Polymarket’s Panama Entity Operates from New York, Raising Compliance Questions
The prediction market’s Panamanian arm, Adventure One QSS, appears to lack a physical presence in Panama, coinciding with an ongoing Commodity Futures Trading Commission probe into its marketing practices.
A WIRED investigation has uncovered that Polymarket’s Panamanian corporate entity, Adventure One QSS, operates primarily from New York rather than Panama, casting doubt on its adherence to a 2022 US regulatory settlement. Former employees report that staff assigned to the offshore platform reside in the United States, with no colleagues based in Panama, a structure experts describe as unusual given the settlement’s requirement to move operations offshore.
Adventure One QSS was incorporated in 2021 to assume operational responsibilities for Polymarket’s flagship platform following the 2022 settlement with the Commodity Futures Trading Commission (CFTC). The agreement required the prediction market to wind down unlicensed US operations and cease violating the Commodity Exchange Act. While a separate US-based entity, Polymarket US, overseen by QCX LLC, was established in 2025 to legally serve American customers, the Panamanian arm remains central to the company’s offshore structure.
Despite incorporation papers listing Panama residents as initial officers, former employees state that Adventure One QSS staff worked from Polymarket’s Manhattan headquarters without travelling to Panama or interacting with local colleagues. WIRED found the company’s headquarters in Panama City to be empty. One former staffer noted that employees touching code or setting up event contracts for the offshore platform were technically working for Adventure One QSS, yet there was no practical barrier dividing the corporate arms.
The setup has drawn scrutiny from former regulators who argue that proper compliance would have required hiring new staff offshore and moving corporate infrastructure to Panama. Joseph Konizeski, a former chief trial attorney in the CFTC’s division of enforcement, stated that the agency would have expected Polymarket to hire new staff offshore and stop accepting funds from US customers to adhere to the settlement. The CFTC has not accused Adventure One QSS of wrongdoing, but declined to comment on whether the current structure fulfills the agreement’s terms.
This disclosure coincides with an ongoing CFTC investigation into Polymarket’s affiliate marketing practices, prompted by a Wall Street Journal report detailing how the company built copies of its website for influencer partners to make fake winning bets. Polymarket has stated it will audit its active promotional content following the report. While the CFTC dropped a previous investigation into Polymarket in July 2025, sources confirm to WIRED that the new probe into deceptive marketing practices is active, aligning with the agency’s current priority on protecting retail traders.
