CFTC Updates Crypto Guidance for Tokenized Customer Funds and On-Chain Records

CFTC updates crypto guidance allowing tokenized customer investments and blockchain-based

The U.S. Commodity Futures Trading Commission has updated its guidance on crypto assets and blockchain technology, clarifying when regulated firms can use tokenized versions of permitted investments and blockchain systems for recordkeeping.

Coin Bureau reported the update in a post on X on September 24, citing changes to the CFTC's crypto-related frequently asked questions. The agency said its staff added four new answers and revised one existing response, addressing tokenized investments and the use of blockchain technology in regulated activities.

Tokenized Investments Gain Regulatory Clarity

Under the updated guidance, futures commission merchants and derivatives clearing organizations may invest customer funds in tokenized forms of investments that are already permitted under applicable CFTC rules, provided the tokenized asset gives the holder the same legal and economic rights as the underlying traditional investment.

The CFTC's clarification applies to tokenized representations of permitted investments rather than treating tokenized assets as a separate category of customer-fund investments. The agency's earlier guidance defined tokenized assets as digital representations of real-world assets, including U.S. Treasury securities, corporate bonds, money markets fund shares and equities, recorded on a blockchain.

The updated FAQs also address tokenized government money market funds. According to the CFTC, firms may use tokenized forms of permitted investments subject to the applicable conditions, including requirements concerning custody and the legal rights associated with the assets.

Blockchain Records Can Support Regulated Operations

The September 24 update also addresses blockchain-based recordkeeping. CFTC staff said the revised FAQs cover the use of blockchain technologies to satisfy certain recordkeeping requirements applicable to registrants and registered entities.

That clarification builds on the agency's broader work examining how blockchain infrastructure can be used within regulated financial markets without changing the underlying legal and regulatory obligations.

The CFTC's earlier tokenized-collateral guidance, issued in December 2025, stated that a tokenized asset could represent ownership or claims associated with an underlying real-world asset and could potentially allow faster transfers through digital platforms.

Tokenized Money Market Funds for Swap Margin

The updated framework also addresses uncleared swaps. Swap dealers can use tokenized forms of eligible money market fund shares as margin collateral when the underlying asset satisfies the applicable requirements and the token provides the holder with the same or functionally equivalent legal and economic rights.

The CFTC had previously clarified that tokenized forms of eligible collateral could be used in futures and swaps transactions under specified conditions. The latest FAQs provide additional detail on how that principle applies to tokenized investments.

The agency said the updated FAQs are intended to provide greater clarity to market participants regarding activities involving crypto assets and blockchain technology. The guidance follows earlier CFTC initiatives focused on tokenized collateral and digital assets used in regulated derivatives markets.

The September 24 update leaves the existing regulatory conditions in place while Cryptocurrency clarifying how tokenized versions of permitted investments can fit within those requirements.

Writer: Victoria Hale
Technology & Blockchain Writer

Victoria Hale writes about blockchain technology, digital infrastructure, and the intersection of emerging technologies with finance. Her articles explore how new protocols and systems are shaping the evolving digital economy.

She prioritises clarity and accuracy when explaining technical developments to a general audience.