$90 trillion in estimated offshore perpetual futures volume in 2025, by Kalshi's measure, is the number anchoring a new comment letter from five former senior SEC and CFTC officials calling on Washington to price its regulation closer to actual risk. Two years prior, Kalshi puts that same market at roughly $28 trillion; the implied multiple is about 3.2x over the period, which the letter's signatories attribute to regulatory arbitrage rather than any genuine preference for offshore venues.
| Metric | Kalshi estimate |
|---|---|
| Offshore perps volume, 2025 | $90 trillion |
| Offshore perps volume, ~two years prior | ~$28 trillion |
| Growth multiple | ~3.2x |
The five signatories are former CFTC Chairman Chris Giancarlo, former CFTC Commissioners Brian Quintenz and Sharon Brown-Hruska, former SEC Commissioner Steven Wallman, and former SEC Chief Economist Chester Spatt. Their comment responds to a joint June request from both agencies for public input on how swaps, security-based swaps, and novel or emerging products should be classified and where CFTC and SEC jurisdiction should divide.
The core position: similar risks should face similar regulatory treatment. Layering redundant compliance costs across overlapping rules does not reduce risk; it moves trading. The bipartisan makeup carries weight at a moment when neither the SEC nor the CFTC has bipartisan representation. The signatories frame these as structurally nonpartisan questions with long precedent across party lines.
Kalshi, the prediction market platform that began offering crypto perps earlier this year, sponsored the letter by retaining law firm Bellementis PLLC to assist with drafting. The signatories say they received no compensation and that Kalshi had no influence over the letter's contents.
Giancarlo told the newsletter Crypto in America that calibrating federal regulation to actual risk rather than maximum burden is the condition for bringing that offshore liquidity home, and that each year of delay compounds the structural difficulty of doing so. President Donald Trump said this month that CFTC Chairman Michael Selig is working to bring Hyperliquid, a popular offshore perps platform, into the United States.
Custody rules and Reg Crypto
Two parallel SEC tracks are moving. The agency sent a planned rewrite of its custody rules for investment advisers and investment companies to the White House Office of Information and Regulatory Affairs last week. The question the crypto industry has sought clarity on for years: how SEC-regulated firms can qualify as custodians for digital assets under securities law. The text is not yet public, so which firms might qualify and on what terms remains open.
Three years ago, then-Chairman Gary Gensler proposed a "safeguarding" rule that would have stretched adviser custody requirements to virtually all client assets, including crypto. The Atkins SEC scrapped that proposal last year.
Separately, the SEC's Reg Crypto proposal, which would establish new rules for certain crypto asset offerings, is now in the Federal Register and open for public comment through October 20.