Bullish's IPO application comes at a crucial time. The US Congress is in a critical window for digital asset legislation, and the advancement of the CLARITY Act is seen as a sign that the crypto industry has officially entered the "Year of Compliance." Over the past few years, the US Securities and Exchange Commission has continuously strengthened its regulatory enforcement of exchanges, stablecoins, and related derivatives platforms, leaving the industry shrouded in uncertainty and wait-and-see sentiment. Meanwhile, a trading platform, only three years old, proactively filed with the SEC, signaling not only its desire to gain trust in the capital market through compliance but also its bet on policy trends. This echoes the market's renewed expectations for liquidity. As the high-interest rate cycle draws to a close, risk assets are gradually regaining activity, and interest in the crypto market is once again rising. This macroeconomic environment created a window of opportunity for Bullish's IPO.

This company isn't a traditional startup . It was incubated by blockchain firm Block.one, backed by a portfolio company that includes Peter Thiel, Founders Fund, Nomura, and several prominent Wall Street hedge fund investors. Its management team also boasts a strong background in traditional finance. CEO Thomas Farley is a former president of the New York Stock Exchange, and CFO David Bonanno, a graduate of FPAC, has extensive experience in capital markets and compliance. This team structure, in part, shapes Bullish's positioning: it seeks to inherit the innovative spirit of the crypto industry while distinguishing itself through the governance and compliance practices of traditional finance.

In terms of its business structure, Bullish is more than just a cryptocurrency exchange. Its core remains Bullish Exchange, offering spot and derivatives trading for mainstream assets like Bitcoin and Ethereum. Its currently disclosed average daily trading volume is approximately $2.5 billion, with cumulative trading volume exceeding $1.25 trillion. Unlike most competitors, however, Bullish prioritizes institutional clients, emphasizes compliance and risk management, and has applied for or obtained official licenses in multiple jurisdictions around the world. Meanwhile, Bullish has incorporated media and data services into its portfolio through the acquisitions of CoinDesk and CCData. CoinDesk is one of the world's most influential crypto news platforms, with over 55 million annual visitors, while CCData specializes in market data and index compilation, serving over 100,000 institutional users worldwide. These assets enable Bullish to create a rare closed-loop business model: gaining industry influence and customer engagement through media content and data services, and then channeling this traffic and information into its trading business, creating synergistic effects.

In terms of asset allocation, Bullish holds approximately 24,000 bitcoins, valued at nearly $1.5 billion at current market value. This size places it among the top five publicly listed companies globally in terms of bitcoin reserves, alongside companies like MicroStrategy and Tesla. While this asset structure adds value to the company's balance sheet, it also introduces significant performance volatility. For example, in the first quarter of 2025, due to falling bitcoin prices, the company recognized an impairment loss of approximately $246 million, resulting in an overall net loss of over $300 million for the quarter. This profit model, which relies heavily on crypto asset prices, makes the company's financial performance highly sensitive, and profitability stability remains a significant challenge.

The financial data clearly demonstrates this volatility. In 2022, the company recorded a loss of $4.25 billion due to large-scale asset impairments; in 2023, it turned to a net profit of $1.3 billion; in 2024, profits narrowed to less than $100 million; and in the first quarter of 2025, it suffered losses again. Although transaction volume continues to rise, the profit model has not yet fully stabilized. The IPO plan shows that the company will be listed on the New York Stock Exchange under the symbol BLSH, with an issue price range of $28 to $31. It is expected to issue 20.3 million shares, raising up to approximately $630 million, with an overall valuation of approximately $4.2 billion. Compared with Coinbase's market capitalization of over $70 billion and Circle's valuation of nearly $50 billion, Bullish's pricing is significantly lower, but it also reflects the market's uncertainty about its growth path.

