I believe this will end up being a multi-part series released over the course of 2025, split into two categories. The first will focus on building a centralised exchange, followed by building a DEX on the Sui and ZKSync, the differences between the two technologies and where you might prefer one over the other.

You might be wondering why you should listen to me about building a centralized exchange.

Well, I’ve had the opportunity to work for two exchanges, both operating in the regulated space and abiding by the local laws of their customers in regions such as the UK and EU.

In 2020, I joined a fintech positioning itself as a crypto-focused “super app.” It was one of the first crypto fintechs in the UK to be regulated by the FCA and placed in its regulatory sandbox for crypto. The platform supported fast KYC, simple fiat on- and off-ramping, basic crypto exchange features, yield farming, and Open Banking payments. Additionally, we integrated both Open Banking (fiat) and crypto collateralised payments services with several large retailers' checkouts in the UK.

In this series, I’ll cover how I would build a decentralized exchange today in the UK/Europe. Please note that this is not a guide on how major exchanges like Coinbase, Binance, Kraken etc., are built. Those exchanges have grown organically, with all the odd baggage that comes with such growth. Some exchanges have undergone massive replatforming efforts, which I genuinely admire, given the level of effort required—possible only because of their exceptionally high hiring standards.

The areas we’ll be covering include:

  1. Treasury management – We’ll discuss custody, liquidity management and third-party wholesale liquidity as part of this.
  2. User Account Management and KYC – This will cover onboarding processes.
  3. Exchange and Trading – Key aspects of running the trading platform.
  4. Core Banking As a Service – We’ll cover integrating with a core banking as a service provider, fiat liquidity management, including fiat on- and off-ramping. This section will highlight the importance of safeguarding customer funds and client assets.
  5. Transaction Monitoring & AML – This will include monitoring for crypto assets and fraud detection.

I'm not going to go too deeply into financial regulatory compliance such as AMLD5 and MiCA.

I’ll discuss digital wallets separately from crypto and digital assets, as it’s a large topic on its own. We’ll approach it more from the fiat side, and I’ll cover the regulatory hurdles, such as EMI and EMD, and their differences.

Finally, while we won’t cover staking and yield generation options in this series.