Kalshi

Kalshi is a New York exchange for event contracts, operated through KalshiEX LLC, that the Commodity Futures Trading Commission designated as a contract market on November 3, 2020. Tarek Mansour and Luana Lopes Lara founded the company, which Y Combinator lists in its Winter 2019 batch.¹ Form D filings with the Securities and Exchange Commission report about 2.47 billion dollars sold in seven offerings between 2020 and 2026, and the sports and election contracts have drawn state enforcement, private class actions, a criminal information in Arizona and rulings from three federal circuits.

Origins

Kalshi's own account states that Mansour and Lopes Lara founded the company in 2018 after exploring event-driven hedging and investment products at Goldman Sachs and Citadel, and that the founders spent the first years obtaining federal registration before launching a product.²³ The Y Combinator profile gives 2019 as the founding year and calls the company the "1st federally regulated exchange where people can trade on events."¹ Kalshi Inc., a Delaware corporation, filed its first Form D on March 19, 2020, reporting a first sale on March 4, 2020 of 6,094,999 dollars to 28 investors and entering 2018 as the year of incorporation.⁴ The 2023 petition to modify the designation order, filed for KalshiEX LLC over the signature of Mansour as chief executive and transmitted by Elie Mishory as chief regulatory officer, gives December 10, 2019 as the date of formation.⁵

The CFTC announced on November 4, 2020 that it had issued an order of designation to KalshiEX LLC, "granting it status as a designated contract market (DCM)," and described the company as located in San Francisco.⁶ The order, dated November 3, 2020, recites submissions from December 30, 2019 through September 17, 2020.⁷ As first issued it provided that Kalshi "may not permit any futures commission merchant to intermediate any transactions or carry accounts for customers" until the order was amended. Kalshi requested removal of that provision in submissions from November 27, 2023 through December 9, 2024, and the Commission superseded the order on January 17, 2025.⁸ The CFTC release of 2020 does not use the word "first" for the designation. Kalshi's February 2021 announcement called the exchange "the first federally regulated exchange dedicated to trading on event outcomes" and "one of just 16 DCMs in the U.S."²

On August 29, 2024 the CFTC announced that it had granted Kalshi Klear LLC registration as a derivatives clearing organization.⁹

Funding

The Form D for the March 2020 sale is the earliest of seven filed by Kalshi Inc.⁴ The second reports a first sale on December 18, 2020 of 29,999,999 dollars to 10 investors, was filed February 23, 2021, and lists Mansour, Lopes Lara and Alfred Lin as directors.¹⁰ On February 17, 2021 the company announced a 30 million dollar Series A led by Sequoia Capital, with participation from Charles Schwab, chairman of Charles Schwab Corporation, Henry Kravis, co-chairman and co-chief executive of KKR, SV Angel and previous investors including Neo and YC Continuity. The release quotes Lin as "partner at Sequoia and Kalshi board member."² Ali Partovi of Neo wrote on February 19, 2021 that his fund "doubled down in this round and are Kalshi's largest investor after Sequoia."¹¹

A Form D with a first sale on November 3, 2021 for 69,999,989 dollars to 14 investors was filed on November 6, 2025.¹² A market data aggregator labels the round a Series B at a 749.83 million dollar valuation.¹³ On November 16, 2021 the company announced that Brian Quintenz, a former CFTC commissioner, had joined its board.¹⁴

On June 25, 2025 Kalshi announced a 185 million dollar Series C at a 2 billion dollar valuation led by Paradigm (investment firm). Mansour listed Sequoia Capital, Multicoin Capital, Peng Zhao (chief executive of Citadel Securities), Neo and Bond Capital as participants, and The Block reported that the round brought total funding to 415 million dollars and that Kalshi had also taken "tens of millions" in short-term loans from venture firms the year before, citing TechCrunch.¹⁵ Decrypt reported, citing PitchBook, a 787 million dollar post-money valuation in late 2024 around the time of a 50 million dollar private round.¹⁵ The Form D with a first sale of June 24, 2025 reports 124,999,957 dollars sold to 14 investors.¹⁶

On October 10, 2025 Kalshi announced a 300 million dollar Series D at a 5 billion dollar valuation, "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm," with Coinbase Ventures, General Catalyst, Spark Capital and CapitalG as additional backers.¹⁷ The Form D with a first sale of October 8, 2025 reports 294,500,203 dollars sold of a 389,999,943 dollar offering to 20 investors and lists Mansour, Lopes Lara, Lin, Michael Seibel and Matt Huang as directors.¹⁸ A Fortune report reproduced on Yahoo Finance describes Huang as the Paradigm cofounder and managing partner who sits on Kalshi's board.¹⁹

