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 centralized exchange, followed by building a DEX on the Sui blockchain and in the later I'll actually walk you through code and introduce you to the Move language.
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 and crypto 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, 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.
One thing I won’t cover is white-label exchange platforms. A few years ago, there was a proliferation of exchanges across Asia that were reskins of a poorly architected PHP-based platform. Unfortunately, when a vulnerability was discovered in one exchange, it often spread quickly to others using the same platform, resulting in significant asset losses for customers.
The areas we’ll be covering include:
- Treasury management – We’ll discuss custody, liquidity management and third-party wholesale liquidity as part of this.
- User Account Management and KYC – This will cover onboarding processes.
- Exchange and Trading – Key aspects of running the trading platform.
- Core Banking Integration – 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 ensuring no co-mingling of business and client assets.
- Transaction Monitoring & AML – This will include monitoring for crypto assets and fraud detection on the fiat side.
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, I’ll address those topics when we dive into building a DEX on Sui.