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Host
Carolyn Pham, the former CFTC commissioner now leading moonpay's institutional push, says crypto has roughly two and a half years to become too big to fail. And the numbers prove it. Stablecoins did 28 trillion in volume in a single quarter, dwarfing Visa and MasterCard combined. Tokenized repo is hitting 10 trillion every month. And 2026, she says, is officially the year of institutional adoption.
Carolyn Pham
I came out, I think January 2nd or January 3rd and I said 2026 is going to be the year of institutional adoption. It's like, Caroline, why are you saying that? Because I've been working on it since 2018.
Host
In this conversation, the woman who built America's first digital asset taxonomy breaks down what MoonPay institutional actually means for every bank and asset manager on Earth.
Carolyn Pham
J.P. morgan, for example. They have spent years building their own proprietary tech stacks that have on chain capabilities. But if you're now just coming to the game because now you realize you actually are allowed to do so, how are you going to get up to speed if you have an infrastructure partner who can deliver for you? Blockchain in a box and it's turnkey. That's what everybody wants.
Host
Why the DEFI is incompatible with KYC narrative is a complete fallacy.
Carolyn Pham
Moonbay has been doing KYC AML since it was founded in 2019. That's on non custodial wallets. 30 million users, 180 countries. It works.
Host
It's possible what the real convergence between TRADFI and DEFI looks like at scale.
Carolyn Pham
All of these major institutions have been investing at this point in time. It's billions of dollars across the industry. This is a whole scale upgrade of financial pipes and plumbing.
Host
And why a bitcoin in every brokerage account changes the game forever. Let's go.
Carolyn Pham
That's dope. That's dope.
Interviewer
How many shows are you doing? How many of these are you doing while you're here?
Carolyn Pham
I ask Casey, I just go where she tells me. Casey's actually my boss.
Interviewer
Like, is secretly your boss?
Carolyn Pham
Yeah, Casey's bossing it up.
Interviewer
All right, get her a third chair. Let's go. So you're having more fun in the crypto industry than you were the cftc, or is that the real party over there?
Carolyn Pham
No comment.
Interviewer
What has that transition been like for you? I mean, it's a pretty stark difference, I would imagine, in your day to day.
Carolyn Pham
Honestly, for me, the hardest transition going to the private sector was slack. I hate slack with a passion.
Interviewer
Well, it's slack.
Carolyn Pham
It reminds me of like aol Instant messenger, when you used to have all the different tabs, that would be different conversations. So I'm trying to figure out, like, how do I get back to this, like, DM that I had, or where's this channel? So the slack is. I'm like, four months in, and the slack is still, like, very challenging. The other thing that I really hate is I do not like Google Mail or Google Docs or Google Slides, because. I'm sorry, I'm like a Microsoft Office 98 person. I like my Word and my PowerPoint.
Interviewer
You know, you get, like, it becomes so habitual, the short shortcuts and the keys and.
Carolyn Pham
Yeah, so it's hysterical because I'm at the cutting edge of, like, defi blockchain technology. And then I'm like, PowerPoint.
Interviewer
Yeah, you're one of us that you described me to a team, right. I couldn't make a PowerPoint presentation.
Host
Thank God.
Interviewer
I could just chat GPT, like, prompt now.
Carolyn Pham
Exactly. And they tried to tell me. They're like, no, no, no. Like, just make slides off Nano Banana. I'm like, excuse me, What?
Interviewer
Like, that's literally not a real thing. We got Nano Banana with our LED screen. It was part of the package. I've never used Nano Banana.
Carolyn Pham
I was like, oh, no, I'm good.
Interviewer
Okay, so you've been in the role now for a few months, so I'm sure you're getting comfortable. What's the main focus I saw, obviously, Moonpay Institutional is launching. I've got to imagine that, that that's a big project for you.
