CFTC Commodities Regulation for Crypto: Bitcoin, Ethereum, and Digital Assets

By Chanté Eliaszadeh | October 2025

While the SEC dominates crypto regulatory headlines, the Commodity Futures Trading Commission quietly wields massive authority over digital asset markets. The CFTC regulates Bitcoin and Ethereum as commodities, oversees derivatives trading, and increasingly targets DeFi protocols operating without registration. For companies offering crypto derivatives, perpetual contracts, prediction markets, or leveraged trading products, CFTC compliance is non-negotiable.

Recent enforcement actions demonstrate the CFTC's expanding reach. Binance paid $2.85 billion to the CFTC for operating an illegal derivatives exchange and evading U.S. regulations.¹ BitMEX founders paid $130 million combined for offering unregistered crypto derivatives to U.S. customers.² Three DeFi protocols—Opyn, ZeroEx, and Deridex—faced enforcement for failing to register as swap execution facilities.³

The message is clear: if your platform facilitates derivatives trading in digital assets, the CFTC considers you within its jurisdiction. This article explains when the CFTC regulates crypto activities, what registration obligations apply, and how to structure compliant operations.

Bitcoin and Ethereum: Confirmed Commodities

The CFTC's foundational authority stems from classifying Bitcoin and Ethereum as commodities under the Commodity Exchange Act (CEA). This classification has major implications for how these assets can be traded, who can offer related products, and what regulations apply.

Legal Basis for Commodity Classification

The CEA defines "commodity" broadly to include "all services, rights, and interests in which contracts for future delivery are presently or in the future dealt in."⁴ The CFTC has consistently stated that virtual currencies, including Bitcoin and Ethereum, fall within this definition.

In July 2024, a federal court explicitly affirmed Ether as a commodity subject to CFTC oversight in a case involving fraud allegations.⁵ This judicial confirmation strengthened the CFTC's legal authority over Ethereum derivatives and spot market fraud.

Bitcoin's commodity status has been established even longer. CFTC Commissioner Brian Quintenz stated in 2018 that "there is no question that Bitcoin is a commodity," and the agency has regulated Bitcoin futures since 2017.⁶

What Commodity Classification Means

For Spot Trading:

The CFTC does not regulate spot purchases and sales of Bitcoin or Ethereum between parties for immediate delivery. You can buy and sell these assets on spot exchanges without CFTC registration—provided you're not offering leveraged, margined, or financed transactions to retail customers.

For Derivatives:

All derivatives on Bitcoin and Ethereum—futures, options, swaps, and leveraged products—fall under CFTC jurisdiction. Exchanges offering these products must register as Designated Contract Markets (DCMs), and intermediaries must register as Futures Commission Merchants (FCMs).

Anti-Fraud Authority:

Even in spot markets, the CFTC retains anti-fraud and anti-manipulation authority under CEA Section 6(c)(1). The agency can prosecute fraudulent schemes involving crypto commodities, even without registration or derivatives trading.⁷

Beyond Bitcoin and Ethereum

While Bitcoin and Ethereum are explicitly recognized as commodities, the classification of other tokens remains uncertain. The CFTC and SEC continue to dispute jurisdiction over many digital assets.

As a practical matter:

• Decentralized tokens with no active development team: Likely commodities (CFTC)
• Tokens sold in fundraising rounds with profit expectations: Likely securities (SEC)
• Functional utility tokens for decentralized networks: Potentially commodities (CFTC)
• Governance tokens with equity-like rights: Likely securities (SEC)

The pending CLARITY Act would establish clearer jurisdictional boundaries, but until Congress acts, companies must navigate case-by-case analysis.⁸

CFTC-Regulated Activities: When Registration Is Required

Not every crypto business needs CFTC registration. The agency's jurisdiction depends on what products you offer and who you offer them to.

Derivatives Trading Platforms

Designated Contract Markets (DCMs):

If you operate an exchange where users trade commodity derivatives—futures, options, swaps—you must register as a DCM under CEA Section 5. DCM registration requires compliance with 23 core principles covering market surveillance, position limits, financial integrity, and customer protection.⁹

Recent Development: In July 2025, Coinbase Derivatives listed the first perpetual futures contracts on Bitcoin and Ethereum on a U.S.-registered DCM, marking a significant expansion of regulated crypto derivatives products.¹⁰

Swap Execution Facilities (SEFs):

Platforms facilitating swaps trading must register as SEFs. The CFTC's enforcement actions against three DeFi protocols in September 2023 clarified that decentralized platforms are not exempt—if your protocol facilitates swaps, you need SEF registration.¹¹

Critical Insight: The CFTC considers DeFi platforms subject to registration when developers retain control over protocol operations, including the ability to charge fees, upgrade smart contracts, or shut down the protocol.

