January 4, 2021

Via Federal E-Rulemaking Portal and Via Email: frc@fincen.gov
Policy Division
Financial Crimes Enforcement Network
P.O. Box 39
Vienna, VA 22183

To Whom It May Concern:

CMT Digital Holdings LLC (“CMT Digital”) is a subsidiary of the CMT Group[1], which was founded in 1997 by Scott Casto and Jan-Dirk Lueders. The CMT Group is a proprietary trading and investments firm that has operated in 20 countries across 5 continents and has been regulated in numerous international jurisdictions.[2] Approximately 75% of the CMT Group’s activities are in traditional finance, including proprietary trading in global equities and commodities markets as…

On April 7, 2020, we launched the Chicago Defi Alliance (the “CDA”) alongside Volt Capital, Jump Capital, and DRW. The CDA’s mission is to provide support and mentorship to startups in the DeFi space in areas including trading, markets, and regulation. We worked tirelessly over the last month to structure the CDA and review the torrent of applications submitted by promising DeFi projects.

After reviewing more than 100 applications, we are thrilled to announce the CDA’s initial cohort of DeFi startups: 0x, dydx, Kyber Network, IDEX, opyn, Set Protocol, and Synthetix. …

We are excited to announce our participation in FalconX’s $17M round of financing. We are joined by notable investors including Accel, Accomplice VC, Avon Ventures, Coinbase Ventures, Fenbushi Capital, Flybridge Capital, and Lightspeed Venture Partners. FalconX is a digital asset trading platform that provides clients with fast, secure, and reliable execution using data science to eliminate slippage and hidden fees. The Company was founded by Raghu Yarlagadda and Prabhakar Reddy in 2018. Raghu, an engineer and entrepreneur by background, held several product leadership roles prior to FalconX, including at Google, where he was instrumental in scaling Chromebooks to a multi-billion…

Bakkt In It

On September 22, bitcoin futures began trading at Bakkt, an exchange and digital asset custodian backed by Intercontinental Exchange (ICE). Not only is CMTD an investor in Bakkt, but the firm had the pleasure of being involved in the first trade on the exchange at 8:02 p.m. ET, at a price of $10,115.

It’s not the only good piece of exchange news for crypto assets, as just two days before Bakkt opened for trading the CME Group confirmed what had been previously reported in The Block: options on the exchange group’s bitcoin futures are coming in Q1…

At CMT, we’ve worked in a variety of different asset classes through our history, but our company’s biggest asset by far is our people. We’re a relatively small firm, and thus our success has been predicated on finding talented people who make an impact by themselves and an even greater impact when combined with a strong team.

We are taking an opportunity to highlight the people who have made, and continue to make, CMT what it is today. We’ll be spotlighting key members of our team over the coming months, and we’ll start today with one of our co-founders, Jan-Dirk…

Colleen Sullivan is CEO and Partner at CMT Digital, a division of the CMT Group. CMT Digital is focused on crypto asset trading, blockchain technology investments, and legal/policy engagement in the crypto asset/blockchain technology industry.

Beginning in late 2013, the firm immersed itself in understanding the bitcoin protocol and took an active role in shaping the regulatory landscape for crypto assets. Accustomed to operating in highly regulated markets, CMT Digital participates in global discussions on regulation, policy, and best practices in the crypto asset and blockchain space.

As an authority in the crypto asset and blockchain space, Colleen is active…

By Brad Koeppen, Head of Crypto Trading and President of Business Development at CMT Digital

This past Friday, I had the opportunity to speak at UChicago’s Booth School of Business on a panel entitled, “VC perspectives on blockchain/crypto.” This was a unique and interesting opportunity because of the event’s focus on crypto, which has become an internationally trending topic.

If you’re wondering how I got here, I’ll share a quick overview of my career: I graduated from the University of Chicago about fifteen years ago, and, like many finance professionals looking to make their mark, I traded on the floor…