Cryptocurrencies as commodities

The US experience

In September 2025, the Commodity Futures Trading Commission (CFTC) commenced discussions on the use of tokenized assets and stablecoins as collateral in derivatives markets.

Derivatives can include oil futures, Apple stock options, etc. Owning a derivative means having the right to enter into an agreement to buy or sell oil or stocks at a certain price in the future. Such transactions involve risk and therefore require collateral. The CFTC is discussing:

1) What pilot projects involving the use of¹ tokens as collateral can be implemented.

2) What rules governing collateral need to be updated so that tokens are recognized as an acceptable form of collateral.

3) What steps companies are already taking to introduce tokenized collateral for derivative transactions.

The criteria for the acceptability of such collateral have been established. Following consultations, measures have been defined for the official recognition of stablecoins and tokens as acceptable collateral for settlements and² derivatives trading.

The implementation of this initiative in the market could potentially significantly change the crypto economy: at the end of 2024, various assets worth $0.9 trillion were used as collateral³ for financial transactions, and their tokenization could increase the crypto economy market by a third ($3.7 trillion as of October 10,⁴ 2025). A positive resolution of this issue could also diversify the collateral market through the tokenization of tangible assets and the “splitting” of ownership rights to them.

Also in September 2025, the CFTC and the Securities and Exchange Commission announced the development of a procedure for admitting crypto assets to exchange trading on the spot market (a market where transactions are conducted almost immediately, for example, the seller transfers the cryptocurrency and receives fiat currency at the time of the⁵ transaction).

The regulators confirmed that the current rules already allow for the trading of cryptocurrencies (such as Bitcoin and Ethereum) as commodities, subject to investor protection and trading transparency requirements. In addition, regulators have identified practical issues that market participants need to work on: how margin requirements are set and maintained, how clearing and settlement are organized, and how data exchange between platforms is established⁶ (to monitor underlying markets and prevent manipulation).

The implementation of the initiative will affect crypto exchanges around the world, as the CFTC's jurisdiction will now cover not only cryptocurrencies themselves, but also the exchanges on which they are traded. The CFTC has already taken the initiative to regulate the right of foreign crypto exchanges to provide services to US residents (this right has been in effect for traditional commodity exchanges since the late 1990s). Foreign crypto exchanges will be able to serve US customers if their jurisdiction⁷ meets comparable regulatory standards.

Russia’s experience

There are currently no decisions in Russia similar to the initiatives in the U.S., but in⁸ May 2025, the Bank of Russia allowed financial institutions to offer qualified investors instruments with returns dependent on cryptocurrency prices (derivatives, securities, CFAs) with a conservative risk assessment (full capital coverage and limits of 1% of capital, as discussed in Monitoring No. 8 (20)). At the same time, the Central Bank emphasizes that it does not support direct investments in cryptocurrencies, considering them to be highrisk.

In the future, the Russian financial market will also consider the possibility of using⁹ tokenized assets (e.g., CFAs ) as collateral, given their potential to speed up and simplify settlements.

From the monitoring issue No. 9 (21), September 2025. Download the full issue (PDF) · issue page at the Gaidar Institute