On November 20, 2025 The Block, relaying TechCrunch, reported a 1 billion dollar round at an 11 billion dollar valuation led by Sequoia and CapitalG, with Andreessen Horowitz, Paradigm, Anthos Capital and Neo participating. Kalshi's announcement of December 2, 2025 describes a 1 billion dollar Series E at 11 billion dollars "led by Paradigm, with participation from Sequoia, Andreessen Horowitz, Meritech Capital, IVP, ARK Invest, Anthos Capital, CapitalG, and Y Combinator."²⁰ The Form D with a first sale of November 19, 2025 reports 820,819,303 dollars sold of a 999,996,557 dollar offering to 31 investors.²¹

On May 7, 2026 Kalshi announced a 1 billion dollar Series F at a 22 billion dollar valuation, led by Coatue Management with participation from Sequoia, Andreessen Horowitz, IVP, Paradigm, Morgan Stanley and ARK Invest, the company's third round in seven months.²² The Form D with a first sale of April 3, 2026 reports 1,120,010,122 dollars sold of a 1,499,997,894 dollar offering to 71 investors.²³

Two feeder vehicles filed their own Form Ds. Soma Capital Kalshi SPV, LP reports a first sale on January 14, 2022 of 2.5 million dollars to one investor, was filed April 13, 2022, and lists Aneel Ranadive as a director and Soma Capital Management as promoter. SC Kalshi SPV II LLC reports a first sale on April 17, 2025, was filed May 1, 2025, and lists Zanbato Capital LLC and Zanbato Advisors LLC as executive officers and Soma Capital Management as promoter.²⁴ Further Form Ds in 2026 name Kalshi in vehicle titles, including HII Kalshi, Latitude Ventures Kalshi, Dominari Master SPV LLC Series XXIX Kalshi and DMM Kalshi I, LLC.²⁵

Securities Filings

Rule 503 of Regulation D requires a notice of sales on Form D no later than 15 calendar days after the first sale of securities in the offering.²⁶ The seven Kalshi Inc. filings, by date of first sale and date filed, are: March 4, 2020 and March 19, 2020 (15 days); December 18, 2020 and February 23, 2021 (67 days); November 3, 2021 and November 6, 2025 (four years and three days); June 24, 2025 and October 30, 2025 (128 days); October 8, 2025 and October 23, 2025 (15 days); November 19, 2025 and December 4, 2025 (15 days); April 3, 2026 and August 25, 2026 (144 days).^{4101216182123}

The filing made on November 6, 2025 for the November 2021 sale lists as related persons Mansour and Lopes Lara as executive officers and directors and Lin, Seibel and Huang as directors, the same five persons listed on the filings of October 23, October 30 and December 4, 2025 and August 25, 2026.¹² None of the seven Kalshi Inc. filings, dated March 19, 2020 through August 25, 2026, lists Quintenz as a related person.^{4101216182123}

Litigation and Regulation

On June 12, 2023 Kalshi self-certified a contract on which chamber of Congress a party would control. On June 23 the CFTC opened a 90-day review, asked Kalshi to suspend listing during the review, and opened a public comment period. Two of the five commissioners dissented from the decision to open the review. On September 22, 2023, at the close of the review, the CFTC issued an order prohibiting the listing, with Commissioner Mersinger dissenting and Commissioner Caroline Pham abstaining, according to the court's account of the Commission's statements.²⁷

Kalshi sued in the District of Columbia. In a memorandum opinion of September 12, 2024, Judge Jia M. Cobb granted summary judgment to Kalshi and held that the contracts "do not involve activity that is unlawful under any Federal or State law, nor do they involve gaming."²⁷ The CFTC appealed to the D.C. Circuit as No. 24-5205. On May 5, 2025, after a 3 to 0 commission vote, the agency moved to dismiss the appeal voluntarily, each side bearing its own costs.²⁸ Protos reported that Yaakov Roth of Jones Day argued the appeal for Kalshi in January 2025 and joined the Justice Department in February 2025.²⁹