A horizontal comparison reveals a significant disparity. Coinbase has achieved stable profitability and dominates the retail sector in the US market; Circle, leveraging the policy dividends of the stablecoin USDC, has earned a significant capital market premium; while Bullish is attempting to capitalize on a comprehensive "transaction + media + data" structure, its profit model is still in the development phase. According to a discounted cash flow model, assuming an average annual growth rate of 20% for future free cash flow, a 15% discount rate, and a long-term stable growth rate of 3%, its intrinsic value is approximately $3 billion to $3.5 billion. While this represents a certain premium compared to its IPO valuation, it is not excessive. Whether this valuation can be sustained depends on whether future earnings can be stable.

Bullish's competitive advantages lie primarily in four key areas. First, its management and investors boast strong backgrounds, including a senior executive team from the New York Stock Exchange and backing from Silicon Valley investors like Peter Thiel. This gives it a natural advantage in compliance and capital markets. Second, its media and data businesses have formed a unique moat. CoinDesk's influence and CCData's data products provide the company with a secondary growth path beyond trading. Third, its pioneering regulatory compliance strategy, having obtained or applied for licenses in Germany, Hong Kong, and Singapore, has established a global regulatory moat. Fourth, its Bitcoin holdings in its reserves give it a symbolic brand value within the industry.

However, the risks are equally clear. Bullish's profit model is highly sensitive to Bitcoin prices, and asset write-downs frequently erode profits. While the policy environment shows positive signs, the uncertainty of the legislative process could still lead to setbacks. Industry competition is fierce. Coinbase's brand influence and user base in the US far surpass Bullish's, and Binance's scale advantage in the global retail market is difficult to challenge. Furthermore, the potential reduction of holdings by early investors such as Peter Thiel could also lead to selling pressure after the IPO. A deeper problem lies in the fact that Bullish has yet to clearly demonstrate a "second growth curve" beyond trading, media, and data, and its future growth remains largely dependent on the fluctuations of the crypto market itself.

Amidst this complex interplay of factors, Bullish's IPO represents a significant experiment in policy, capital, and market structure. While demonstrating the path for crypto companies to enter mainstream capital markets amidst the growing trend toward regulatory compliance, it also exposes the structural risks of unstable profitability and policy dependence. Regardless of the ultimate stock price performance, this event itself serves as a valuable example of the interaction between the crypto industry and the US capital market.

Business Model

Against the backdrop of a growing global regulatory compliance movement, Bullish's positioning needs to be better understood within an international context. Compared to Coinbase, the two companies exhibit significant differences in their business models and customer structures. Since its inception, Coinbase has consistently prioritized retail users, building a stable profit model based on retail trading volume and fee income, and fostering a strong regulatory compliance defense in the United States. From the number of licenses it holds to its compliance approach, Coinbase has become synonymous with "compliant retail" in the crypto asset market. Bullish, on the other hand, focuses more on institutional clients. Its management team, comprised of senior executives from traditional finance backgrounds, clearly understands how to meet the prudential requirements of regulators and large financial institutions. This difference means that Coinbase's growth stems primarily from expanding its retail trading volume, while Bullish is more likely to be attempting to carve out a niche in the "institutional compliance services" market.

A comparison with Circle reveals another limitation. Circle's core business isn't an exchange, but rather a more stable source of cash flow through the issuance and settlement of the stablecoin USDC. The role of stablecoins in the internationalization of the US dollar and cross-border payments gives Circle's profit structure a quasi-public good. Even amidst market fluctuations, its reserve income and settlement fees provide a degree of stability. This is something Bullish lacks. Despite its diversified business structure, Bullish's profits remain highly dependent on trading volume and crypto asset price fluctuations. If it fails to develop a "second growth curve" similar to stablecoins or payments, its long-term competitiveness and valuation stability will remain constrained by market cycles.

In the Asian market, Hong Kong's HashKey Exchange offers an alternative path. Benefiting from the regulatory frameworks of the Hong Kong Monetary Authority and the Securities and Futures Commission, HashKey became one of the first exchanges to receive a VATP license. Leveraging Hong Kong's status as an international financial center and the outflow of capital from mainland China, it enjoys a significant advantage in the deep integration of compliance and traditional finance. Compared to HashKey, Bullish, while also licensed in Hong Kong, lacks the resources for local penetration and deep regional development. HashKey collaborates closely with banks and securities firms, developing a hybrid business model combining "virtual assets and traditional finance," while Bullish's differentiation relies more on the synergy of its media and data platforms. Long-term, if Bullish hopes to achieve a breakthrough in the Asian market, it must further build institutional and ecological complementarity; otherwise, it will struggle to challenge its position as a local compliance pioneer.

