REGULATION | The Phantom Crypto Wallet Receives First-of-its-Kind No Action Relief from CFTC

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The U.S. Commodity Futures Trading Commission (CFTC) has issued a ‘no-action’ letter to crypto wallet provider, Phantom, saying it will not pursue enforcement action if the firm facilitates access to regulated derivatives markets without registering as a broker according to official statements.

The position comes after Phantom’s planned interface enabling users to access derivatives markets through its wallet software and informating the regulator of its expanded capabilities. The interface would enable users:

  • view derivaties market data
  • track positions
  • submit orders to registered exchanges or brokers

The relief allows Phantom, a self-custodial wallet, to operate as a software front-end interface connecting users to CFTC-registered entities such as futures commission merchants and exchanges, while avoiding introducing broker registration requirements.

The regulator said the position applies under specific conditions, including that Phantom does not hold customer funds or intermediate trades, with orders routed directly to registered market participants.

The decision marks a rare instance of regulatory clarity for non-custodial crypto wallet providers and could serve as a framework for how similar platforms integrate with traditional financial markets.

Phantom said the move would enable it to offer users access to derivatives and event contracts through licensed partners, while maintaining its non-custodial model that avoids it taking on regulatory obligations of an introducing broker.

“This is first-of-its-kind relief for this specific model. The CFTC letter acknowledges their focus on developing rulemaking or guidance that may supersede the letter in the future, and we hope that our engagement can help shape a long-lasting framework that benefits the industry as a whole.

We also want to acknowledge the CFTC for engaging with us seriously and in good faith. Working through genuinely novel legal questions takes effort on both sides, and this outcome reflects a willingness to do that work rather than default to no.”

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