Sports contracts followed in January 2025. The Third Circuit opinion in the New Jersey case records that a competitor began offering sports event contracts in December 2024, Kalshi did so a month later, and New Jersey sent a cease-and-desist letter two months after that.³⁰ In Nevada, a federal judge, Andrew Gordon, granted Kalshi a preliminary injunction in April 2025 against the Nevada Gaming Control Board, dissolved it on November 24, 2025, and in December refused a stay.³¹ The Ninth Circuit opinion of August 28, 2026 in KalshiEX, LLC v. Assad (No. 25-7516), written by Judge Ryan Nelson with a concurrence by Judge Kenneth Lee, affirmed the dissolution as to sports contracts and remanded for the district court to consider Nevada's challenges to the election contracts.³²

In New Jersey, the Third Circuit decided KalshiEX, LLC v. Flaherty (No. 25-1922, 172 F.4th 220) on April 6, 2026, after argument on September 10, 2025, affirming the preliminary injunction granted by District Judge Edward Kiel. Judge David Porter wrote the opinion, joined by Chief Judge Michael Chagares. Judge Jane Roth dissented, writing that "if it looks like gambling, talks like gambling, and calls itself gambling, it's gambling."³⁰ New Jersey filed a petition for certiorari on September 2, 2026, docketed as No. 26-299 on September 8, and the Supreme Court extended the response deadline to November 9, 2026.³³

In Maryland, Judge Adam Abelson denied a preliminary injunction on August 1, 2025. Kalshi's appeal to the Fourth Circuit was docketed on August 6, 2025 as No. 25-1892, and on August 12 Maryland gave written assurance that it would forgo enforcement against Kalshi pending the outcome. The Ninth Circuit's opinion of August 28, 2026 records the Fourth Circuit appeal as pending.³⁴

In Ohio, the Ohio Casino Control Commission sent cease-and-desist letters to prediction markets in 2025, and the Southern District of Ohio (District Judge Sarah Morrison) denied Kalshi a preliminary injunction on March 9, 2026. In Tennessee, Judge Aleta Trauger had granted one on February 19, 2026. On September 25, 2026 a Sixth Circuit panel of Judges Clay, Gibbons and Bloomekatz, in an opinion by Judge Julia Gibbons after argument on July 30, 2026, affirmed the Ohio denial and vacated the Tennessee injunction, holding that Kalshi had not shown that sports event contracts are swaps and, alternatively, that the Commodity Exchange Act neither expressly nor impliedly preempts the states' gambling laws.³⁵ Briefs for Kalshi were signed by Neal Katyal and Joshua Sterling of Milbank LLP. The opinion lists Elizabeth Prelogar of Cooley LLP and CFTC counsel Henry Dickman and M. Jordan Minot among counsel for amici, and cites the amicus brief of the Coalition for Prediction Markets "in support of Kalshi."³⁵ Ohio's commission dated cease-and-desist notices October 2, 2026 to ten operators including Coinbase, Polymarket and Robinhood and did not include Kalshi; Covers reported that Ohio fined Kalshi 5 million dollars in April.³⁶

On January 20, 2026 Suffolk Superior Court Judge Christopher Barry-Smith ruled in Commonwealth v. KalshiEX LLC (No. 2584CV02525) that Kalshi could not offer sports wagering in Massachusetts without a license and said he would issue a preliminary injunction. Attorney General Andrea Campbell called the ruling "a major step toward fortifying Massachusetts' gambling laws."³⁷ The matter is before the Supreme Judicial Court as No. SJC-13906 (Appeals Court No. 2026-P-244), where the CFTC filed an amicus brief on April 24, 2026 in support of Kalshi and of reversal.³⁸

On March 12, 2026 Kalshi sued Arizona officials in federal court. Five days later Attorney General Kris Mayes filed twenty misdemeanor counts against KalshiEX LLC in Maricopa County Superior Court, sixteen for unlawful betting and four for election wagering, covering sports and political contracts.³⁹ Morgan Lewis describes the filing as the first criminal prosecution of a CFTC-registered prediction market operator. The Ninth Circuit's August 2026 opinion records that the District of Arizona granted Kalshi a preliminary injunction against enforcement of Arizona's gambling laws on May 5, 2026 (appeal No. 26-2978) and that the Southern District of New York denied one on July 13, 2026.³²