Carolyn Pham
That is super fun. I've been really excited to launch Moonpay Institutional. But even taking a step back, for me, coming to Moonpay was really seeing this vision that our founder and CEO, Ivan Soto Wright, had, and Keith Grossman, our president, who's a dear friend of mine, which was about really creating the future operating system for value. So think about it, like right now with, you know, with our Google search, with any kind of, like, AI chatbot that you're using, you can just type, right, what you want to do into a chat box and then be able to do it. Well, with Agentic Payments, which we launched with Moonpay agents a couple weeks ago, and with all the capabilities that we're bringing together, why shouldn't you be able to interact with your money the same way or your value the same way by just typing what you want to do in just natural language and having that work? So this is something that's really exciting, seeing that all come together. But Underneath the hood of all of that is having a really robust tech infrastructure platform that is compliant, that does comply with regulations, that has kyc, aml. And so kind of bringing that vision together about how do we take where Moonpay started with its roots in 2019, being DeFi, being non custodial, scaling to like 30 million users in 180 countries, we can do settlement in 120 fiat currencies. I actually was blown away when I found that out. And now let's enable it for institutional clients because I think right now we're seeing finally this thesis that I've had for years now, starting with when I worked on digital asset strategy at Citi where I was the managing director. I was there for seven years. We are finally moving to open architecture for payments and market infrastructure. Right. Just the way you had open banking, just the way you have fintechs and you're able to decompose the different transactions that you want to do. We're going to see that happen with financial markets. And so to me, not only do you have this move towards an open architecture for payments and financial market infrastructure, but you also finally have the regulatory clarity that is necessary with the SEC and the CFTC doing a token taxonomy, for example, and a lot of other rulemakings that they have in the pipeline. Everything I did last year to make America the crypto capital of the world, of course, the strong leadership from the President and from the administration, now you finally have that moment where you're going to see convergence between TradFi and DeFi. So open architecture, TRADFI and Defi, and what enables all of that is having regulated compliant Rails, which moonfay provides.
Interviewer
And I would imagine you're in a unique position to bring that insight having been at the cftc. Yes, because everybody else can kind of guess, you know.
Carolyn Pham
Sure. But even before that I was a global compliance executive at Citi. Even before that. That's where I kind of started when I went to the private sector originally after being staff at the cftc. So understanding what it's like to navigate all of the regulations around the world. I used to lead engagement with all of cities, regulators around the world. There's a lot. Short answer. Being able to lead examination strategy, looking at all of that and knowing what it takes to have the types of resilience infrastructure with the controls, the right policies and procedures, the right governance and risk for frameworks, all of that is really important. So you know, pipes and plumbing, people think like this is boring, like this is all the stuff that's on the back end. But it actually is probably the most exciting and transformational part of that. So by having this open platform, like I said, where we provide white label solutions, it's MoonPay institutional is really designed to serve our partners who are banks, who are asset managers, who are trading firms and who are exchanges. Because you have to make this decision between what's your digital asset strategy, are you going to build, are you going to buy? Now firms like the biggest banks, like a JP Morgan for example, they have spent years building their own proprietary tech stacks that have on chain capabilities. But if you're now just coming to the game because now you realize that from a regulatory perspective you actually are allowed to do so, you know, you don't have debanking, you don't have those things going on now how are you going to get up to speed? Well, if you have a partner, an infrastructure partner who can deliver for you blockchain in a box, you plug into it, you turn it on, you can integrate it into your own systems, you get to keep your own infrastructure, you get to keep your own customers and clients and it's turnkey, that's what everybody wants. We have a direct API integration. I'm not going to nerd out too much about all the nerd it out statistics, but it is really something where I think that's what people want. Especially if you think about like what do we see in the United States? In the United States we have such a diverse and varied financial system from the largest banks to the smallest banks. And everybody's going to want to figure out how do I turn on and enable the digital asset ecosystem, how do I turn on defi. It's real, it's not going away. People like having their own wallets, they like being able to plug in, they like being able to just like, you know, push a button, send value from one place to the other place. And so it's just marrying that convenience. But again, how do you like own that relationship with your customer?
Interviewer
So what products are these institutions looking for and what is the full suite of the offering?
Carolyn Pham
Absolutely.
Interviewer
Seems like there's a lot of things they can be doing in crypto and offering all of them would be a challenge.
