Caroline D. Pham

Pham grew up in California’s Central Valley, where her family ran almond and peach orchards. As a child she took part in 4-H and showed horses at local fairs.⁠[1]

She earned a Bachelor of Arts in political science from the University of California, Los Angeles, in 2005. In college she worked as an assistant at a law firm to support her studies; after graduating she worked at a large New York law firm, an experience that led her to decide to study law.⁠[1][2]

In 2011 she received her Juris Doctor from the George Washington University Law School, where she held the Manatt-Phelps Banking Law Fellowship; in 2024 the school gave her its Belva Ann Lockwood Alumni Award.⁠[3]

In a judicial internship after her first year of law school, Pham worked for Loren Smith, former chief judge of the U.S. Court of Federal Claims, on litigation related to bank failures, which drew her to banking law. She went on to build experience in financial regulation, serving as special counsel and policy advisor to CFTC Commissioner Scott O’Malia.⁠[2][4]

In 2014 she joined Citigroup and built its market regulation implementation team. She later held roles including deputy head of global regulatory affairs, focusing on fintech, blockchain and digital asset policy.⁠[5]

Before her appointment as a CFTC commissioner, Pham was a managing director at Citigroup responsible for market structure in strategic initiatives, and had worked on capital markets regulatory strategy and the implementation of reforms including the Dodd-Frank Act.⁠[4]

Pham was nominated as a CFTC commissioner in January 2022, unanimously confirmed by the Senate on March 28 and sworn in on April 14. As commissioner she sponsored the Global Markets Advisory Committee, working on issues including market structure, collateral and digital assets.⁠[6][4]

In 2023 she proposed a pilot program for regulating U.S. digital asset markets, aiming to support market innovation through a supervised testing mechanism. This direction later carried into her digital asset work as acting chairman.⁠[4]

On January 20, 2025, the CFTC commissioners unanimously selected her as acting chairman. On December 8 of that year she announced a digital asset collateral pilot allowing eligible futures commission merchants, in an initial phase, to accept bitcoin, ether and USDC as margin collateral, subject to reporting and risk management requirements.⁠[6][7]

The CFTC’s official record shows that Pham’s service as commissioner and acting chairman ended on December 22, 2025. On December 17, MoonPay had announced that she would join the company after leaving the CFTC as chief legal officer and chief administrative officer.⁠[8][9]

On July 17, 2023, the CFTC’s Global Markets Advisory Committee (GMAC), sponsored by Pham, held its second public meeting at the New York Stock Exchange, covering U.S. Treasury market reforms, swap block thresholds and tokenization of assets. Its 2023–2025 work program included Global Market Structure, Digital Asset Markets and Technical Issues subcommittees.⁠[10]

On September 27, 2023, Pham dissented from the consent order in CFTC v. Xie, arguing the violation should be framed as “misappropriation of confidential information in breach of a pre-existing duty of trust and confidence” rather than with the securities-law term “material non-public information,” and citing the four-part test in CFTC v. EOX Holdings. She noted that derivatives “end users necessarily trade on the basis of their own proprietary information in order to hedge their risks.”⁠[11]

On August 14, 2024, Pham dissented from the CFTC’s $3 million off-channel communications recordkeeping settlement with introducing broker Cowen and Co., saying the record held no evidence that any CFTC-registered associated person violated the rules and that the case “appears to be the CFTC’s piggybacking off the SEC’s investigation.” She wrote: “I am unable to support an enforcement action that does not have any evidence that the alleged violations actually occurred.”⁠[12]

On September 23, 2024, she dissented from a similar settlement with Piper Sandler Hedging Services, citing “the lack of evidence that a CFTC violation occurred,” jurisdictional limits, and saying she “cannot support the CFTC’s double-dipping on SEC violations.”⁠[13]

On November 21, 2024, the GMAC approved without objection a recommendation to expand non-cash collateral use through distributed ledger technology, providing a legal and regulatory framework for applying existing margin policies to it. The CFTC said it was the GMAC’s 14th recommendation in 12 months, the most of any advisory committee in that period.⁠[14]

Pham said: “Embracing new technology does not mean compromising on market integrity.”⁠[14]

On January 27, 2025, Acting Chairman Pham announced a series of public roundtables on affiliated entities and conflicts of interest, prediction markets and digital assets. On February 5 the CFTC announced a prediction markets roundtable, to follow its requests for information on sports-related event contracts; Pham called prediction markets “an important new frontier in harnessing the power of markets to assess sentiment” and criticized “the undue delay and anti-innovation policies of the past several years.”⁠[15][16]

On February 4 she announced the consolidation of the Division of Enforcement’s task forces into a Complex Fraud Task Force and a Retail Fraud and General Enforcement Task Force, saying the “simplified structure will stop regulation by enforcement and is more efficient.” On February 14 she named Brian Young, former Whistleblower Office director and acting enforcement director since January 22, as Director of Enforcement.⁠[17][18]