Two California tribes, the Blue Lake Rancheria and the Chicken Ranch Rancheria of Me-Wuk Indians, sued Kalshi and Robinhood in the Northern District of California. Judge Jacqueline Scott Corley denied a preliminary injunction. On September 16, 2026 the Ninth Circuit held in Blue Lake Rancheria v. Kalshi, Inc., No. 25-7504, that the tribes were likely to succeed on their claim that the sports contracts violate the Indian Gaming Regulatory Act, and returned the case to Judge Corley on the remaining injunction factors.⁴⁰

A putative class action filed January 8, 2026 in the Northern District of Illinois alleges that the sports contracts are unlicensed wagering. A federal judge transferred it to New York in April 2026, where similar suits are consolidated, and a Massachusetts bettor filed a class action in April 2026.⁴¹ On June 27, 2026 Kalshi sued Illinois officials in federal court over SB 3019, scheduled to take effect July 1, 2026.⁴¹

The CFTC under Chairman Michael Selig has argued for its own exclusive jurisdiction in the state cases. Morgan Lewis records a CFTC amicus brief in the Ninth Circuit on February 17, 2026.³⁹ Protos reported that Roth's name appears on federal complaints filed by the Justice Department against Illinois, Arizona and Connecticut.²⁹ A law-firm summary records that the CFTC sent a proposed rule to the White House on September 28, 2026 that would define prediction market event contracts as swaps.⁴² Selig was confirmed by the Senate on December 18, 2025 and sworn in on December 22.⁴³ The CFTC's Innovation Advisory Committee, announced February 12, 2026 with 35 members, lists Mansour and Shayne Coplan of Polymarket among them.⁴⁴

Quintenz

Brian Quintenz served as a CFTC commissioner from August 2017 to September 2021.⁴⁵ Kalshi's post of November 16, 2021 announcing that he had joined its board states: "It's been an honor to engage with Brian from the very early days of Kalshi when we were just starting the process of becoming a regulated exchange," and says he "authored a tour de force analysis of prediction markets and their treatment within the CFTC's regulatory ecosystem."¹⁴ The Block reported that shortly after leaving the commission Quintenz also joined the advisory board of Andreessen Horowitz; he later held the title head of crypto policy there.¹⁴⁴⁶

Donald Trump's nomination of Quintenz to chair the CFTC was first reported by Bloomberg on the night of February 11, 2025.⁴⁷ His ethics agreement, submitted to the Office of Government Ethics on May 21, 2025, pledged to resign from the boards of Kalshi, AH Capital Management (Andreessen Horowitz) and Next Level Derivatives, to divest equity within 90 days of confirmation, and to recuse from matters involving Kalshi for one year and Andreessen Horowitz for two.⁴⁸ The Senate Agriculture Committee held his hearing on June 11, 2025.⁴⁶ The committee's scheduled July 28, 2025 vote did not take place; Chairman John Boozman told Bloomberg the White House had asked him to delay it.⁴⁶ The newsletter Closing Line reported that a Quintenz associate had emailed current CFTC officials in what appeared to be a request for non-public information about Kalshi's competitors, and Protos reported that FOIA documents showed his incoming staff seeking CFTC information about Kalshi's competitors and about the Winklevoss twins' lobbying against him.⁴⁶⁴⁹

Tyler Winklevoss and Cameron Winklevoss of Gemini urged Trump in July 2025 to reconsider the pick, and in September 2025 Quintenz released private texts from Tyler Winklevoss. Politico reported late on September 30, 2025 that the White House had withdrawn the nomination, and Decrypt wrote that crypto lobbying, the dispute with the Winklevoss twins and opposition to Quintenz's Kalshi links "may have played a role."⁵⁰ Quintenz joined the board of SUI Group Holdings on January 5, 2026, and The Block noted that his public LinkedIn profile still listed a Kalshi board seat.⁵¹ On July 9, 2026 he joined the Coalition for Prediction Markets as a senior advisor, and Global Gaming Insider wrote that he "currently maintains a position on Kalshi's Board of Directors."⁵²

Political Ties

On January 13, 2025 Mansour announced on Kalshi's news site that Donald Trump Jr. had joined as a strategic advisor. The post quotes Trump Jr.: "On Election night at Mar-a-Lago, while biased outlets called the race a coin toss, my family and close friends used the prediction market Kalshi to know we won hours ahead of the fake news media. I immediately knew I had to contribute to their mission."⁵³ Mansour told CNBC that the company is "not a political company in any way, shape or form."⁵⁴ On August 26, 2025 Trump Jr.'s firm 1789 Capital was reported to be investing "double-digit millions" in Polymarket, with Trump Jr. joining its advisory board.⁵⁵