Carolyn Pham
Honestly when you look at it, it is really all of the products and services that are currently being offered across banking, payments, wealth management, trading, all of that is enabled on blockchain. We're seeing that move. You've seen some of the biggest announcements, even just this week about tokenized securities. Obviously payments has been something that's already been moving towards blockchain for a long time. So what we see is first of all like secure wallet infrastructure. So we acquired soda in $100 million. All stock acquisition. They have the best in class. You know, it's Israeli defense tech, it's cybersecurity, it's cryptography. They provide the secure wallet infrastructure for BitGo, for example, for eToro, for Flow Traders, for Flow Desk. So just seeing the scale of what that is, I think it's 50 billion that they have secured already today. So that's something where you can white label that and all of a sudden you're able to offer your secure wallets right now. The other thing that we have that I think is super, super exciting that we're just starting to see is like tokenized fund distribution is very exciting. Being able to provide instant liquidity for stablecoin settlement 24 7. So the thing is is that a lot of this is still on that like T plus 2 or like over the weekend and you can't get that liquidity. We set up our stablecoin liquidity facilities that are always on and it provides that instant liquidity because we have this technology which is super exciting where we are connected to, you know, any chain, any token, any wallet. 200 plus chains enabled today. Auto scaling capabilities, native cross chain movement, interoperable between permissioned and permissionless networks. These are the things that provide aggregated defi liquidity that traditional financial institutions and trading firms and asset managers are looking to mobilize. So tokenized fund distribution is very exciting for us. Instant liquidity solutions like I said, obviously stablecoin settlement, stablecoin payments. And so when you think about the entire end to end, I actually don't think anybody has assembled this type of tech stack the way that Moonpay has. Moonpay's already had I think over 8 like almost maybe 10 plus acquisitions in the last year or two. And again it's because you know Ivan Keith, our corporate development team, Abe who leads that they've had this vision for a true operating system for value.
Interviewer
What's so interesting to me, and maybe I have the evolution wrong, but Moonpay was very much a retail focused platform and it seems like everything you built for retail all of a sudden is when you put it all together as purpose built for institutions. Because Moonpay wasn't the first to try to provide institutional solutions. But you have it all.
Carolyn Pham
Exactly. Well what I realized is, you know, I came to moonpay to help to grow and scale the business right? Like I'm here, I'm in it to win it. And with my background obviously having led a lot of the initiatives around developing digital asset products and services, with the Citi team being the head of market structure on the institutional clients group business development team, being in the chief administrative office of Citi, working closely on strategy and risk across the firm, I realized that when you're able to deliver those types of products at scale with that kind of resiliency and that kind of security, this is where we are actually seeing the maturation of the DEFI ecosystem where it is now institutional grade. Right. It took a long way to get there. It always was the case. Years ago when we were looking at this back in 2018, it was sort of like, well, it doesn't really scale. It doesn't really have the kind of security that's necessary. It doesn't really have the resiliency that's necessary. But when you look at what's going on right now, I mean when you think about, you know, there are probably over $10 trillion worth of just tokenized repo transactions a month that's happening on Blockchain. Right. I mean a lot of people are focused on sort of these little numbers. I like to sort of quote this Jay Z song. So I'm all about those tease. And that is, I mean I also, every time I post quadrillions like everybody goes nuts. But it's true, like that's what we're really looking at. We're looking at a full on modernization of the system. Stable, even just stablecoins. I think that even just in Q1 of 2026 we've had 28 trillion in volume in stable coins alone. That's just one quarter.
Interviewer
Yeah. I mean it's dwarfing, It'll be dwarfing ACH and Swift I think this year. And Visa and MasterCard are like a tiny little bar on the chart now versus stablecoin volumes.
Host
What do you think when you look
Interviewer
forward are going to be the. You can't call for a black swan. Right. But the crypto industry has, let me put it this way, the crypto industry has a long history of own goals. We are the masters of shooting ourselves in the foot. You were at the cftc, you saw everything and now you're here. So is there anything glaring that you see as kind of a big obstacle, somebody, something that's going wrong in this industry that we need to kind of re steer?
Carolyn Pham
Yeah.
Interviewer
And you're steering around it obviously on moonhat Moonpay's behalf. Yeah.