Intermediaries and Service Providers

Futures Commission Merchants (FCMs):

Any person acting as an intermediary in derivatives transactions—accepting customer funds, executing trades, or clearing positions—must register as an FCM under CEA Section 4d.¹²

Crypto.com became the first major crypto platform to obtain full CFTC derivatives licensing, including FCM registration, enabling the company to serve as an intermediary for customers and institutions.¹³

Swap Dealers (SDs):

Entities that make markets in swaps or induce others to trade swaps must register as swap dealers. As of March 2024, approximately 107 swap dealers are registered with the CFTC.¹⁴

Registration triggers extensive obligations:

• Capital and financial reporting requirements
• Risk management programs
• Business conduct standards
• External business conduct rules for dealing with counterparties
• Clearing and trade execution mandates for certain swaps

Leveraged Retail Commodity Transactions

CEA Section 2(c)(2)(D) gives the CFTC jurisdiction over leveraged, margined, or financed retail commodity transactions—even in spot markets.¹⁵

Example: A platform offering Bitcoin spot trading with 10x leverage to retail customers falls under CFTC jurisdiction, even though Bitcoin spot trading is generally unregulated.

This provision has been central to CFTC enforcement actions. BitMEX illegally offered leveraged retail commodity transactions in Bitcoin and other cryptocurrencies without registration, resulting in $100 million in penalties.¹⁶

Who Is "Retail"?

The CEA defines retail customers as individuals trading for personal use, not commercial purposes. Institutional counterparties and "eligible contract participants" (ECPs) are excluded, allowing platforms to offer leveraged products to sophisticated investors without retail compliance obligations.

CFTC Enforcement Trends: Key Cases and Lessons

The CFTC has pursued aggressive enforcement against crypto platforms operating without registration, establishing clear expectations for compliance.

Binance: $2.85 Billion Settlement (2023-2024)

Violations:

• Operating an unregistered derivatives exchange accessible to U.S. customers
• Facilitating illegal leveraged retail commodity transactions
• Failing to implement adequate KYC/AML controls
• Allowing traders to evade compliance measures through VPNs

Penalties:

• $1.35 billion civil monetary penalty
• $1.35 billion disgorgement
• $150 million penalty against CEO Changpeng Zhao
• Compliance monitoring and extensive remedial measures

Lesson: Geofencing and VPN detection are not optional. Platforms must implement robust controls to prevent U.S. customers from accessing unregistered derivatives products.¹⁷

BitMEX: $130 Million Combined Penalties (2020-2022)

Violations:

• Operating an unregistered FCM and DCM
• Offering illegal leveraged retail commodity transactions
• Failing to implement required AML programs
• Willfully evading Bank Secrecy Act compliance

Penalties:

• $100 million corporate penalty
• $30 million in penalties against three co-founders
• $100 million parallel FinCEN penalty for BSA violations

Lesson: "Code is law" is not a defense. Operating through smart contracts or offshore entities does not exempt platforms from U.S. regulatory obligations when serving U.S. customers.¹⁸

DeFi Enforcement: Opyn, ZeroEx, Deridex (2023)

Violations:

• Failing to register as DCMs or SEFs despite facilitating derivatives trading
• Operating without FCM registration while acting as intermediaries

CFTC Position:

DeFi protocols are subject to registration requirements when developers retain control through:

• Fee-setting authority
• Smart contract upgrade capabilities
• Protocol shutdown or pause functions
• Treasury management or governance control

Lesson: "Decentralization" is not a magic exemption. If your team can materially alter protocol operations, the CFTC considers you a regulated entity.¹⁹

DeFi Protocols: Navigating CFTC Jurisdiction

The CFTC's enforcement actions against DeFi protocols sent shockwaves through the industry. Many developers believed decentralized architecture immunized them from regulation. The CFTC made clear: not even close.

When Does the CFTC Regulate DeFi?

