From Watchdog to Builder: What Caroline Pham’s Move to MoonPay Signals for Crypto Policy

Every market transition has its symbolic moments. In US digital-asset regulation, one such moment is unfolding as Caroline Pham, Acting Chair of the Commodity Futures Trading Commission (CFTC), prepares to join MoonPay as Chief Legal and Administrative Officer. At the same time, the CFTC is expected to gain a new leader with deep experience in crypto law, Mike Selig, who is awaiting Senate confirmation.

The headlines are simple: a regulator known for a constructive stance on Bitcoin, Ethereum and stablecoins moves into a private company that builds on- and off-ramp infrastructure. But the underlying story is much richer. It touches on how jurisdictions manage innovation, how agencies think about risk, and how industry participants interpret the so-called 'revolving door' between public service and the private sector.

This article unpacks the implications of Pham’s move for policy, for market structure, and for ordinary participants trying to understand what all of this means for the future of digital assets.

A Regulator Who Spoke the Language of Crypto

During her time at the CFTC, Caroline Pham developed a reputation as one of the agency’s most crypto-literate leaders. Instead of viewing digital assets purely through the lens of enforcement, she consistently argued that clear rules and supervised experimentation were the best way to manage risk.

Several themes defined her approach:

• Support for spot markets under supervision. Pham advocated frameworks that would allow regulated venues to offer spot trading in major digital assets under the CFTC’s oversight, giving investors protections that resemble those in futures and derivatives markets.

• Recognition of collateral role for BTC, ETH and USDC. She pushed for policies that allow Bitcoin (BTC), Ether (ETH) and high-quality stablecoins such as USDC to be used as collateral, subject to appropriate risk controls. The idea was not to give these assets special status, but to place them inside well-understood margin and custody frameworks rather than leaving their use in a grey zone.

• Sandbox and tokenization initiatives. Under her leadership, the CFTC explored pilot programs and sandboxes where banks, exchanges and fintech firms could test tokenized assets and innovative products with limited scale and close supervision.

In short, Pham cultivated the view that innovation should be encouraged inside the rulebook, not outside it. That philosophy makes her transition to a private company particularly interesting: she is leaving the role of referee to become a builder, but she is bringing the rulebook with her.

What MoonPay Gains: A Policy Strategist in an Era of Scrutiny

MoonPay sits at a critical junction in the digital-asset ecosystem. The company operates infrastructure that allows individuals and businesses to convert fiat currency into cryptoassets and back again, using familiar payment methods. As a result, it must navigate a dense web of regulations touching on payments, securities, commodities and consumer protection in multiple jurisdictions.

By appointing Caroline Pham as Chief Legal and Administrative Officer, MoonPay is signalling several priorities.

First, it wants to be seen as a company that designs products with compliance at the centre. Having a recent acting head of a US federal market regulator in charge of legal strategy is a strong statement that the firm expects to be part of the regulated core of the system, not its fringe.

Second, MoonPay gains someone who understands how policy is made in Washington, not just how rules are applied. Pham has experience crafting guidance, negotiating with other agencies and speaking to lawmakers. That perspective is valuable at a time when the US is still debating how to divide responsibilities between the CFTC, the Securities and Exchange Commission (SEC), banking supervisors and state authorities.

Third, the appointment suggests that the boundary between 'traditional' finance and digital-asset infrastructure is becoming more porous. Firms like MoonPay are no longer just technology vendors; they are part of the payment and settlement stack. Having leadership with central-bank and market-regulator experience helps them speak the same language as banks, card networks and supervisors.

The Revolving Door Question: Risk or Opportunity?

Whenever a senior regulator joins a private company in the sector they once oversaw, concerns arise about the 'revolving door.' Critics worry that officials might shape policy with future job prospects in mind, or that companies could gain unfair advantages by hiring insiders.

Those are valid questions to ask, and democratic systems have developed tools to manage them: cooling-off periods, transparency requirements, and recusal rules designed to prevent conflicts of interest. Assuming such rules are followed, a move like Pham’s can also create benefits that are often overlooked.

On the positive side, when experienced regulators join industry, they bring with them:

• A deep understanding of supervisory expectations. This can help companies build products that address risks upfront—around custody, disclosures, market integrity and consumer protection—rather than retrofitting controls in response to enforcement actions.

• Realistic views on what can and cannot be approved. Not every idea is compatible with existing law; having someone who knows where the legal boundaries lie can focus innovation on viable paths instead of on strategies that are likely to be blocked.

• A bridge for dialogue. Healthy markets rely on trust between public and private actors. Leaders who have served on both sides can help translate concerns and reduce misunderstandings.

The key is whether this experience is used to create more robust, transparent practices or merely to navigate around oversight. Given Pham’s track record of advocating for clear rules and responsible experimentation, the former seems the more likely outcome, but ongoing vigilance from journalists, civil society and policymakers remains essential.

A New CFTC Leadership with Crypto Expertise

Pham’s departure coincides with the expected confirmation of Mike Selig, a lawyer known for his work in digital-asset regulation, as the next CFTC Chair. That succession is noteworthy. It suggests continuity rather than a sharp change in direction: the agency is likely to remain engaged with crypto markets instead of stepping back.

A CFTC led by a subject-matter expert has several potential implications:

• The agency may move further toward rule-based clarity on which digital assets fall within its commodity jurisdiction and how platforms should register.
• There could be deeper coordination with other agencies on issues such as stablecoin oversight, cross-margining and custody standards, reducing the patchwork of overlapping or conflicting guidance.
• Programs that allow responsible experimentation—such as sandboxes, limited-scope approvals or no-action letters—might become more structured and predictable.