Carolyn Pham
So there's two things that I feel like the industry would really help themselves a lot if they maybe recalibrated or reframed the narrative. Right, that they're pushing. So number one, this idea that DEFI is incompatible with KYC and AML is just a fallacy. Right? Like I said this in the beginning, like moonpay has been doing KYC AML since it was founded in 2019. That's on non custodial wallets again, 30 million users, 180 countries, it works, it's possible. So I know that there's people who are out there saying, oh, that's against the DEFI ethos to do KYC aml. And it's like, oh, so you want to be facilitating what, like terrorism? No, that's awful. That's a terrible thing to do. So let's be adults here and realize that yes, it is good to have KYC and AML laws and regulations. That is what we should be doing. We should be responsible. The other thing that I think would be helpful as a reframe because a lot of crypto uses crypto words and it's very technical and it's a lot of like jargon, it's a lot of tech speak and it kind of freaks people out. Right? I think it would be better if instead of saying, oh, we're going to disrupt this, we're going to blow everything up and create a whole brand new financial system, like, realistically, okay, banking and markets have been around for like hundreds, thousands of years. We're not really going to blow everything up and start all over again. So if we actually just looked at this as modernization, why is this so different from going from paper to computers to now blockchain, which is really just decentralized computing anyway. That sounds less scary and much more common sense. And if you want to bring the world with you, if you want to bring policymakers with you, regulators with you, it would be a lot better if you just reframed it as like, look, this is modernization. I mean, imagine if people were like, oh, you know, computers is going to disrupt everything and we're going to like blow everything up. We would still be on paper.
Interviewer
Yeah, DeFi's had a long month or two, right. So do you think that that's had an impact on how institutions view participating in DEFI or even what you're building? Obviously, you know, everybody's sensitive to North Korean hackers taking hundreds of millions of dollars of people's money.
Carolyn Pham
I think what happened is actually a great example of why you need to have secure wallet infrastructure available, which is why moonpay made such a big bet on it by acquiring sodot, which was, you know, founded by Udo Sofer and his team. And they have, I think over 20, 30 years in cybersecurity and cyber defense. What they have built is really special, I think. And so, yeah, that's a big bet, $100 million all stock. But you do need that security. And so I actually feel like that happening just sort of proved our point about why you want to go and white label the best tech possible. Like yes, maybe you did build your own in house solution, but you built it a couple years ago. And you know, if you are stretching out your OP X dollars across all the different systems that you need to maintain, maybe it's better to go and buy, right. And white label something. And because we have the direct API integrations, you can keep all your own internal risk systems, your own internal booking systems, your books and records, all that stays the same. But you're able to use our infrastructure to power all of it.
Interviewer
You said that we have the regulatory clarity now. I think everybody agrees that the SEC and CFTC both have the right ideas about the future of this industry. And we have at least two and a half years of that.
Carolyn Pham
Yeah.
Interviewer
How important is the legislative side? Obviously the big conversation right now is the Clarity act itself. Do we need it? Is the regulatory clarity enough? If we don't get it, you know, I guess what's a world with or without the Clarity Act?
Carolyn Pham
Yeah. So it's so important. All of the initiatives that are happening in Congress. I really commend all of the leadership that we have in both houses of Congress, the Senate and the House, as well as the Senate and House Agriculture Committees and Senate Banking and House Financial Services. And like the huge progress that they've made. Those conversations are ongoing. Obviously, I think we're up against a tough calendar, so we'll have to see like how that plays out with just like how many days are there really to get this done. But in the meantime, what I really appreciate is that you just can't waste time. You just said it. We have like what, two years, right, to get this done right. Before somebody else could come along. And so the way that it works is even when you pass the law, the agencies have to go and make rules. So why don't we dual track it? Congress is working on creating a durable framework that is encoded into legislation that is going to be there. Right. But at the same time, the agencies are making great progress. Right. Let's not waste time. They're also putting their rules out there. They're going through that process because it takes about a year to 18 months to actually like propose rules, go through a public notice and comment process and then finalize those rules and then implement them. So I do think it makes a lot of sense to dual track it. I'm really impressed with the leadership of both the CFTC and the sec, with Chairman Selig, with Chairman Atkins. And I think by dual tracking it, we are going to be in a great place by the time we come to the end of this administration. And then the most important aspect is just the adoption. When you have institutional adoption coming in again, we're talking like not just millions, not just billions, not just trillions, maybe quadrillions, right? You can't put that genie back in the bottle, right? And like stablecoins are here to stay. The genius act is law and those rules are being made now. So I think that we actually have reached that tipping point where, you know, blockchain technology is not going away. Stablecoins are not going away. Bitcoin as an asset class is not going away. These things are all here. And you know, we have that, that framework that's necessary around protocol tokens and network tokens, which I've always thought clearly are commodities because they literally are consumables that you have to power the network with burning those tokens just like any kind of energy, right? Like whether it's like, you know, lng, it's oil, it's gas. So all of that makes sense. And I think it's really good that that's there now and then we'll just see. We have a lot of different chains and that's why I think it is important to have that cross chain capability which again our technology provides you.
