Key Takeaways:

• Phantom users can now access regulated derivatives without the wallet needing a broker license.
• Phantom only provides the software, without holding funds or controlling trades.
• The decision sets a precedent for how crypto wallets can connect to regulated markets.

America’s top derivatives regulator has given crypto wallet provider Phantom Technologies permission to connect users to regulated financial trading products inside its app, without registering as a financial broker.

Under US law, firms that solicit or accept orders for derivatives typically must register as introducing brokers (firms that connect users to trading platforms).

On 17 March, 2026, the CFTC’s (Commodity Futures Trading Commission) Market Participant Division (MPD) issued CFTC Staff Letter No. 26-09, a “no-action letter” to Phantom. 

It’s a formal assurance that the MPD would not recommend that the CFTC take action against Phantom for failing to register as an introducing broker, subject to certain pre-specified conditions. It’s among the first no-action letters under Chair Michael Selig since his US Senate confirmation in December 2025.

What Phantom plans to offer

Phantom is a self-custodial crypto wallet, meaning users can store and manage their digital assets themselves rather than relying on a third party. Widely used within the Solana blockchain ecosystem, it also supports Bitcoin and Ethereum.

The company plans to add a trading interface inside its wallet where users can view market data, track their open trades, and place orders for CFTC-regulated derivatives. 

The relief covers event contracts (payouts based on whether a specific real-world event occurs), perpetual contracts (derivatives with no expiry date, common in crypto markets), and other Commission-regulated derivative products. 

Rather than acting as a broker itself, Phantom would act as a passive software layer, routing orders to registered exchanges and brokers, without holding user funds, offering trading advice, or controlling how trades are executed.

Phantom described the approval as “first-of-its-kind.” Its General Counsel, Kevin Jacobs, noted the company engaged the CFTC before building the feature, not afterwards. CEO Brandon Millman said early regulatory dialogue produced better outcomes for users and the industry.

Conditions and limitations

The relief excludes DeFi derivatives (contracts executed through blockchain-based applications) and tokenized prediction markets (platforms where people speculate on real-world outcomes using digital tokens).

The CFTC letter attaches 10 conditions. Among these are requirements for Phantom to:

• Clearly disclose risks and potential conflicts of interest to users
• Ensure users can access trading partners independently of the wallet 
• Follow marketing and communication rules similar to registered brokers
• Maintain detailed compliance records 
• Sign joint-liability agreements with each registered trading partner

The concession stays valid until the CFTC issues formal rules for software providers.

Chair Selig said on X that clear rules for software developers are critical as the US builds its global crypto standing. However, the letter reflects the Market Participants Division’s view only and is not binding on the full Commission.

A precedent for the crypto wallet industry

The ruling is the first time the CFTC has formally addressed how self-custodial wallets fit within existing broker registration rules.

It comes amid debates over the responsibilities of crypto software developers, especially following legal actions targeting privacy-focused tools such as Tornado Cash and Samourai Wallet. Both faced prosecution as alleged financial middlemen despite not directly handling user funds.

The CFTC’s position draws a clear line: passive software that routes orders to registered venues without touching user funds does not automatically require a broker’s license. 

Phantom said it hopes this helps shape lasting guidance for the broader crypto wallet industry.