In April 2026 Kalshi announced Stephanie Cutter, co-founder of Precision Strategies and a former deputy campaign manager for Barack Obama's 2012 campaign, as a policy advisor.⁵⁶ The Revolving Door Project, writing in the American Prospect, listed Cutter, Curtis Doster (formerly deputy chief of staff in the Biden White House, now an outside lobbyist) and John Bivona among former Democratic officials working for Kalshi, alongside Sean Patrick Maloney as head of the Coalition for Prediction Markets.⁵⁷

The Coalition for Prediction Markets was formed in December 2025 with Kalshi's Head of Corporate Development Sara Slane and Crypto.com's Matt David as executive board members. It named Maloney president and Patrick McHenry its first senior advisor on January 13, 2026, and its members include Kalshi, Crypto.com, Coinbase, Robinhood and Underdog.⁵² Prelogar of Cooley filed a Sixth Circuit amicus brief in Kalshi v. Orgel on behalf of the coalition, according to the Revolving Door Project.⁵⁷

On September 23, 2026 Democratic members of the Senate Banking Committee, led by Ranking Member Elizabeth Warren, wrote to Chairman Tim Scott requesting a public hearing on prediction markets. The letter states that, according to reports, Scott planned a roundtable that week with only Republican members, that "executives from Kalshi will be in attendance," and that Congress should examine prediction markets in a public hearing, "not behind closed doors in a Republican-only, industry-friendly roundtable." It cites a Punchbowl News report of September 18, 2026 and states that in December 2025 individuals traded nearly 12 billion dollars on Kalshi and Polymarket, citing the New York Times. The other signers were Catherine Cortez Masto, Jack Reed, Mark Warner, Chris Van Hollen, Tina Smith, Raphael Warnock, Andy Kim, Ruben Gallego, Lisa Blunt Rochester and Angela Alsobrooks.⁵⁸

Political Contributions

Federal Election Commission Schedule A data list contributions from Mansour, Lopes Lara and Mishory to both parties. Totals below exclude memo and transfer duplicates of joint fundraising committees and ActBlue conduit rows, and party is the committee's registered party or the party of its candidate or sponsor.⁵⁹

Mansour's contributions from 2020 through July 2026 total about 747,000 dollars: about 466,000 dollars to Republican candidates and committees, about 278,000 dollars to Democratic ones and 3,300 dollars to the Kennedy presidential committee. He gave 25 dollars through ActBlue to a Biden fund on August 28, 2020. In 2022 he gave 2,900 dollars each to Booker Victory Fund and Gillibrand for Senate on April 8, to Stabenow for US Senate on June 28 (two entries), and to Friends of John Thune on July 12, gave Boozman for Arkansas 5,800 dollars on July 23 (the record notes later refunds), and gave 5,800 dollars to the Maloney Victory Fund on October 27, 2022. On November 13, 2023 he gave 3,300 dollars to Team Kennedy, the Kennedy presidential committee. In 2025 he gave Ken Paxton for Senate 7,000 dollars on June 13, Lummis for Wyoming 5,000 dollars on June 23, the Cotton Majority Committee 5,000 dollars each on August 29 and September 25, the Sheehy Victory Committee 3,300 dollars on September 25, the Whatley Victory Committee 5,000 dollars on September 29 and Angie Craig for Minnesota 7,000 dollars across July 8 and September 2, and gave the California Democratic Party 9,800 dollars on October 22. In 2026 he gave the DSCC 44,300 dollars on January 21, the New York Majority Fund 19,000 dollars on January 20, the Blue Dog Victory Fund 26,000 dollars on March 25, the Steil Victory Fund 22,000 dollars on March 31, and 250,000 dollars to NRSC Victory on April 28. Smaller 2026 contributions went to House candidates of both parties on February 4, May 25 and June 2 to 16.⁵⁹