The CFTC applies a control test to determine whether protocol developers are responsible for compliance:

Indicators of Control:

• Admin keys allowing protocol upgrades or pauses
• Fee capture mechanisms benefiting the development team
• Governance token distributions concentrating control
• Continued marketing, promotion, or user onboarding by developers
• Treasury management or resource allocation decisions

If developers exercise material control over protocol operations, the CFTC treats the protocol as a regulated entity requiring registration.

Compliance Options for DeFi Protocols

Option 1: Register with the CFTC

Current CFTC registration frameworks were designed for centralized entities with corporate structures, boards of directors, and compliance officers. Most DeFi protocols cannot satisfy these requirements.

The CFTC has acknowledged that registration may not be feasible for truly decentralized protocols and has called for updated regulatory frameworks. Until those exist, registration remains practically impossible for most DeFi projects.

Option 2: Exclude U.S. Users

Many DeFi protocols implement geofencing to block U.S. IP addresses, coupled with terms of service prohibiting U.S. user access.

Effectiveness Limitations:

• VPNs allow users to bypass geoblocking
• Smart contracts on public blockchains are permissionless by design
• The CFTC may view ineffective geofencing as willful evasion

Option 3: Achieve Genuine Decentralization

If the development team genuinely relinquishes all control—no upgrade authority, no fee capture, no governance influence—the protocol may fall outside CFTC jurisdiction.

Requirements for Credible Decentralization:

• Immutable smart contracts (no upgrade mechanisms)
• Governance distributed across a large, diverse token holder base
• No single entity controlling validators, oracles, or critical infrastructure
• No ongoing marketing or promotional activities by developers
• Open-source code with no proprietary components

Reality Check: Few protocols meet this standard. Most development teams retain some level of ongoing control, whether for security patches, feature improvements, or community engagement.

Prediction Markets and Event Contracts

The CFTC regulates prediction markets as event contracts—derivatives based on the occurrence or non-occurrence of specific events. This includes political elections, sports outcomes, and other real-world occurrences.

Regulatory Framework

Event contracts must be listed on CFTC-registered exchanges (DCMs) and comply with CFTC Regulation 40.11, which prohibits contracts involving:

• Terrorism, assassination, or war
• Illegal activity or gaming (with limited exceptions)
• Contracts contrary to the public interest²⁰

Recent Developments

September 2025 SEC-CFTC Joint Statement:

The agencies announced coordination on event contracts, including those based on securities. This collaboration aims to provide clarity for platforms seeking to offer prediction markets responsibly.²¹

CFTC Prediction Markets Roundtable:

The CFTC held a public roundtable to develop regulatory approaches for prediction markets, including sports-related event contracts. The agency is considering updated frameworks to accommodate innovation while protecting market integrity.²²

Approved Platforms:

• KalshiEX: CFTC-registered DCM offering event contracts on non-political topics
• ForecastEx: Recently approved DCM focused on prediction markets
• Crypto.com Derivatives: Offers event contracts alongside crypto derivatives

Compliance Considerations

If your platform offers prediction markets:

• Register as a DCM before launching
• Submit all event contracts for CFTC review under the Part 40 certification process
• Implement position limits and accountability rules
• Maintain market surveillance systems to detect manipulation
• Comply with customer onboarding, KYC, and AML requirements

SEC vs. CFTC: Jurisdictional Boundaries

The SEC and CFTC share overlapping authority over digital assets, creating compliance complexity. Understanding which agency regulates your activities is critical.

Division of Authority

CFTC Regulates:

• Digital asset commodities (Bitcoin, Ethereum, and likely other decentralized tokens)
• Derivatives on any underlying asset, including securities
• Leveraged retail commodity transactions
• Fraud and manipulation in commodity markets

SEC Regulates:

• Digital asset securities (tokens meeting the Howey test)
• Offerings and sales of investment contracts
• Securities exchanges and broker-dealers
• Fraud and manipulation in securities markets

Overlapping Authority:

Both agencies can pursue fraud cases involving digital assets. The SEC focuses on investment contract fraud (promises of returns from others' efforts), while the CFTC addresses commodities fraud (price manipulation, wash trading, misrepresentation).

