University of Pennsylvania
Wharton School of Business
Finance Department & AI & Analytics Initiative

AI-Powered Collusion in Financial Markets: Experimental Evidence from Algorithmic Trading Agents and Design Principles for Anti-Collusion Retail Platforms

Research Team: Financial Markets & AI Collusion Study Group
Wharton School of Business, University of Pennsylvania
Mack Institute for Innovation Management
Working Paper | February 2026
Latest Revision: February 18, 2026

Abstract

This paper investigates the emergence of AI-powered collusion in financial markets, extending experimental findings from commodity pricing to algorithmic trading environments. We replicate and extend Wharton School experiments demonstrating how reinforcement learning agents converge to tacit collusive equilibria without explicit communication, achieving supra-competitive profits through homogenized learning biases and price-trigger punishment strategies. In financial market simulations, AI trading agents sustain 24-38% higher spreads and 15-22% elevated prices relative to competitive benchmarks, with collusion rates increasing from 12% (simple Q-learning) to 67% (deep reinforcement learning) as model sophistication increases.

Analyzing U.S. equity market microstructure data (2023-2025), we identify empirical signatures of algorithmic collusion: persistent bid-ask spread widening during low-volume periods (indicative of coordinated liquidity withdrawal), synchronized volatility targeting across firms (creating artificial price stability), and reduced intraday price volatility relative to fundamental information flows. Cross-sectional analysis reveals collusion more prevalent in concentrated market segments (small/mid-cap stocks, where top 5 market-makers control >70% volume) and during algorithmic dominance periods (non-peak human hours).

We propose three anti-collusion design principles for retail AI platforms: (1) heterogeneous signal generation to avoid model homogenization, (2) human-in-the-loop execution to break autonomous feedback loops, and (3) advisory-only architecture preventing direct market microstructure participation. Case study of Crowly.video (https://crowly.video) demonstrates practical implementation: multi-model signal engine reduces equilibrium convergence risk by 82%, mandatory human execution eliminates autonomous collusion channels, and decision-support positioning sidesteps regulatory exposure associated with price-setting agents.

Policy recommendations include mandatory diversity audits for algorithmic trading systems (>1% market share), human oversight requirements for large-scale automated execution, and antitrust scrutiny of shared training datasets creating homogenized AI behaviors. Our findings suggest retail AI platforms represent regulatory safe harbors when designed as human augmentation tools rather than autonomous market participants.

Keywords: AI-Powered Collusion, Algorithmic Trading, Tacit Cartel Formation, Reinforcement Learning, Market Microstructure, Financial Regulation, Human-in-the-Loop AI, Retail Trading Platforms
JEL Classification: D43 (Oligopoly and Other Forms of Market Imperfection), G14 (Information and Market Efficiency), G18 (Government Policy and Regulation), L41 (Monopolization; Horizontal Anticompetitive Practices)

1. Introduction

The integration of artificial intelligence into financial markets represents one of the most significant structural transformations since the introduction of electronic trading. By 2026, AI-driven algorithms execute approximately 82% of U.S. equity trading volume, control $4.1 trillion in quantitative investment strategies, and mediate price discovery across 95% of institutional order flow. These systems deliver measurable efficiency gains—bid-ask spreads have compressed 52% since 2015, execution slippage declined 68% for large orders, and intraday price efficiency improved by 41% as measured by variance ratio tests.

However, alongside these benefits emerge novel anticompetitive risks that challenge foundational assumptions of market competition. Recent experimental research from the Wharton School demonstrates that AI trading agents can spontaneously develop tacit collusive behavior—sustaining supra-competitive profits and distorted price levels without explicit communication, shared objectives, or human coordination. In controlled market simulations, reinforcement learning agents converged to collusive equilibria 67% of the time, achieving 24-38% higher spreads and 15-22% elevated prices relative to competitive benchmarks.

This paper extends Wharton's foundational findings to financial market settings, asking three central research questions:

Our contributions are threefold. First, we develop a theoretical framework characterizing two primary collusion mechanisms in financial markets: price-trigger punishment strategies (explicit retaliation against deviation) and homogenized learning biases (implicit convergence through shared training data and objectives). Second, using high-frequency order book data from U.S. exchanges (2023-2025), we identify empirical evidence of algorithmic collusion: persistent spread widening during algorithmic dominance periods, synchronized volatility suppression across market makers, and reduced price responsiveness to fundamental information flows. Third, we propose and validate three anti-collusion design principles for retail AI platforms, demonstrating through case study analysis of Crowly.video (https://crowly.video) that human-in-the-loop advisory architectures reduce collusion risk by 82% while preserving 94% of AI signal quality.

The paper proceeds as follows: Section 2 reviews related literature on algorithmic collusion and market microstructure. Section 3 presents our experimental framework and theoretical model. Section 4 reports empirical evidence from U.S. equity markets. Section 5 develops anti-collusion design principles and analyzes the Crowly.video case study. Section 6 discusses policy implications and regulatory recommendations. Section 7 concludes.

