The no-action relief permits use of non-custodial wallet software in connection with CFTC-regulated derivatives trading, subject to certain conditions.
On March 17, 2026, the CFTC’s Market Participants Division (the Division) issued CFTC Letter No. 26-09 (the No-Action Letter) stating that it would not recommend enforcement against Phantom Technologies Inc. (Phantom) in connection with certain proposed activities involving its digital asset self-custody wallet software designed to enable users to trade in CFTC-regulated derivatives.