The CLARITY Act and Future Reforms

Congress is considering the CLARITY Act, which would establish clear jurisdictional boundaries:

• CFTC: Spot and derivatives markets for digital commodities
• SEC: Digital asset securities meeting specific criteria

Until federal legislation passes, companies must navigate dual regulatory uncertainty. Our earlier article, The CLARITY Act Explained: CFTC vs. SEC Jurisdiction Finally Defined, provides detailed analysis of the proposed framework.²³

Coordinated Regulation (2025)

The SEC and CFTC have launched joint initiatives to harmonize digital asset oversight:

Project Crypto Sprint (September 2025):

The agencies issued a joint staff statement clarifying that registered exchanges can facilitate trading of certain spot crypto asset products without separate authorization, marking a significant policy shift toward regulatory coordination.²⁴

Harmonization Initiative:

The SEC and CFTC announced a joint roundtable on regulatory harmonization, focusing on:

• Product and venue definitions
• Reporting and data standards
• Capital and margin frameworks
• Innovation exemptions and safe harbors²⁵

These efforts signal a shift toward cooperation, reducing duplicative enforcement and providing clearer compliance pathways.

CFTC Compliance Framework: Practical Checklist

Step 1: Determine Whether CFTC Jurisdiction Applies

Ask These Questions:

• Do you offer derivatives (futures, options, swaps) on digital assets?
• Do you provide leveraged, margined, or financed transactions to retail customers?
• Does your platform facilitate derivatives trading between users?
• Do you act as an intermediary, accepting customer funds or executing derivatives trades?

If YES to any: CFTC registration likely required.

Step 2: Identify Required Registrations

Platform Operators:

• Derivatives exchange → Register as DCM
• Swaps trading platform → Register as SEF
• Prediction market → Register as DCM

Intermediaries:

• Customer-facing intermediary → Register as FCM
• Market maker in swaps → Register as Swap Dealer

Service Providers:

• Clearing organization → Register as DCO (Derivatives Clearing Organization)

Step 3: Implement Core Compliance Programs

All Registered Entities Must Have:

• KYC/AML Program: Customer identification, ongoing monitoring, suspicious activity reporting
• Market Surveillance: Real-time monitoring for manipulation, wash trading, layering
• Cybersecurity Controls: Incident response, data protection, business continuity
• Risk Management: Capital requirements, position limits, stress testing
• Recordkeeping: Transaction records, communications, compliance documentation

Derivatives Exchanges (DCMs) Must Comply with 23 Core Principles:

1. Compliance with CFTC regulations
2. Prevention of market manipulation and abusive trading
3. Fair and equitable trading
4. Position limits and accountability
5. Emergency authority to intervene in markets
6. Financial integrity of transactions
7. Designation of contract terms
8. Settlement procedures 9-23. Additional operational and governance requirements²⁶

Step 4: Obtain Legal Counsel and Regulatory Guidance

CFTC Registration Is Complex:

• Application processes take 6-18 months
• Require detailed business plans, financial documentation, and compliance manuals
• Involve CFTC staff interviews and on-site inspections
• Necessitate ongoing reporting and examination readiness

Engage Experienced CFTC Counsel:

Firms with CFTC registration experience can guide you through:

• Registration application preparation
• Compliance program design
• Regulatory interpretation and advisory opinions
• Enforcement defense and settlement negotiations

Step 5: Consider Strategic Alternatives

If Full Registration Is Infeasible:

• Partner with Registered Entities: Use registered FCMs or DCMs as intermediaries
• Limit Product Offerings: Avoid derivatives and leveraged retail products
• Serve Only Eligible Contract Participants: Institutional-only business models avoid retail compliance
• Exclude U.S. Customers: Operate offshore with robust geofencing (risks remain)

What to Expect in 2025-2026

The CFTC's regulatory approach to crypto is evolving rapidly. Here's what companies should anticipate:

Expanded Spot Market Authority

The CFTC has repeatedly called for expanded statutory authority over spot digital commodity markets. Currently, the agency can only prosecute fraud—it cannot regulate spot exchanges, custody providers, or market participants absent derivatives activity.

Legislation granting the CFTC comprehensive spot market authority would transform the regulatory landscape, requiring registration and oversight for Bitcoin and Ethereum spot exchanges, similar to existing securities exchange regulation.

Stablecoin Regulation

Acting CFTC Chairman Caroline Pham announced a Tokenized Collateral and Stablecoins Initiative in 2025, exploring the use of stablecoins in derivatives markets.²⁷

Potential Outcomes:

• CFTC oversight of stablecoins used as collateral in derivatives trading
• Registration requirements for stablecoin issuers serving derivatives markets
• Capital, reserve, and disclosure requirements for CFTC-regulated stablecoins

DeFi Enforcement Continues

The CFTC has made clear that DeFi protocols are not exempt from regulation. Expect continued enforcement actions against protocols facilitating unregistered derivatives trading.

