The talks land just weeks after MoonPay secured a Limited Purpose Trust Charter from the New York Department of Financial Services (NYDFS), a regulatory milestone that clears the firm to hold client funds as a qualified custodian. The company further bolstered its compliance standing Wednesday by appointing former Commodity Futures Trading Commission Acting Chair Caroline Pham as chief legal officer.
New York-based MoonPay is nearing the completion of the fundraising, according to Bloomberg, citing people familiar with the matter. The $5 billion valuation would represent a significant premium over the $3.4 billion mark the company set during its last capital raise in 2021. Neither ICE nor MoonPay provided comment on the investment negotiations.
Institutional Convergence
The negotiations come as venture capitalists and institutional giants rush back into the sector. Crypto and blockchain companies have raised nearly $19 billion year-to-date in 2025, the highest annual total since 2022, according to PitchBook data.
An investment would mark ICE’s second major foray into the space recently. The exchange operator agreed in October to invest up to $2 billion in prediction market platform Polymarket, leveraging blockchain technology to settle bets.
MoonPay has simultaneously expanded its product suite to match this institutional demand. The firm completed a string of acquisitions this year, including fintech startup Meso, and launched a stablecoin division following the passage of U.S. stablecoin legislation in July.
Regulatory Fortification
But expanding into high-stakes settlement layers required a new legal shield. The sequence of events signals MoonPay is moving beyond its roots as a consumer payment gateway to position itself as a regulated infrastructure provider for institutional capital.
The NYDFS Trust Charter, granted on Nov. 25, places the firm in a select tier of crypto entities, including Coinbase and Fidelity Digital Assets, authorized to custody digital assets under New York banking law.
“Receiving our New York Trust Charter reflects our commitment to meeting the highest standards of compliance,” MoonPay CEO Ivan Soto-Wright said in a statement following the approval.
The Regulator-to-Executive Pipeline
To enforce that playbook, the firm has turned to one of Washington’s most prominent crypto regulators.
Caroline Pham brings extensive federal experience to the private sector. During her tenure leading the CFTC, she advocated for integrating digital assets into existing derivatives frameworks.
Specific policy shifts under her leadership included launching a pilot program for tokenized collateral, utilizing assets such as Bitcoin and Ether, and approving spot crypto trading on regulated platforms.
Pham takes the dual role of chief legal and administrative officer at a critical juncture, tasked with navigating a fragmented global map of 180 jurisdictions. Her move to the private sector follows the expected confirmation of Michael Selig as her successor at the agency.
Chain Street’s Take
This is a calculated siege on the traditional financial infrastructure stack. MoonPay secured the “gold standard” New York license in November, hired the federal regulator who wrote the pilot programs in December, and is now reportedly bringing the owner of the NYSE onto its cap table.
This is no longer a startup trying to disrupt banks but an infrastructure play designing itself to be the bank for the next wave of tokenized assets. The $5 billion valuation is a bet that custody and settlement, not just trading, will be the primary revenue drivers of the next cycle.
If ICE closes this deal, the gap between Wall Street and crypto plumbing doesn’t just narrow; it closes.