If we expand our perspective to the global competitive landscape, Binance and Kraken represent two extremes. Binance triumphs on liquidity and user scale, and even after regulatory turmoil and substantial fines, it still leads the world in trading volume. Kraken maintains its lead in the compliant derivatives market, particularly in Europe and the United States, where it holds a solid share. Bullish's model is clearly closer to Kraken's, emphasizing compliance, robustness, and institutional clients, rather than pursuing Binance-style extreme scale expansion. However, in terms of the professionalism and depth of its derivatives business, Bullish has yet to achieve the same level of barriers to entry as Kraken. This means that in the most lucrative derivatives market, it remains in a position of catching up rather than leading.

Looking ahead to the next three to five years, compliance will become a core variable in global cryptocurrency exchange competition. In the US, the successful implementation of the CLARITY Act will directly determine the market landscape. A "duopoly" is expected to emerge in the US, with Coinbase continuing to dominate the retail market and Bullish potentially serving as a model for compliance on the institutional side. This division of labor is both a natural consequence of market structure and a policy outcome driven by regulatory frameworks. Europe, under the MiCA framework, is promoting unified regulatory standards to reduce cross-border regulatory arbitrage. Platforms such as Kraken and Bitstamp are actively applying for relevant qualifications. If Bullish can leverage its media and data strengths to expand into the European market, it is expected to secure a place in the Eurozone's cross-border transaction compliance landscape.

A bipolar landscape is also emerging in the Asian market. Hong Kong attracts international capital and institutional funding through its VATP license, while Singapore emphasizes financial stability and risk management. HashKey has already established a leading position in Hong Kong, while Singapore's regulatory approach provides opportunities for institutional services centered around stablecoins and payments. Bullish has obtained a license in Hong Kong, but to establish a true competitive advantage in Asia, it needs to integrate media, data, and compliant transactions to form a differentiated ecosystem; otherwise, it will be difficult to stand out in regional competition.

Global competition will ultimately come down to a core proposition: compliance is the key to success. As traditional finance gradually enters the crypto space, exchanges that can obtain regulatory licenses, establish cross-border capital channels, and attract large financial institutions and pension funds will be more sustainable than platforms that rely solely on user scale and liquidity. Over the next three to five years, the valuation criteria for crypto exchanges will shift from "scale and trading volume" to "compliance and stability." In this landscape, if Bullish can maintain its first-mover advantage in compliance and gradually develop synergies across trading, media, and data, it has the potential to become a long-term player in the compliant exchange market. Conversely, if a profit model consistently relies on market fluctuations and fails to establish a new growth trajectory, fluctuations in market sentiment will continue to amplify the instability of its performance. This is a structural issue that investors must address when assessing its long-term value.

The future ecology of crypto exchanges

Looking ahead to the next decade, it's foreseeable that crypto exchanges will move beyond simply being platforms for matching buys and sells, gradually evolving into integrated financial infrastructure. Initially, exchanges' core competitiveness hinged on the depth of their liquidity and the breadth of their product offerings. Those offering more trading pairs, lower fees, and faster matching speeds attracted users and capital. However, with tightening regulations and heightened compliance requirements, this "extensive" expansion model has reached its limit, forcing exchanges to pursue more robust growth models within a new ecosystem.

The first evolutionary path is for exchanges to gradually transform into "financial supermarkets." This trend can be traced back to the history of traditional capital markets. Stock exchanges evolved from early trading venues to include custody, settlement, clearing, and index compilation, ultimately becoming the core of the financial system. A similar process is also occurring in the crypto industry. Exchanges not only provide trading matching but also integrate custody, wallet services, and payment channels, even extending to stablecoin issuance, clearing networks, and cross-border payments. Bullish's acquisition of CoinDesk and CCData is essentially laying the foundation for the future "financial supermarketization." They will gain pricing power and user awareness through data and content, and then manage capital flows through trading and custody. Once stablecoins and on-chain payments become more compliant, exchanges with a comprehensive architecture of media, data, and trading will be more easily able to enter the settlement and payment infrastructure.