Risk Factors:

• Protocols offering perpetual swaps, leveraged tokens, or synthetic assets
• Platforms facilitating margin trading or lending in crypto derivatives
• Prediction markets operating without DCM registration

Perpetual Futures and Innovative Products

Coinbase Derivatives' launch of perpetual futures marked a milestone in bringing offshore products onshore. The CFTC is likely to approve additional innovative derivatives products, including:

• Options on spot Bitcoin and Ethereum ETFs (cleared November 2024)²⁸
• Tokenized commodity derivatives
• Cross-margined crypto and traditional derivatives portfolios

Companies with novel product ideas should engage the CFTC's LabCFTC initiative, which provides regulatory guidance for emerging technologies.

Key Takeaways

1. Bitcoin and Ethereum are commodities. All derivatives on these assets fall under CFTC jurisdiction, requiring platform registration and compliance.

2. Leveraged retail trading triggers CFTC oversight. Offering margin, leverage, or financing to retail customers requires FCM and DCM registration—even for spot products.

3. DeFi is not exempt. Developers who control protocol operations are responsible for CFTC compliance, regardless of decentralized architecture.

4. Enforcement is escalating. Billion-dollar penalties against Binance and BitMEX demonstrate the CFTC's commitment to enforcement. Operating without registration is not a viable strategy.

5. Registration is complex but achievable. Companies like Coinbase and Crypto.com have successfully navigated CFTC registration, demonstrating compliance is possible for well-resourced firms.

6. Regulatory clarity is coming. The CLARITY Act, SEC-CFTC coordination initiatives, and expanded CFTC authority will reshape the regulatory landscape in the next 12-24 months.

7. Early compliance creates competitive advantage. Registered entities benefit from regulatory certainty, institutional customer access, and reduced enforcement risk.

Navigate CFTC Compliance with Expert Guidance

CFTC regulation is among the most complex areas of crypto law. Registration processes, compliance obligations, and enforcement risks require specialized expertise.

Astraea Counsel advises crypto derivatives platforms, DeFi protocols, and digital asset companies on CFTC compliance strategy. We help clients assess registration obligations, design compliance programs, and navigate enforcement inquiries.

Explore our Regulatory Compliance services or contact us to discuss your CFTC compliance needs.

Related Resources

• The CLARITY Act Explained: CFTC vs. SEC Jurisdiction Finally Defined - Detailed analysis of jurisdictional framework
• The SEC's Crypto Pivot: What It Means for Your Startup - Understanding SEC coordination with CFTC
• Digital Assets & Blockchain Legal Services - Comprehensive crypto legal counsel
• Regulatory Compliance Services - Navigate CFTC and SEC compliance
• Contact Us - Discuss your compliance strategy

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Footnotes

1. CFTC, CFTC Charges Binance and Its Founder, Changpeng Zhao, with Willful Evasion of Federal Law and Operating an Illegal Digital Asset Derivatives Exchange, Release No. 8680-23 (Mar. 27, 2023), available at https://www.cftc.gov/PressRoom/PressReleases/8680-23. ↩

2. CFTC, Federal Court Orders BitMEX to Pay $100 Million for Illegally Operating a Cryptocurrency Trading Platform and Anti-Money Laundering Violations, Release No. 8412-21 (Aug. 10, 2021), available at https://www.cftc.gov/PressRoom/PressReleases/8412-21; CFTC, Federal Court Orders BitMEX's Three Co-Founders to Pay a Total of $30 Million, Release No. 8522-22 (May 19, 2022), available at https://www.cftc.gov/PressRoom/PressReleases/8522-22. ↩

3. CFTC, CFTC Issues Orders Against Operators of Three DeFi Protocols for Offering Illegal Digital Asset Derivatives Trading, Release No. 8774-23 (Sept. 7, 2023), available at https://www.cftc.gov/PressRoom/PressReleases/8774-23. ↩

4. Commodity Exchange Act, 7 U.S.C. § 1a(9) (2018). ↩

5. Ether's Legal Status Clarified? CFTC Scores Win as Court Backs Agency's Commodity Classification, Lexology (July 2024), available at https://www.lexology.com/library/detail.aspx?g=be30e4fc-363c-4191-9884-c268c2986ab1. ↩

