFTC has not accused Adventure One QSS of any wrongdoing. It is unclear, now, if the agency would currently find issue with employees of the Panamanian offshoot working in New York. Todd Phillips, a financial services regulation expert, describes the setup as odd, “even if it is legal.”

The CFTC has previously filed enforcement actions against companies that purported to operate offshore without actually doing so. According to a 2021 complaint, a foreign exchange company called WorldWideMarkets had incorporated in the British Virgin Islands but was actually working from an office in New Jersey. (Though the case is still pending, a recent motion filed in court indicated a settlement is being finalized.) In 2023, the government brought a landmark action against the cryptocurrency giant Binance and its billionaire founder Changpeng Zhao. The CFTC claimed that Binance violated the Commodity Exchange Act by illegally operating a digital assets derivative exchange, while the Justice Department charged the company with failing to implement an effective anti-money-laundering program or comply with its financial services regulations.

As part of the settlements with the federal government, both the company and Zhao pleaded guilty, but the landscape has changed since then: President Donald Trump pardoned Zhao in 2025, and the agency’s approach to regulating decentralized finance platforms and prediction markets has been notably friendlier. The CFTC dropped an investigation into Polymarket in July 2025 without bringing any charges, which followed a May 2025 staff letter that changed its approach to foreign futures and cross-border swap rules, an apparent break from the agency’s prior stances.

That said, the tides may be shifting. A recent Wall Street Journal investigation into Polymarket’s affiliate marketing practices, which documented how the company built copies of its website for influencer partners to make fake winning bets, has spurred significant backlash, including calls for a federal probe. (Following the WSJ reporting, Polymarket said it would audit its active promotional content.) Around the same time, the WSJ also reported that the CFTC is investigating Polymarket. Sources familiar with the matter confirmed to WIRED that the investigation is ongoing.

According to former CFTC enforcement trial attorney Jack Murphy, the agency has not prioritized cases that are simply about running allegedly unlicensed exchanges under this administration, which