Interviewer
It's interesting. It's almost like the industry has two and a half years to become too big to fail. There's actually this situation, well, if we don't get legislative clarity and you could get a different administration and executive orders can be rolled back and rulemaking can be changed, the onus becomes on us to actually become so fundamentally important and so big that it's impossible to kill or legislate or regulate away.
Carolyn Pham
Exactly. And it's to be resilience and to be safe and to be compliant. Right. To be able to prove that the industry has grown up, I think that is actually like critically important. But I've said in the past, like, I think I said this maybe last summer, the summer before that Where I said, look, if you have a Bitcoin in every brokerage account, you can't undo that. Right. And it's safe and it's been proven and it has value. And so I think that's the thing that's really important. You know, another example I've given in the past is TikTok. I mean, they actually did pass a law to make Tik Tok illegal.
Interviewer
How's that going?
Carolyn Pham
People still have Tik Tok, right? I mean, you're going to take TikTok away from Americans, like, you're going to pull it from, like, our cold, dead hands. I've said that in the past. So, you know, look at Uber, look at Airbnb. Right? These were. These were modernizations. This was a new way to deliver services. It's a new way to think about how you make reservations to stay someplace. Right. It's a new way to think about how you, you know, call a ride to get to someplace. So these are just evolutions, and I think they're important ones. And, you know, we shouldn't stand in the way of innovation, but, yes, let's be responsible about it.
Interviewer
I think tokenization has been the big topic here, right? At consensus so far that I've heard the most about. How fast do you think this happens? I mean, you were just at the CFTC not so long ago, right?
Carolyn Pham
Yeah.
Interviewer
And now at the SEC saying everything will be on blockchain rails by the end of next year. Right? It's. But then the DCC follows up saying, listen, we have no action from the sec. We're plowing forward with this. I've got to imagine that if all securities are trading on tokenized rails, like, we've. The cat's out of the bag. Correct.
Carolyn Pham
That is not. That's also like the. The investment. I think this is what people don't realize, right? So everyone's like, oh, wow, like, all of a sudden, institutional adoption, 2026. Like, I came out on, like, I think January 2nd or January 3rd, and I said, 2026 is going to be the year of institutional adoption. It's like, Caroline, why are you saying that? Because I've been working on it since 2018, actually.
Interviewer
No.
Carolyn Pham
Yeah. Since I've been working on it since 2018. So all of these major institutions have been investing at this point in time. It's billions of dollars across the industry into this technology. I mean, this is a whole scale upgrade of, you know, financial pipes and plumbing. So, no, that's not going to go away. And it does take a really long time. I mean the, the regulators were also there from the beginning too. So you know, there were a hundred central banks that were working on testing blockchain technology for CBDCs and for cross border payments and remittances and things like that. The, the Monetary Authority of Singapore, the MAS in 2018 is when they launched their first institutional pilots to use blockchain technology. So I mean this is almost 10 years that people have been working on this. So it's not like it came out of nowhere. It's actually the culmination of a lot of really hard work. But that's also why when I did my CFTC Global Markets advisory, which is about having a level playing field for global businesses and global markets, and I created my Digital Asset Markets subcommittee, I made sure that we had both the largest, you know, institutional and traditional finance players from like, you know, the sell side, the buy side. So banks and asset managers, exchanges, service providers, so very well represented with TradFi but also at the crypto natives because I knew eventually you were going to have that convergence between like tradfi and crypto natives and they both brought something really important to the table. And let me tell you, I really commend the leadership of my subcommittee. So Sandy Call from Franklin Templeton was one of my co chairs, Caroline Butler who used to head up BNY Digital Assets Custody. She was my other co chair and it was definitely hurting cats. But we put out some incredible recommendations which have now all been adopted. So my sub, my Digital Asset Market subcommittee put out the first ever US Digital Asset Taxonomy, a lot of which became the foundation for the token taxonomy that the SEC and then the CFTC put out. They also put out the tokenized collateral recommendations which then of course we put out as guidance last year. And then they also had recommendations for how to be technology neutral about blockchain technology in market infrastructure. So you know, it's a lot of long and that was over four years. I mean it took a lot of time to put that in. I'm sure like a lot of like, you know, hard conversations and then you see kind of building on that like. So for example, I was really so gratified to see that DTCC has launched a industry working group of like 50 plus firms to look at tokenization of securities. And these types of industry initiatives are fantastic to come up with the right standards again for everybody to be responsible and to be doing this the right way.