6. CFTC, Bitcoin Basics: What is Bitcoin?, CFTC Backgrounder (Feb. 2018), available at https://www.cftc.gov/sites/default/files/2019-12/oceo_bitcoinbasics0218.pdf. ↩

7. 7 U.S.C. § 9(1) (CEA Section 6(c)(1) anti-fraud authority). ↩

8. See The CLARITY Act Explained: CFTC vs. SEC Jurisdiction Finally Defined, Astraea Counsel (June 2025), available at https://astraea.law/insights/clarity-act-cftc-sec-jurisdiction-explained. ↩

9. 7 U.S.C. § 7 (CEA Section 5); 17 C.F.R. Part 38 (CFTC Regulations for Designated Contract Markets). ↩

10. Pillsbury, CFTC Permits Listing of Perpetual Futures on BTC and ETH: A Regulatory Milestone for U.S. Crypto Derivatives (July 2025), available at https://www.pillsburylaw.com/en/news-and-insights/cftc-perpetual-futures-btc-eth-crypto-derivatives.html. ↩

11. CFTC Release No. 8774-23 (Sept. 7, 2023). ↩

12. 7 U.S.C. § 6d(a)(1) (CEA Section 4d); 17 C.F.R. Part 1 (CFTC Regulations for FCMs). ↩

13. Crypto.com, Crypto.com Becomes First Major Crypto Platform to Obtain a Full Stack of CFTC Derivatives Licenses (2024), available at https://crypto.com/en/company-news/cryptocom-becomes-first-major-crypto-platform-to-obtain-a-full-stack-of-cftc-derivatives-licenses. ↩

14. CFTC, Registration - Swap Dealers and Major Swap Participants, available at https://www.cftc.gov/LawRegulation/DoddFrankAct/Rulemakings/DF_1_Registration/index.htm. ↩

15. 7 U.S.C. § 2(c)(2)(D) (CEA Section 2(c)(2)(D)). ↩

16. CFTC Release No. 8412-21 (Aug. 10, 2021). ↩

17. CFTC Release No. 8680-23 (Mar. 27, 2023). ↩

18. CFTC Release No. 8412-21 (Aug. 10, 2021); CFTC Release No. 8522-22 (May 19, 2022). ↩

19. CFTC Release No. 8774-23 (Sept. 7, 2023); see also Goodwin, The CFTC's DeFi Trifecta: Lessons and Implications for DeFi Participants (Sept. 2023), available at https://www.goodwinlaw.com/en/insights/publications/2023/09/alerts-finance-ftec-cftc-decentralized-finance-defi-lessons-implications. ↩

20. 17 C.F.R. § 40.11 (CFTC Regulation 40.11). ↩

21. SEC and CFTC, Joint Statement from the Chairman of the SEC and Acting Chairman of the CFTC (Sept. 5, 2025), available at https://www.sec.gov/newsroom/speeches-statements/joint-statement-atkins-pham-090525. ↩

22. CFTC, CFTC Announces Prediction Markets Roundtable, Release No. 9046-25 (2025), available at https://www.cftc.gov/PressRoom/PressReleases/9046-25. ↩

23. The CLARITY Act Explained: CFTC vs. SEC Jurisdiction Finally Defined, Astraea Counsel (June 2025). ↩

24. SEC and CFTC, SEC and CFTC Staff Issue Joint Statement on Trading of Certain Spot Crypto Asset Products (Sept. 2, 2025), available at https://www.sec.gov/newsroom/press-releases/2025-110-sec-cftc-staff-issue-joint-statement-trading-certain-spot-crypto-asset-products. ↩

25. SEC and CFTC, SEC-CFTC Joint Staff Statement (Project Crypto-Crypto Sprint) (Sept. 2, 2025), available at https://www.sec.gov/newsroom/speeches-statements/sec-cftc-project-crypto-090225. ↩

26. 17 C.F.R. Part 38 (CFTC Regulations for Designated Contract Markets). ↩

27. CFTC, Acting Chairman Pham Launches Tokenized Collateral and Stablecoins Initiative, Release No. 9130-25 (2025), available at https://www.cftc.gov/PressRoom/PressReleases/9130-25. ↩

28. DeSilva Law Offices, CFTC Clears the Way for Bitcoin Spot ETF Options: A Game-Changer for Institutional Investors (Nov. 2024), available at https://www.desilvalawoffices.com/articles/blog/2024/november/the-cftcs-new-advisory-on-clearing-options-for-s/. ↩