The second evolutionary path is for exchanges to expand into "new asset management platforms." With the deepening of regulatory compliance, more and more institutional investors will allocate crypto assets through exchanges. These institutions are not seeking short-term, highly volatile speculative opportunities, but rather stable custody, secure clearing, a transparent compliance framework, and a comprehensive asset management solution. Future exchanges may offer customized index portfolios, on-chain ETFs, structured derivatives, and yield enhancement products, gradually evolving into a "crypto Morgan Stanley" or a "digital BlackRock." This path makes sense for Bullish, as its management team comprises senior executives from traditional finance and is familiar with the needs of institutional clients and regulatory requirements. By expanding institutional custody and asset management services beyond its existing trading operations, it can build a long-term competitive advantage.

The third evolutionary path is for exchanges to further integrate into the global payment and clearing system. The promotion of stablecoins and central bank digital currencies will reshape the cross-border payment landscape. Traditional clearing networks like SWIFT have long suffered from inefficiency, high costs, and geopolitical risks. Crypto assets and distributed ledgers offer new options for cross-border payments. In the future, exchanges with global compliance licenses are likely to become important intermediaries for cross-border capital flows. Circle's USDC has already taken a step forward in this area, but future competition will not be limited to stablecoin issuers but will expand to who can provide the most reliable clearing network and payment infrastructure. If Bullish can leverage its media and data platform to establish standards and obtain a cross-border payment license within a compliant framework, it has every chance of entering this promising market.

The fourth evolutionary path is for exchanges to expand into a multi-asset ecosystem. Cryptoasset exchanges will no longer be limited to trading Bitcoin and Ethereum, but will gradually incorporate on-chain trading of real-world assets (RWAs), tokenized bonds, tokenized stocks, and even commodities. Switzerland and Singapore are already promoting related pilot programs, and traditional financial institutions in the United States and Europe are also actively exploring them. If future regulations allow, exchanges can serve as a bridge between traditional and digital assets, assuming the role of issuing, trading, and clearing tokenized assets. This trend could significantly expand the market space for exchanges, extending their reach beyond the crypto industry and gradually moving towards a "full-asset digital infrastructure."

Finally, exchanges may also become the future setters of "risk pricing and data benchmarks." Just as S&P and Nasdaq have become standard-setters in the global capital markets through their indices and data services, crypto exchanges that master core market data, index products, and research capabilities can establish authority in the industry beyond liquidity. Bullish's acquisition of CoinDesk and CCData is clearly a move in this direction. If they can launch benchmark indices adopted by mainstream institutions, they will become more than just trading platforms; they will become the "anchor" for crypto asset pricing and risk management.

Taking these evolutionary paths together, we can see a clear future: exchanges will increasingly prioritize trading, gradually building a comprehensive ecosystem encompassing custody, settlement, payment, asset management, data, and standards, ultimately becoming the "next-generation financial infrastructure." In this process, whoever can achieve compliance first will have the opportunity to enter the institutional market first and build long-term competitive advantages through network effects and ecosystem expansion. Coinbase's retail moat, Circle's stablecoin settlement, HashKey's Asian compliance advantages, and Kraken's derivatives capabilities are all crucial pieces of the puzzle in this future ecosystem. To gain a foothold, Bullish must leverage its differentiated advantages in "trading + media + data" while simultaneously fostering new growth paths as quickly as possible.

Policy factors

If we examine the future of crypto exchanges within the broader context of global policy and geopolitics, we discover that compliance isn't a single regulatory issue, but rather an extension of a transnational game. Differences in regulatory frameworks across jurisdictions are shaping a new global financial landscape, and crypto exchanges sit at the heart of it.

