CFTC Unit Says No Enforcement Action Against Phantom Derivatives Software for IB Registration

The U.S. Commodity Futures Trading Commission (CFTC) Market Participants Division announced on March 17, 2026, that it would not recommend enforcement action against Phantom Technologies for providing derivative trading software under specific conditions, even if introduction brokers (IBs) remain unregistered.

In its non-enforcement letter, the CFTC specified that Phantom's provision and promotion of software connecting users to registered futures intermediaries, introduction brokers, and designated contract markets must comply with certain conditions. Users will directly transmit orders through the software to trading counterparties. The division emphasized that Phantom must not hold user assets or provide buy/sell signals, nor exercise discretion over order routing or execution.

Additional conditions include addressing conflicts of interest, disclosing derivative product risks, adhering to marketing and communication compliance procedures, and maintaining records of related activities.