CFTC Declines to Enforce Registration Requirements for Phantom Technologies

The U.S. Commodity Futures Trading Commission (CFTC) Market Participants Division has declared it will not pursue enforcement action against Phantom Technologies Inc., the provider of self-custody cryptocurrency wallet software, for failing to register as an introducing broker (IB) or associated person (AP). In a non-enforcement letter published on March 17, 2026, the CFTC specified that its stance applies where Phantom's software serves only as a front-end interface connecting users to registered futures brokers and designated trading venues, without holding or controlling user assets, providing buy/sell signals, or exercising discretion over order routing and execution. The CFTC also required Phantom to disclose trading risks and potential conflicts of interest to users, while mandating proper management of marketing and communication procedures related to derivatives. Users must be able to access registered counterparties directly without using Phantom's platform.