The U.S. Commodity Futures Trading Commission (CFTC) is one of the main regulators engaged in the cryptocurrency space. Between the first quarter of 2015 and the third quarter of 2025, the CFTC brought 130 actions against virtual currency market participants, including traders, exchanges, and service providers.
KEY TRENDS
The CFTC did not bring any virtual currency enforcement actions during the first three quarters of 2025, after bringing 10 such actions in 2024 and 44 in 2023. This downshift in enforcement actions followed the leadership transition at the CFTC announced in January 2025, as Chairman Rostin Behnam resigned and Ms. Caroline Pham was named Acting Chair.
CASE DURATION
For the 37 cases resolved in U.S. district courts, the median time from the date of the complaint filing to the case resolution was 496 days.
VENUE
Of the 50 cases litigated in U.S. district courts, 40% occurred in the state of New York.
As of December 16, 2025, 37 of the 50 cases litigated in U.S. district courts had reached a resolution.
ALLEGATIONS
The majority of actions, 95 out of 130, involved alleged failure to register with the CFTC or allegedly false registration claims.
Additionally, 51 of the 130 actions involved an allegedly fraudulent scheme, while 25 involved allegedly illegal retail or off-exchange transactions.
ENFORCEMENT AMOUNTS
In 2023 and 2024, fines and restitution amounts ordered by the CFTC or U.S. district courts totaled over $19.4 billion across 23 cases (including partial resolutions).
For more information on this topic, please see Trends in CFTC Virtual Currency Enforcement Actions.
The views expressed herein are solely those of the authors and do not necessarily represent the views of Cornerstone Research.
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