[Objective] Ensuring the normal operation of the price mechanism and auxiliary mechanisms is an important goal for the future regulation of China's electricity market. Summarizing the regulatory practices of mature international electricity markets in dealing with behaviors that disrupt the price mechanism and auxiliary mechanisms，and comparing the penalty rules for violations in different countries，is of great significance for improving China's electricity market system. [Methods] Grounding its analysis in penal theory，this study conducts a focused investigation into the jurisprudential rationales and operational methodologies employed by EU and U.S. electricity market regulators to sanction manipulative practices. Through a comparative examination of statutory frameworks，regulatory philosophies，and empirical enforcement cases，the research systematically contrasts jurisdictional variations in both legal thresholds for liability and gradations of punitive severity. The concluding synthesis assesses enforcement efficacy to derive comparative insights into regulatory paradigm effectiveness. [Results] While Europe and the U.S. differ significantly in specific legal provisions governing penalties，their electricity regulators apply identical thresholds for initiating enforcement actions against market manipulation. While the U.S. model presents more efficient for quantifiable illegal gains，the French model provides clearer outcomes for uncertain gains. When no illegal gains or harm have yet occurred，the French model exerts stronger deterrence against non-compliant firms. [Conclusions] In light of China's evolving electricity market landscape，this article advances three policy recommendations： excluding the element of intention for violation determination； establishing a fine base with dual deterrence and compensation functions，coupled with fines graded by harm severity； education and penalties are combined to enhance regulatory effectiveness.