Interviewer
There's this interesting question Paul, I think about what blockchains people will choose and whether they'll go a centralized route and build it themselves or create a walled garden, or whether they'll use existing crypto native decentralized protocols. How do you think that that shakes out? A lot of the announcements of late have certainly been surprisingly to me, we're doing it on Solana, we're doing it on Ethereum, choosing the natives instead of building themselves. But I've got to imagine that some of these are going to want much more control.
Carolyn Pham
I think one thing that is interesting in the crypto industry, and maybe that's all industries, but there's this idea that it's a zero sum. I don't believe in that. I think let a thousand flowers bloom. Everybody's constantly innovating and that's great. You know, you're finding people are putting out like different layer twos. They're putting out, like, just different protocols. So that's why we are agnostic to protocols and to venues. We connect to all of them. Right. So honestly, we deliver the ecosystem no matter where you're at or what you want to reach. And I think that that's the good thing about having competition. It's the good thing about having innovation is like, let everybody put their best, you know, foot forward, and see, like, how does this all play out.
Interviewer
So I gotta be honest, I was a little sad when you left the cftc, because it was like, one of us.
Carolyn Pham
Thank you.
Interviewer
But I think ceiling's one of us too.
Carolyn Pham
Absolutely.
Interviewer
He's like, alone over there. What does that even mean? By the way? How can you be the only. He's like, hello.
Carolyn Pham
It is perfectly legal.
Interviewer
Yeah. No, I'm just saying it's like, crazy what a job he's got. But it's great to see you now over on our side building, because I think it'll be equally as impactful. But thank you for everything you've done.
Carolyn Pham
Absolutely. I feel like it's really important that people, like, if you, if you know it, you. You bring your experience to the government, you serve your country. That was very important to me because, you know, my parents were evacuated from the roof of the US Embassy in Saigon on the last day of the Vietnam War. Came and started, you know, a whole new life in the United States and always raised us to want to give back and serve our country for all the opportunities that we have being here. And so that's where I feel like, if you feel like you can contribute, come and serve your country, come and serve your time in government and then leave.
Interviewer
Yeah, don't stay forever.
Host
What a novel idea.
Carolyn Pham
And then leave and go back and build.
Interviewer
Are you daring to say that octogenarians should not be deciding the future of policy for new technology? It's a crazy, crazy thought. Well, thank you so much. I really appreciate it.
Carolyn Pham
Thank you. It's really great to be on the show. Thanks so much.
Host
This podcast is sponsored by Weeks and was recorded live at Consensus 2026. You can find out more about what they have to offer by clicking on the link down below in the description. Thanks to Weeks for sponsoring.
Date: June 21, 2026
Host: Scott Melker
Guest: Caroline Pham (Former CFTC Commissioner, now leading MoonPay Institutional)
Location: Recorded live at Consensus 2026
This episode dives deep into the rapid institutional adoption of crypto, with a special focus on MoonPay's foray into institutional services. Caroline Pham, a pivotal figure in US crypto regulation and now an industry leader, discusses the convergence of TradFi (Traditional Finance) and DeFi (Decentralized Finance), the regulatory environment, and how innovation in digital assets is restructuring the whole financial ecosystem. Scott and Caroline also explore MoonPay's "operating system for value," the myths around KYC in DeFi, the importance of robust infrastructure, and why the next two and a half years are critical for crypto to become "too big to fail."
This episode encapsulates a maturing industry entering a critical phase where scalable, compliant infrastructure and regulatory certainty meet soaring institutional interest. The next two and a half years are pivotal for crypto’s irreversible integration into global finance. Caroline Pham offers both a visionary’s clarity and a regulator’s insight, making this a must-listen (or read) for anyone following the institutionalization of crypto.