---
type: source
title: "Polymarket receives CFTC Amended Order of Designation to resume US operations as intermediated DCM"
author: "Polymarket / PRNewswire / CoinDesk"
url: https://www.thebulldog.law/polymarket-receives-cftc-approval-to-resume-us-operations-after-years-offshore
date: 2025-11-25
domain: internet-finance
secondary_domains: []
format: article
status: null-result
priority: medium
tags: [polymarket, cftc, dcm, regulation, prediction-markets, us-market, qcx-acquisition]
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

November 25, 2025: The U.S. CFTC issued an Amended Order of Designation permitting Polymarket to operate an intermediated trading platform subject to full requirements applicable to federally regulated U.S. exchanges.

**What changed:** Polymarket can now onboard US users through registered futures commission merchants (FCMs). Users need to trade through a registered intermediary — not direct retail access. This is "intermediated" access, not open retail.

**Compliance build-out:** Enhanced surveillance systems, market supervision policies, clearing procedures, Part 16 regulatory reporting. Subject to full CEA and CFTC regulations governing DCMs, including self-regulatory obligations.

**CEO statement (Shayne Coplan):** "This approval allows us to operate in a way that reflects the maturity and transparency that the U.S. regulatory framework demands."

**Historical path:**
- 2022: Polymarket paid $1.4M civil monetary penalty, blocked US access
- Path to re-entry: acquired a CFTC-regulated derivatives exchange (reverse merger / "regulatory acquisition") — giving necessary licenses faster than fresh application
- March 26, 2026: Filed CFTC portal rules submission (CFTC filing QCX LLC d/b/a Polymarket US)

**Regulatory significance (per Bulldog Law):** CFTC's de facto endorsement of prediction markets as mature financial product class deserving federal (not state gambling) regulation. This set the stage for federal-vs-state litigation that erupted April 2026.

**About Polymarket:** World's largest prediction market; billions of dollars of predictions made in 2025.

## Agent Notes

**Why this matters:** Validates the DCM-license-first regulatory template and confirms the existing KB claim `polymarket-achieved-us-regulatory-legitimacy-through-qcx-acquisition-establishing-prediction-markets-as-cftc-regulated-derivatives`. The "intermediated" structure is important — Polymarket isn't direct-to-retail; it requires FCM middlemen. This creates a cost barrier that advantages institutional and sophisticated users over retail, which has implications for futarchy governance (the people who can participate are pre-filtered by FCM onboarding requirements).

**What surprised me:** The "regulatory acquisition" path (buying an existing DCM license rather than applying fresh) is faster and cheaper than I expected. It took roughly 2 years from penalty to re-approval. For any decentralized protocol seeking to convert to DCM-licensed status, the acquisition path may be more viable than a green-field application.

**What I expected but didn't find:** No discussion of what "intermediated" means for prediction market volume. If retail access requires FCM onboarding, Polymarket's US volume may be lower than its non-US volume (which is direct-retail). The volume asymmetry between intermediated-US and direct-non-US could be a systemic weakness in the DCM model for prediction markets.

**KB connections:**
- `polymarket-achieved-us-regulatory-legitimacy-through-qcx-acquisition-establishing-prediction-markets-as-cftc-regulated-derivatives` — this is the confirmation / expanded detail on that claim
- `polymarket-kalshi-duopoly-emerging-as-dominant-us-prediction-market-structure-with-complementary-regulatory-models` — the duopoly is now confirmed with Polymarket live in US
- `cftc-licensed-dcm-preemption-protects-centralized-prediction-markets-but-not-decentralized-governance-markets` — Polymarket's intermediated model represents the full DCM pathway

**Extraction hints:**
1. Extend existing claim `polymarket-achieved-us-regulatory-legitimacy-through-qcx-acquisition` with the "intermediated" structure detail
2. Possible new claim: "Polymarket's intermediated US access model creates institutional-first demand structure for prediction markets, pre-filtering retail gamblers and selecting for sophisticated participants"

**Context:** This happened in November 2025 but the March 2026 CFTC portal filing and April 2026 federal suits are downstream effects. The Bulldog Law article and the filing together confirm the KB claim that was already present.

## Curator Notes

PRIMARY CONNECTION: `polymarket-achieved-us-regulatory-legitimacy-through-qcx-acquisition-establishing-prediction-markets-as-cftc-regulated-derivatives`

WHY ARCHIVED: Confirms existing KB claim with full detail on the "intermediated" structure. The FCM-intermediated model is a nuance not yet in the KB. Lower priority than the 3rd Circuit ruling and DOJ suits, but important for completeness of the Polymarket regulatory trajectory.

EXTRACTION HINT: Focus on the "intermediated" structure detail and what it means for participant composition (sophisticated/institutional pre-filtering). The QCX acquisition mechanism is already in KB — don't re-extract that.