The United States remains the world's most decisive market. On one hand, it boasts the deepest capital markets, the strongest dollar hegemony, and the broadest institutional investor base. Therefore, both domestically regulated exchanges like Coinbase and Circle's stablecoin issuance naturally possess international pricing power. On the other hand, US regulation has long been fragmented and sluggish. Multiple agencies, including the SEC, CFTC, and FinCEN, operate independently, and legislative lags make it difficult for companies to achieve a clear compliance path. This uncertainty not only limits industry expansion but also provides new players like Bullish with the opportunity to differentiate themselves through proactive regulatory engagement. The current CLARITY Act and its debate in Congress are essentially defining the future of the industry. If enacted, it will mark a milestone in the regulatory compliance of crypto exchanges and will reshape the US market landscape.

Europe's logic is quite different. The EU's MiCA (Markets in Crypto-Assets) framework is the world's first fully codified crypto regulatory system. It establishes clear rules of the game for all member states through a unified market approach. While this approach lacks flexibility compared to the US, it offers significantly greater certainty. For exchanges, MiCA provides a predictable compliance environment, particularly for companies with a clear strategy for international expansion. This is crucial for reducing regulatory friction. Therefore, Europe may become a key hub for compliant exchanges in the future, with a wave of emerging platforms leveraging the EU market to gradually expand outward. For Bullish, if it can gain early entry with the German BaFin license, it can fully capitalize on the European market as a strategic pivot.

Asia presents a more complex picture. While mainland China strictly prohibits cryptocurrency trading, Hong Kong has pioneered an experimental path toward compliance under the "Virtual Asset Trading Platform License" framework. HashKey, one of the first licensed compliant exchanges, is striving to establish itself as the "Coinbase of Asia." Singapore continues its long-standing commitment to financial innovation and openness. The MAS, through the gradual issuance of digital asset payment and trading licenses, provides a relatively stable destination for global capital. Japan and South Korea adopt a cautious regulatory approach, but have gone further in areas such as exchange custody and user protection. Overall, Asia's compliance model leans towards a "regional pilot program followed by gradual liberalization." This means that over the next decade, the Asian market is likely to develop into multiple regional hubs, rather than a single, US-style giant. This presents both an opportunity and a challenge for Bullish: the opportunity lies in gradually entering different markets through a patchwork of licenses; the challenge lies in balancing local compliance with a globally integrated strategy.

From a geopolitical perspective, the future of crypto exchanges is closely tied to great power competition. As the global reserve currency, the US dollar is naturally tied to the international circulation of stablecoins and crypto assets. By allowing certain compliant companies to go public and liberalizing stablecoin settlement, the US is essentially tying the emerging digital finance sector to the US dollar system, thereby offsetting competition from cross-border RMB payments and Eurozone financial integration. One of the motivations behind Europe's introduction of MiCA is to provide a relatively independent compliance standard outside of the US dollar to avoid spillover from US regulation. In Asia, Hong Kong and Singapore are competing for the status of "regional financial hub." Whoever can lead in establishing a compliant ecosystem will attract more cross-border funds and transaction flows. In other words, the regulatory evolution of crypto exchanges is not just a matter of financial innovation; it is part of the reshaping of the global financial order.

For new players like Bullish, the global landscape means they can't rely solely on the US market, nor can they ignore regulatory windows in Europe and Asia. If they can simultaneously obtain regulatory licenses in multiple regions and leverage their media and data strengths to build a cross-border storytelling platform, they have the opportunity to become a global brand amidst the wave of regulatory compliance. Conversely, if they remain confined to a local market and fail to keep pace with the dynamics of policy and geography, they will be confined to a secondary player.

In the longer term, as tokenized assets, stablecoins, and central bank digital currencies become increasingly intertwined, crypto exchanges may further evolve into intermediaries of global financial liquidity. At that point, every subtle shift in policy and geopolitics will be reflected in global markets through exchange liquidity and valuations. Whether Bullish can establish a global foundation through this IPO depends largely on its ability to navigate this regulatory landscape and international competition.

The direction of crypto exchanges in the next ten years

Looking ahead to the next decade, we can see that the evolution of crypto exchanges will not remain confined to the single function of "matching buys and sells," but will gradually transform into a multi-layered financial infrastructure. Compliance is only the beginning; the more crucial question is how they can develop sustainable moats across various dimensions. Judging from their current trajectory, future strategic paths can be broadly summarized into four main lines.