For market participants, a regulatory environment anchored by people who understand the technology and its risks is usually preferable to one driven primarily by litigation or ad-hoc responses to crises.

Why This Matters Beyond Washington

It is easy to treat these developments as inside-baseball movements within the US policy community. But they have practical consequences for global markets and everyday users.

First, jurisdictional competition is real. Europe is rolling out its Markets in Crypto-Assets (MiCA) framework, the United Kingdom is committing to regulate crypto under a financial-services regime by 2027, and jurisdictions in Asia and the Middle East are offering bespoke digital-asset licences. If US agencies send the signal that responsible innovation is welcome—as Pham did while at the CFTC and may continue to do from the private sector—it becomes easier for the US to remain a key venue for talent and capital.

Second, the combination of a crypto-savvy CFTC and companies like MoonPay led by ex-regulators can help standardise good practices around topics such as customer disclosures, asset segregation, resilience against operational failures and governance of tokenized products. These standards tend to spread across borders because global firms want harmonisation rather than maintaining separate, incompatible systems for each market.

Third, policy choices ultimately shape how ordinary people encounter crypto. If on-ramps and service providers operate within clear supervisory frameworks, users can benefit from stronger consumer protections, better information and easier recourse when problems arise. That does not remove all risk—digital assets remain volatile and involve real uncertainty—but it reduces the 'unknown unknowns.'

From Collateral to Tokenization: Areas Where Pham’s Experience May Be Crucial

One of the most interesting aspects of Caroline Pham’s record at the CFTC is her focus on using digital assets as collateral and on the safe development of tokenized instruments.

In derivatives markets, the quality of collateral is central to stability. Allowing BTC, ETH and selected stablecoins to serve as margin assets requires careful calibration: appropriate haircuts, concentration limits, stress-testing and contingency planning. Regulators need to understand both the upside of broader collateral options and the downside of rapid price swings.

Someone who has wrestled with these questions from the regulatory side can bring that discipline into product design. For a company like MoonPay, that might translate into:

• More conservative and transparent policies on which assets it supports and how it manages treasury exposures.
• Closer alignment with banking-sector expectations for liquidity buffers and capital planning.
• Thoughtful engagement in industry discussions on how tokenized deposits, money-market funds or real-world assets should be structured.

The same applies to tokenization more broadly. When banks and fintech firms issue tokenized claims on traditional assets—such as treasury bills or cash reserves—questions arise about legal enforceability, segregation of assets, redemption rights and disclosures. A leader familiar with both the potential benefits and the regulatory guardrails can help avoid missteps that might otherwise slow adoption.

Implications for Builders and Investors

For developers, entrepreneurs and investors, what lessons emerge from this transition?

1. Compliance is becoming a competitive advantage. In the early days of digital assets, some projects treated regulation as an afterthought. Today, the trend is toward compliance-first strategies, especially for infrastructure firms that handle fiat on-ramps, stablecoins or tokenized financial products. The hiring of former top regulators into leading roles is a visible sign of that shift.

2. The policy conversation is moving from 'if' to 'how.' With a CFTC chair-designate who specialises in crypto law and a former acting chair joining one of the best-known on-ramp providers, the debate is less about whether digital assets should exist and more about under what conditions they should operate. That does not guarantee lenient rules, but it does favour clarity over uncertainty.

3. Long-term participants should watch regulations as closely as prices. Market cycles can be dramatic, but the underlying regulatory architecture often matters more for multi-year outcomes. Licensing regimes, collateral standards, and cross-border recognition of digital-asset products will influence which business models are sustainable.

Practical Considerations for Everyday Users

For individuals who use services like MoonPay to access crypto assets, it is important to keep realistic expectations. Having former regulators in leadership positions does not make any platform risk-free, and digital assets themselves can fluctuate significantly in value.

However, users can reasonably expect that a company led by people with Pham’s background will focus heavily on:

• Clear disclosures about fees, supported assets and terms of service.
• Robust compliance programs related to identity verification, anti-money-laundering controls and transaction monitoring.
• Careful custody arrangements and risk-management practices around how assets are held and how operations are secured.

Even so, good personal habits remain vital. Users should diversify their holdings, understand the basic differences between custodial and self-custodial solutions, and avoid making decisions based solely on short-term market moves or high expectations.

Conclusion: A Bridge Between Two Worlds

Caroline Pham’s transition from Acting CFTC Chair to a senior leadership role at MoonPay is more than a career change. It is a symbol of a broader convergence: regulators, banks and fintech companies are increasingly interacting within the same ecosystem rather than standing on opposite sides of a divide.

Whether this convergence ultimately produces a safer, more inclusive financial system will depend on how both sides use the opportunity. If industry participants treat regulatory experience as a toolkit for building transparent, resilient products—and if public agencies continue to refine rules in light of real-world experimentation—the result could be a healthier balance between innovation and protection.

For now, one thing is clear: the conversation around digital assets is maturing. The presence of former top regulators inside leading crypto companies is a sign that the sector is moving from the margins toward the mainstream, where responsibilities are heavier, but the potential for lasting impact is greater as well.

Disclaimer: This article is for educational and informational purposes only and does not constitute legal, investment or tax advice. Regulatory frameworks and market conditions can change rapidly. Readers should conduct their own research and consult qualified professionals before making decisions related to digital assets or financial services.