I haven't read the CFTC report in detail but to me, they will walk away free with the cash as long as they didn't hammered the may outright just before and during the 2 min settlement window. That's the old Optiver case where they were buying loads of TAS contracts during the day and pushing the settlement downside automatically, creating momentum and averaging a sell higher than the settlement they created. If they continuously sold may contracts during the day and hoped the settlement would be lower or even negative, there is no manipulation possible, just trading skill and good forecating of the risk of oil turning negative. I watched it live and I remember there was still liquidity available until it turned negative. So if most of their sells were on the positive side, I can't see a manipulation case being brought...