Lopes Lara gave 291 dollars to the Trump National Committee JFC on July 17, 2024. Her 2025 contributions were 5,000 dollars to Lummis for Wyoming on June 23 and 7,000 dollars to Angie Craig for Minnesota on September 2. On March 3, 2026 she gave the Republican National Committee 100,000 dollars (55,700 dollars to its legal proceedings account and 44,300 dollars), and on March 30 and 31 she gave 3,500 dollars twice each to the committees of Darren Soto, Lori Trahan, Emily Randall, Andrea Salinas and Vargas, and 5,000 dollars to the Willamette Valley PAC. On April 29, 2026 she gave 250,000 dollars to NRSC Victory. In late May 2026 she gave 3,500 dollars each to the committees of Republican House candidates including Andy Ogles, Scott DesJarlais, Andy Harris, Mark Harris, Nick Begich, Brandon Gill, Mary Miller and Davidson, and in June to Vindman for Congress and Mannion for New York. Her contributions total about 487,000 dollars: about 419,000 dollars to Republican committees and candidates and about 68,000 dollars to Democratic ones.⁵⁹

Mishory, listed in the records as Eliezer or Elie Mishory with the occupations "Kalshi attorney," "Kalshi CRO and counsel" and "Kalshi executive," gave to Cory Booker (April 12, 2022, 2,900 dollars), Kirsten Gillibrand (April 13, 2022, 2,900 dollars), John Boozman (May 5, 2022, 2,000 dollars, and July 22, 2022, 2,900 dollars), Debbie Stabenow (July 11, 2022, 2,900 dollars), John Thune (July 18, 2022, 2,900 dollars) and Torres for Congress (November 19, 2023, 6,000 dollars).⁵⁹

Lobbying

Kalshi Inc. registered as its own lobbyist on July 31, 2025 under LDA registrant ID 401109813. Its in-house reports show 190,000 dollars in expenses for the third quarter of 2025, 175,000 dollars for the fourth, 430,000 dollars for the first quarter of 2026 (amended to 490,000 dollars on April 21, 2026) and 500,000 dollars for the second quarter.⁶⁰ The in-house lobbyists include Sara Slane, John Bivona (a White House liaison at the Department of Homeland Security in 2021 and chief of staff to Representative Antonio Delgado from December 2018 to August 2020), Tony Hanagan (Republican cloakroom and floor staff, Senate, 2014 to 2026, who stated he will not contact the Senate until his post-employment restriction ends), and, in an August 2026 amendment, Chelsea Brossard (chief of staff to Representative Josh Gottheimer, 2023 to 2024) and Jamie Gillespie (Congress and White House legislative staff, 2015 to 2026).⁶⁰

Outside firms filed for Kalshi from December 2021. Rich Feuer Anderson reported 20,000 to 40,000 dollars a quarter until a termination effective June 1, 2024; its lobbyists included Jared Sawyer (deputy assistant secretary at the Treasury Department, senior counsel to the Senate Banking Committee) and Rashawn Mitchell (deputy chief of staff to Representative Joe Cunningham and adviser at the Office of Management and Budget). Capitol Counsel LLC registered in November 2022, reported 30,000 to 50,000 dollars a quarter, and terminated effective October 31, 2024 with a final 20,000 dollar report posted January 14, 2025. Its lobbyist De'Ana Dow lists service as counsel to CFTC Chairman William Rainer and as special adviser to CFTC Chairman James Newsome, and is the only Kalshi lobbyist whose covered positions are at the CFTC. Dow Solutions Inc., which also lists Dow, registered in December 2025 and reported 10,000 to 20,000 dollars a quarter through the second quarter of 2026.⁶⁰

Miller Strategies registered in May 2024 and reported 50,000 to 120,000 dollars a quarter; its filings name Jeffrey Miller, Jessica Mandel and, from 2026, Lucas Wallwork, Natalie McIntyre and James Grimm, whose covered positions include chief counsel to Representative Jim Jordan, legislative director to Senator Bill Hagerty and a White House legislative affairs post. Lincoln Policy Group registered in June 2024 with former Senator Blanche Lincoln and reported 60,000 dollars a quarter. Tower 19 and Alva Elliott Partners, 2024 registrants that terminated effective October 2024, listed Jed Bhuta and Robert Russell, the latter a former chief of staff to Senator Mark Pryor. Intersection reported 30,000, 45,000 and 45,000 dollars for the fourth quarter of 2025 and the first two quarters of 2026; its lobbyists include Curtis Doster (chief of staff to Representative Brenda Lawrence, senior counsel to Delgado) and Matthew McNally (chief of staff to Representative Sean Patrick Maloney). Squire Patton Boggs registered in March 2026 and reported 70,000 and 110,000 dollars for the first two quarters, with Thomas Andrews (staff to Speakers John Boehner and Paul Ryan, White House legislative affairs 2018 to 2021) and Caren Street (staff to Senator Harry Reid 2008 to 2017, chief of staff to Representative Karen Bass). Resolution Public Affairs registered in April 2026 and reported 60,000 dollars for each of the first two quarters, with lobbyists formerly legislative directors to Senator Chuck Schumer. Forbes-Tate registered in July 2026. The second-quarter 2026 reports sum to 915,000 dollars across the in-house registrant and six outside firms.⁶⁰

