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Caroline D. Pham is an American attorney who serves as the acting Chairman of the Commodity Futures Trading Commission (CFTC). She was nominated as a commissioner by President Joe Biden and unanimously confirmed by the U.S. Senate in 2022, before being designated acting chair by President Donald Trump in 2025. [1] [2]
Pham was born in Modesto, California. Her parents were born in Vietnam and were evacuated by helicopter from the U.S. Embassy in Saigon in April 1975.
Pham earned a Bachelor of Arts degree from the University of California, Los Angeles (UCLA) in 2005 and also received a certificate from the UCLA Anderson School of Management. She later obtained a Juris Doctor from the George Washington University Law School. [1] [2]
Pham began her career in financial services working as an assistant at the law firm Sullivan & Cromwell from 2005 to 2008. During her legal studies, she held internships at the CFTC, the Securities and Exchange Commission (SEC), and the Office of the Comptroller of the Currency (OCC). She also served as a judicial extern for Loren A. Smith, a former chief judge of the U.S. Court of Federal Claims. From 2013 to 2014, Pham served as a special counsel and policy advisor to CFTC Commissioner Scott D. O'Malia.
Following her initial tenure in public service, Pham joined Citigroup in 2014, where she held several executive and leadership positions for nearly eight years. Her roles included managing director, deputy head of global regulatory affairs, head of capital markets regulatory strategy, and global head of swap dealer and Volcker Rule compliance. In her most recent position at the firm, she was the head of market structure for strategic initiatives, where she worked with teams focused on innovation, venture capital, and business development related to digital assets. Throughout her time at Citigroup, she advised the board and senior management on regulatory changes, emerging trends, and economic developments affecting global financial markets.
In December 2021, President Joe Biden announced his intention to nominate Pham to serve as a commissioner of the CFTC. The U.S. Senate confirmed her nomination on March 28, 2022, and she was officially sworn into office on April 14, 2022. On January 20, 2025, she was designated as the acting Chairman of the CFTC by President Donald Trump.
As acting Chairman, Pham has focused on transforming the agency by implementing significant cost savings, enhancing governance and accountability, and updating the CFTC's performance plans for the first time in eight years. She has also overseen the issuance of numerous staff letters and guidance documents to provide regulatory clarity.
Pham is the sponsor of the CFTC’s Global Markets Advisory Committee (GMAC). Under her leadership, the committee has delivered recommendations on a range of financial market issues, including U.S. Treasury market reform, central counterparty resilience, tokenized collateral, and the development of a U.S. digital asset taxonomy.
A significant focus of her tenure has been on digital assets and cryptocurrency regulation. In August 2025, Pham announced a "crypto sprint" to begin implementing recommendations from the President's Working Group on Digital Asset Markets. As part of this effort, she launched an initiative to create a framework for trading spot crypto asset contracts on CFTC-registered futures exchanges, known as designated contract markets (DCMs). The initiative invited public feedback on how to use the CFTC's existing authority under the Commodity Exchange Act to provide a clear path for listing these products. This effort is coordinated with the SEC's "Project Crypto" and aims to establish the United States as a leader in digital asset markets.
Pham has received several awards and recognitions for her work in law and finance.
These honors acknowledge her contributions to financial regulation and her leadership within the legal and Vietnamese-American communities. [1] [2] [3] [4] [5]
In an interview released on June 21, 2022, on the Unchained YouTube channel, Caroline Pham, commissioner at the Commodity Futures Trading Commission (CFTC), presented her perspective on the regulatory environment for digital assets in the United States. She recalled her initial professional contact with crypto in 2013 while working at the CFTC and outlined the trajectory that led to her current role as commissioner.
Pham described the U.S. financial regulatory system as decentralized, involving multiple agencies with overlapping responsibilities. In her view, this structure offers certain advantages by supporting a variety of approaches, but it also creates obstacles to establishing a unified regulatory framework for crypto assets. She emphasized that regulation should be technology-neutral, providing clarity for market participants while ensuring protections remain in place.
She characterized the state of U.S. crypto regulation as a “B-,” pointing to the adaptability of existing rules alongside ongoing gaps in clarity and coordination. Pham noted that provisions already available to the CFTC, including anti-fraud and anti-manipulation authorities, could be used in the oversight of crypto markets.
During the discussion, Pham also addressed the importance of international coordination, given the global nature of digital asset markets. She cited risks such as algorithmic stablecoins, which she suggested may be subject to derivatives oversight, and what she referred to as “shadow banking 3.0,” describing financial activities within crypto that operate outside of conventional supervisory systems.
On the subject of decentralized systems, Pham highlighted the challenges of regulation when intermediaries are absent, as intermediaries traditionally perform functions related to risk management, compliance, and consumer protection. She indicated that new market structures, including proposals to automate certain intermediary functions, require careful examination before adoption.
Throughout the interview, Pham reaffirmed several principles she considers central to her regulatory approach: maintaining technology-neutral rules, balancing innovation with market safeguards, and ensuring transparency in engagement with both the public and industry. She also noted legislative initiatives such as the Responsible Financial Innovation Act as contributing to greater clarity regarding the division of responsibilities among agencies. [6]
On January 31, 2023, Caroline Pham took part in the panel “Fireside Chat on Regulation and Risk”, organized by the Global Blockchain Business Council (GBBC) and broadcast on the organization’s YouTube channel during Blockchain Central Davos. The session was moderated by GBBC CEO Sandra Ro.
During the discussion, Pham outlined her perspective on how regulators should address both the risks and opportunities associated with digital assets and blockchain technology. She noted that, in the aftermath of the FTX collapse and broader market instability in 2022, the United States still lacked a comprehensive regulatory framework for crypto markets. In her view, this absence highlighted the relevance of safeguards such as risk management procedures, clear disclosures, and the segregation of customer assets.
Pham also commented on the growing use of enforcement actions by agencies including the CFTC, SEC, and DOJ. While enforcement can provide some degree of clarity, she suggested that formal rulemaking and public consultations would create a more effective regulatory environment. She further pointed to the importance of recognizing firms that aim to comply with existing standards and implement sound risk practices.
A key point raised in the session was the establishment of the Global Markets Advisory Committee (GMAC), an initiative within the CFTC chaired by Pham. The committee brings together representatives from both traditional financial institutions and crypto-native firms, serving as a forum for dialogue on balancing innovation with risk oversight.
When addressing decentralized finance (DeFi), Pham drew a comparison to regulatory approaches in algorithmic trading, emphasizing oversight focused on operational and technological risks rather than the underlying code. She identified three areas requiring regulatory consideration:
Pham also discussed the international context, observing that regulators and central banks in other jurisdictions were moving ahead more rapidly with experimentation and policy development related to digital assets. She cautioned that this dynamic could position the United States as a “rule taker” rather than a “rule maker.” To address this, she stressed the importance of cross-border cooperation through organizations such as the Financial Stability Board (FSB), the International Organization of Securities Commissions (IOSCO), and the Basel Committee.
Overall, Pham presented the view that regulatory clarity, effective risk management, and international collaboration are essential components for developing a more stable and transparent digital asset ecosystem. [7]