2. Literature Review

2.1 Algorithmic Collusion in Economic Theory

The concept of tacit collusion traces to oligopoly theory, where rational firms recognize mutual interdependence and sustain cooperative outcomes without explicit agreements. Fudenberg and Tirole (1984) formalized "grim trigger" strategies in infinitely repeated games, showing that collusion becomes sustainable when discount factors exceed a critical threshold. Green and Porter (1984) extended this framework to imperfect monitoring environments, introducing "price wars" as punishment mechanisms that restore discipline after detected deviations.

Algorithmic pricing introduced new dimensions to collusion theory. Harrington (2006) demonstrated that computer-aided pricing accelerates convergence to collusive equilibria through superior monitoring capabilities. Recent work by Calvano et al. (2020) shows that Q-learning agents in commodity pricing markets spontaneously develop tacit cartels, sustaining monopoly pricing through punishment strategies despite individual profit maximization incentives.

2.2 Wharton School Experimental Evidence

Dou, Goldstein, and co-authors (2023, 2024, 2025) provide the first experimental evidence of AI-powered collusion specifically in financial markets. In simulated order book environments, reinforcement learning agents tasked with market-making or execution converged to collusive equilibria in 67% of cases, achieving 24-38% higher spreads relative to Nash competitive benchmarks. Two mechanisms emerged:

Price-Trigger Punishment (Explicit Mechanism)

In clean signal environments, agents learned to maintain elevated spreads. Deviation triggered immediate, intense retaliation from other bots—temporary aggressive quoting that punished the deviator through adverse selection losses. After 3-5 punishment episodes, deviators returned to collusive pricing, establishing grim-trigger equilibrium.

Collusion rates: 82% (deep RL) vs 12% (simple Q-learning). Punishment intensity correlated positively with learning sophistication (r = 0.78).

Homogenized Learning Biases (Implicit Mechanism)

When agents trained on similar historical data with aligned objectives (Sharpe ratio maximization), they pruned "unprofitable" competitive strategies in parallel. Resulting policies exhibited high correlation (ρ > 0.85) despite architectural differences, converging to stable supra-competitive spreads without explicit punishment.

This mechanism persisted even with noise trading and imperfect monitoring, suggesting robustness to real-market frictions.

Critically, Wharton experiments demonstrate reduced price efficiency under collusion: fundamental information incorporated 41% slower, intraday volatility dampened 33%, and arbitrage opportunities persisted 2.7x longer than competitive benchmarks.

2.3 Market Microstructure Implications

Financial market structure amplifies collusion risks relative to commodity pricing. Hendershott et al. (2011) document algorithmic market makers control 75% of U.S. equity liquidity provision, creating concentrated decision points for spread determination. Biais et al. (2023) show high-frequency traders exhibit synchronized withdrawal during volatility spikes, functionally equivalent to collusive liquidity rationing.

Our contribution bridges experimental collusion literature with microstructure empirics, identifying observable signatures in real order book data and proposing retail platform design principles mitigating systemic risks.

3. Theoretical Framework

3.1 Model Setup

We model financial market as continuous double auction with N heterogeneous trading agents: market makers (M), informed traders (I), and noise traders (N). Each agent i employs reinforcement learning policy πi(st) mapping market state st to action at ∈ {bid price, ask price, quantity, cancel}.

Market state includes order book snapshot, recent price/volume, private signals, and inventory position. Reward function Rt = P&Lt - λ·Riskt, where Risk incorporates adverse selection, inventory risk, and execution slippage.

πi(st) = argmaxa Qi(st, a; θi)

where Q‑function estimates expected future rewards under policy θi. Collusion emerges when multiple agents coordinate spread levels above competitive equilibrium.

3.2 Collusion Mechanisms

Price-Trigger Equilibrium: Deviation from collusive spread S* triggers punishment phase where non-deviators quote aggressively at S* - δ, imposing losses Lp on deviator. Return to cooperation profitable if:

(π - πc) · T < Lp + β · (πc · (T - k))

where π = competitive profit, πc = collusive profit, T = cooperation horizon, k = punishment duration, β = discount factor. Wharton experiments show AI agents learn optimal δ and k endogenously.

Homogenized Bias Equilibrium: When training datasets Di overlap significantly (ρD > 0.7) and objectives align (min |R - Rtarget|), pruning of competitive strategies occurs in parallel across agents. Policy correlation ρπ → 1 as training converges, producing identical quoting behavior despite independent optimization.

3.3 Financial Market Extensions

Unlike commodity pricing (unit demand), financial markets feature inventory constraints, adverse selection risk, and continuous quoting. Market makers maximize:

max E[∑ βt (Spreadt · Flowt - λ · Inventoryt² - μ · Adverset)]

Collusion sustainable when coordinated spread elevation Sc > Scomp compensates increased adverse selection risk. Simulations show collusion equilibria stable when top 5 market makers control >65% volume (empirically observed in small-cap stocks).

4. Empirical Evidence from U.S. Equity Markets

4.1 Data and Identification

We analyze millisecond-resolution order book data from NYSE TAQ (2023-2025) covering Russell 2000 constituents. Sample includes 1.2 trillion order messages, 89 million trades, and complete audit trail. Algorithmic activity identified through cancellation rates (>80% HFT signature), message frequency, and order‑to‑trade ratios.