Resolution Public Affairs' July 2026 report lists as issues S. 4469, the Prediction Markets Act of 2026, S. 4784, the Senate fiscal 2027 defense authorization bill, S. 4668, the Protect College Sports Act, and the purchase of event contracts by government employees.⁶¹ The Coalition for Prediction Markets has its own LDA filings: a registration by Invariant LLC posted May 15, 2026 (terminated in the second quarter) and a registration by Determinant LLC posted August 6, 2026.⁶²

Revolving Door

Elie Mishory held leadership roles in the CFTC's Division of Market Oversight and served as counsel to Commissioner Quintenz before joining Kalshi, where he was chief regulatory officer and general counsel from before the exchange's launch. Protos reported that he stepped down in March 2025 for a role connected to the Department of Government Efficiency at the Securities and Exchange Commission with the title senior advisor to the chairman. On June 23, 2026 Novig announced him as chief regulatory and legal affairs officer.⁶³

Joshua Sterling, a Milbank partner on Kalshi's Sixth Circuit briefs, was Director of the CFTC's Market Participants Division under Chairman Heath Tarbert.³⁵⁶⁴ Brian Nelson, a former Under Secretary of the Treasury for Terrorism and Financial Intelligence and a Cooley partner, was engaged by Kalshi in February 2026 to advise on market integrity, trading surveillance and financial compliance.³ Protos reported that Roth moved from Jones Day to the Justice Department's Civil Division in February 2025, with the title Principal Deputy Assistant Attorney General.²⁹

Media and Brokerage Partnerships

Robinhood introduced Super Bowl event contracts through Kalshi in early February 2025 and, by February 5, 2025, had suspended the offering a day after listing it, following a CFTC request, according to Finance Magnates, which also reported a CFTC review of Super Bowl contracts offered by Crypto.com and Kalshi. Webull announced its Kalshi partnership on February 12, 2025.⁶⁵ Coinbase announced on January 28, 2026 that prediction markets were live in all 50 states with all contracts supplied by Kalshi, after Coinbase first announced its prediction-market plans in December 2025.⁶⁶

On December 2, 2025 CNN named Kalshi its official prediction markets partner, with Chief Data Analyst Harry Enten to lead use of the data and a Kalshi-powered ticker on air.⁶⁷ CNBC announced a similar arrangement days later covering its television, digital and subscription products. Popular Information reported on July 6, 2026 that the CNN arrangement is exclusive, so that CNN cannot mention Polymarket odds, and that CNBC invested in Kalshi and receives a fee for referring new users; CNBC's disclosure on some articles reads "CNBC and Kalshi have a commercial relationship that includes customer acquisition and a minority investment."⁶⁸

Integrity

On February 5, 2026 Kalshi announced an independent Surveillance Advisory Committee (Lisa Pinheiro of Analysis Group and Daniel Taylor of the Wharton Forensic Analytics Lab), a surveillance partnership with Solidus Labs, and the engagement of Brian Nelson.³ On February 25, 2026 Kalshi said it had opened 200 investigations over the past year. It reported a two-year suspension and a penalty of five times the trade size, over 20,000 dollars, against Artem Kaptur, an editor who worked for MrBeast, and a five-year ban and a penalty of ten times the trade size against Kyle Langford, a California gubernatorial candidate who had bet about 200 dollars on his own race, and said it had reported both cases to the CFTC.⁶⁹

On April 22, 2026 Kalshi announced five-year suspensions and fines for three congressional candidates who had traded on their own races, Mark Moran of Virginia, Matt Klein of Minnesota and Ezekiel Enriquez of Texas, and fined Moran 6,229.30 dollars after he refused to settle.⁷⁰ Kalshi reported more than 150 insider-trading investigations opened in the first quarter of 2026, more than 100 potential trades blocked and at least 20 referrals to law enforcement, together with a risk-scoring framework and employment verification for traders on high-risk markets.⁷¹