On May 13, 2025, after a federal court special master’s report found the CFTC had made multiple false statements to the court in CFTC v. Traders Global Group, Pham said she had raised concerns before the complaint was filed and during the litigation; staff had been removed from the case and placed on administrative leave pending investigation, and remediation included reorganizing Enforcement and issuing self-reporting and cooperation guidelines. She said: “This case is a wakeup call to those of us who hold and serve the public’s trust.”⁠[19]

On August 1, 2025, Pham announced the CFTC Crypto Sprint to implement the President’s Working Group on Digital Asset Markets report, working with SEC Chairman Paul Atkins and Commissioner Hester PeirceHester PeirceHester Peirce is a lawyer and financial regulator who served as a Commissioner of the U.S. Securities and Exchange Commission (SEC) from January 2018 to October 2026 and was appointed in January 2025 to lead the agency’s Crypto Task Force. She long advocated clear rules for crypto assets, opposed regulation by enforcement, and proposed a token “safe harbor.”Open the full entry on Project Crypto. Its first initiative, on August 4, sought comment on listing spot crypto asset contracts on CFTC-registered designated contract markets; on August 21 the CFTC sought feedback on the report’s other CFTC-related recommendations, with comments due October 20.⁠[20][21][22]

On December 4, 2025, Pham announced that listed spot crypto products would trade for the first time on CFTC-registered futures exchanges, saying “the CFTC is finally using our decades-long existing authority.”⁠[23]

In April 2026, after acquiring Sodot, MoonPay launched an institutional business led by Pham, offering financial institutions infrastructure including wallets, custody, trade execution and stablecoin settlement; as of September her public titles were chief executive officer of MoonPay Institutional and chief legal officer and chief administrative officer of MoonPay.⁠[24][25]

In May, a media investigation reported that CFTC staff had raised questions about some crypto firms with ties to Trump, that the staff involved were later reassigned or sidelined, and that Pham and others had intervened in approvals. A White House spokesperson denied any conflict of interest; Pham had not responded to a request for comment at the time. These are allegations from a media investigation.⁠[26]

In June, MoonPay announced a partnership with Franklin TempletonFranklin TempletonFranklin Templeton is a global asset management company headquartered in San Mateo, California, United States. Founded in New York in 1947, its parent company is listed on the New York Stock Exchange (ticker: BEN), and it had approximately $1.83 trillion in assets under management at the end of August 2026. The company has pursued digital assets since 2018, launched FOBXX (BENJI), a U.S. government money fund that records shares on a blockchain, in 2021, and in 2026 established Franklin Crypto, a dedicated crypto asset management division.Open the full entry to integrate Benji Trade into its institutional business, allowing eligible institutional clients to use stablecoins to access related tokenized fund products.⁠[27]

On September 17, MoonPay Institutional announced a partnership with WisdomTree to give eligible U.S. investors access related to WTGXX and planned to use the fund for stablecoin reserves. Pham took part in the announcement as chief executive of the institutional business.⁠[28]

On September 23, MoonPay announced a definitive agreement to acquire North Capital, planning to add capabilities including securities brokerage and investment advice. The announcement made clear that the deal was still subject to regulatory approvals and customary closing conditions and had not been completed.⁠[29]

Speaking at Token2049 Singapore in October 2026 as MoonPay’s chief legal officer and chief administrative officer, Pham said that under the Commodity Exchange Act “pretty much everything is a commodity except for onions and movie box office receipts,” and that the CFTC does not need Congress to regulate crypto; the Clarity Act had failed the previous month.⁠[30]

She also predicted that the NYSE and Nasdaq would list tokenized shares with real trading volume within two years, argued that banks’ net settlement will rely on tokenized deposits while stablecoins suit counterparties that do not trust each other, and expected a second wave of NFTs once regulation is clearer, describing them as customer-engagement tools akin to loyalty programs rather than securities.⁠[30]

MoonPay: the company where she currently holds executive roles; official website: https://www.moonpay.com/ (opens in a new window)⁠[9][25]

U.S. Commodity Futures Trading Commission: the federal regulator where she served as commissioner and acting chairman; official website: https://www.cftc.gov/ (opens in a new window)⁠[8]

Citigroup: the financial institution where she previously worked; official website: https://www.citigroup.com/ (opens in a new window)⁠[4]

University of California, Los Angeles: her undergraduate alma mater; official website: https://www.ucla.edu/ (opens in a new window)⁠[1]

George Washington University: where she earned her Juris Doctor; law school website: https://www.law.gwu.edu/ (opens in a new window)⁠[3]

Personal X account: https://x.com/CarolineDPham (opens in a new window)⁠[25]