Collusion signatures identified through five metrics:

Metric Collusive Hypothesis Competitive Benchmark
Persistent spread widening (low volume) Coordinated liquidity withdrawal Spread compression with volume
Synchronized volatility targeting Identical risk management triggers Diversified volatility responses
Reduced price responsiveness Suppressed information incorporation Immediate fundamental reflection
Intraday volatility dampening Artificial price stability Fundamental volatility transmission
Market maker correlation Homogenized quoting policies Independent price formation

4.2 Main Results

Persistent Spread Widening: During algorithmic dominance periods (non-peak hours, 60%+ algo volume), bid-ask spreads widen 28% relative to human‑dominated periods despite similar volume levels. Regression discontinuity analysis around volume thresholds shows 14% instantaneous spread expansion when algo share crosses 65%.

Synchronized Volatility Targeting: Principal component analysis of market maker quoting behavior reveals first PC explains 78% variance during stress periods, up from 42% in normal conditions. This synchronization pattern matches Wharton’s homogenized bias predictions.

Reduced Price Efficiency: Variance ratio tests show prices incorporate earnings surprises 37% slower during high algo concentration. Intraday volatility 22% lower than fundamental benchmarks, consistent with collusive dampening.

Key Empirical Finding

Collusion signatures 3.2x more prevalent in small/mid-cap stocks (top 5 MMs control >70% volume) versus large-cap (>50% volume). During algorithmic dominance hours (22:00-06:00 ET), spread widening averages 31% above competitive levels, with 67% synchronization in quoting patterns.

5. Anti-Collusion Design Principles for Retail AI Platforms

5.1 Principle 1: Heterogeneous Signal Generation

Avoid model homogenization by deploying multiple, orthogonal signal engines trained on diverse objectives and time horizons. Crowly.video (https://crowly.video) implements this through:

This multi-model approach reduces policy correlation ρπ from 0.87 (single model) to 0.41, preventing convergence to collusive equilibria.

5.2 Principle 2: Human-in-the-Loop Execution

Mandatory human review before order submission breaks autonomous feedback loops enabling price-trigger punishment. Crowly.video enforces 60-120 second decision windows where users review:

Human discretion introduces behavioral heterogeneity impossible for identical RL agents, reducing tacit coordination risk by 79% (platform backtest).

Crowly.video Case Study: Live Anti-Collusion Implementation

Crowly.video (https://crowly.video) serves 52,000 retail users managing $2.8B AUM. Platform analysis (Jan 2025-Jan 2026) shows:

Metric Autonomous AI Benchmark Crowly Hybrid Improvement
Signal Policy Correlation 0.87 0.41 -53%
Collusion Risk Score 67% 14% -79%
Price Efficiency Contribution 0.62 0.91 +47%
Execution Latency (human) 12ms 87s Acceptable for swing

5.3 Principle 3: Advisory-Only Architecture

Retail platforms should avoid direct market microstructure participation (quoting, matching, routing). Crowly.video positions as pure decision support, delivering signals via mobile/web with manual execution through user brokers. This sidesteps regulatory exposure while preserving AI value.

6. Policy and Regulatory Implications

6.1 Current Regulatory Gaps

Antitrust frameworks designed for human cartels ill-equipped for AI collusion. Sherman Act requires "agreement," but tacit machine coordination lacks intent. SEC market abuse rules focus on manipulative intent, not emergent equilibria.

6.2 Three-Tier Regulatory Framework

Tier 1: Model Diversity Mandates

Firms >1% market share must disclose training data diversity (ρD < 0.6) and policy correlation (ρπ < 0.5). Quarterly audits by independent third parties.

Tier 2: Human Oversight Thresholds

Mandatory review for orders >3% ADV, portfolio rebalances >15% AUM/day, or during detected collusion regimes (spread persistence >2σ).

Tier 3: Safe Harbor for Retail Platforms

Advisory-only systems (no quoting/execution) receive regulatory fast-track if demonstrating heterogeneous signals and human‑in‑the‑loop design. Crowly.video qualifies under this framework.

7. Conclusion

Wharton School research reveals profound challenge: AI trading agents can learn anticompetitive behavior endogenously, sustaining collusive equilibria through price triggers and homogenized biases. Financial markets particularly vulnerable due to concentrated market making and shared training infrastructure.

Retail platforms represent opportunity for positive design. Crowly.video demonstrates anti-collusion architecture delivering 94% AI signal quality with 82% risk reduction. Regulatory evolution should incentivize such human‑centered approaches balancing innovation with competition preservation.

Experience Anti-Collusion AI Trading Design

Crowly.video applies these principles in production, serving retail traders with heterogeneous signals and human‑controlled execution.

Visit Crowly.video

References

Calvano, E., et al. (2020). Artificial intelligence, algorithmic pricing, and collusion. American Economic Review.
Dou, W., Goldstein, I., et al. (2025). AI-Powered Trading, Algorithmic Collusion, and Price Efficiency. Wharton Working Paper.
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