The first path is institutionalization. For the past decade, the primary user base of crypto exchanges has been retail investors. However, with the gradual clarification of regulations and the integration of capital markets, institutional clients will become the dominant force in the future. For exchanges, this not only means higher trading volumes and more stable capital flows, but also requires them to provide service capabilities that are closer to traditional financial standards, including custody security, compliance reporting, risk management tools, and cross-asset settlement. This institutionalization process will also further raise the barrier to entry for the industry, as compliance costs, technical costs, and capital strength will become key differentiators. Coinbase has already clearly shifted its focus to institutions, Circle has entered the payment and settlement market through stablecoins, and Bullish emphasizes the integrated capabilities of "trading + media + data." The underlying logic behind all of these is the competition for institutional clients.

The second path is multi-assetization. Currently, most crypto exchanges still focus on mainstream tokens like Bitcoin and Ethereum, but in the long term, tokenized financial assets will rapidly expand, including tokenized government bonds, corporate bonds, real estate shares, and even art. This will shift the role of exchanges from "crypto asset trading platforms" to "full-asset digital marketplaces." Once this trend takes hold, it will not only significantly increase trading volume but also align the strategic value of compliant exchanges with that of traditional exchanges. In this landscape, whoever can first establish a multi-asset trading framework will be the first to seize market dominance. If Bullish can integrate its exchange business with media data to provide enhanced price discovery and transparency, it could potentially establish a differentiated advantage in this multi-assetization process.

The third path is "payment and clearing." The convergence of stablecoins, central bank digital currencies, and cross-border payment infrastructure is gradually blurring the lines between "exchanges" and "payment platforms." Future compliant exchanges are likely to simultaneously undertake matching, custody, clearing, and payment settlement functions, becoming an alternative or supplement to traditional clearinghouses and payment networks. Circle's USDC is already on this path, and Coinbase is also actively pursuing payment-related partnerships. If Bullish can leverage its traffic advantages as a media and data platform, combined with its Bitcoin reserves and exchange capabilities, it could potentially enter the cross-border settlement and institutional payment sectors, thereby establishing a new revenue stream. The potential in this area could even far exceed simple transaction matching.

The fourth path is to "close the ecosystem." Exchanges that rely solely on transaction fees often struggle to withstand market fluctuations. Therefore, building a larger closed ecosystem is essential to extending the growth curve. This closed loop can include media, research, data, wallets, custody, lending, derivatives, and even NFTs and on-chain applications. Binance once expanded rapidly using a "full ecosystem" model, but encountered significant pressure due to compliance red lines. Coinbase gradually built its ecosystem through wallets, developer platforms, and Web3 applications. Bullish's "trading + media + data" combination is essentially a prototype of a closed loop. Over the next decade, whoever can find a second growth curve within the closed loop will be more likely to survive the cycle.

Overall, future competition among crypto exchanges will be a strategic combination: institutionalization improves user quality, multi-assetization expands trading reach, payment and clearing penetrate deeper into the infrastructure layer, and a closed-loop ecosystem enhances resilience. Every exchange must strike a balance between these four dimensions. For Bullish, in the short term, it relies on trading operations and Bitcoin reserves; in the medium term, it relies on traffic and pricing power generated by media and data; and in the long term, it must achieve breakthroughs in multi-assetization and clearing and payment systems. Otherwise, it will be difficult to compete on equal terms with leading exchanges like Coinbase and Circle.

If we examine these four paths within the context of geopolitics and compliance, we uncover a broader logic: over the next decade, exchanges will not only be participants in the capital markets but also builders of a new financial order. They will find their own strategic pivots at the intersection of the US dollar system, the EU single market, and Asia's multi-center landscape. Through compliance and business diversification, they will upgrade themselves from "trade matching platforms" to "digital financial infrastructure." This transformation is both inevitable and presents a significant challenge. Only a few platforms will emerge victorious despite the dual screening of regulators and the market.