Crypto Exchange Disruption Analysis
Crypto Exchange Disruption Analysis
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 4
4. THE TEAM 14
7. IN CONCLUSION… 22
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Exchange
An Arturo Capital Analysis
This is a report on the Nash Exchange and its fully-compliant, registered crypto security token, NEX.
1. EXECUTIVE SUMMARY
Arturo Capital believes that the crypto exchange market is ripe for disruption. We believe a new
exchange platform will soon capture significant market share from its existing incumbents, in a similar
fashion to Binance’s market share capture in 2017 (where they siphoned a significant user base from
Bittrex and Poloniex). Anyone can dispute such a thesis, but two key points are widely accepted within
For crypto investors, accurate trade volumes have been a headache to measure. This is mostly a
“authentic” trade volume data among top crypto exchanges, placing the total 24-hour spot volume
Image: [Link]
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Compliant exchanges such as Coinbase have seen over 300% growth in Bitcoin volume in less than
4 years despite enduring two major bear markets over this timespan. Unregulated crypto-to-crypto
exchanges that dominate the altcoin market, such as Binance, have experienced even more drastic
volume growth, seeing over 3,000% total volume growth in less than 2 years (see images below).
Image: [Link]
Image: [Link]
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2) A new exchange emerges to the top of crypto every 1-2 years.
While exchanges like Coinbase and Bitfinex have consistently maintained relevance since 2013,
this isn’t the case for all of the top exchanges. Over the years we’ve seen several fade in-and-out
of market dominance. Mt. Gox, BTC-e, Cryptsy, Poloniex, and Bittrex are a few that wore the
crypto-to-crypto “crown” before Binance. All of these previous crown holders were dethroned
due to lackluster user experience, poor security, regulatory clampdown, or some combination of
each.
Binance, today’s largest crypto exchange, burst on the scene in 2017 and hasn’t looked back.
Today, they’re the top exchange by volume in the world. However, during the June 2019, Binance
announced it will soon ban US traders from their main platform due to clamp down from US
regulators.1 Since the US market currently accounts for 30-40% of Binance’s revenue,2 one might
speculate this opens the door for history to repeat itself, allowing a new exchange to scoop up
These two key points tell a story: the retail exchange space is thriving, and getting a slice of the
pie (market share) could be wide open for the taking. Thousands of crypto exchanges are currently
operating, so the competition is thicker than ever; but there is a shortage of US compliant, highly-
innovative exchanges offering something different. Arturo Capital believes Nash Exchange could be
offering something different. After conducting a thorough analysis of Nash’s products and regulatory
progress, we’ve observed a calculated and ambitious approach to innovating the entire crypto exchange
space from the ground-up via blockchain, self-custody, and a security token. The following document
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2. CRYPTO EXCHANGES: WHAT LIES AHEAD
Before diving into Nash, it’s important to understand the regulatory climate for crypto and how this
affects crypto exchanges like Nash. While guidance is still “foggy” at best, the advent of massive
projects like Libra (Facebook) 3 has regulators clamping down on cryptocurrency projects and ramping
up compliance oversight. 4
As previously mentioned, Binance will be restricting US traders on its platform starting September
2019, and many suspect it’s related to regulatory pressures. Exchanges such as Huobi and Bitfinex have
already restricted US trading, while many more centralized exchanges are expected to follow suit. These
top exchanges have all trimmed a large portion of their customer base (US traders) to avoid legal
US agencies are focused on ensuring thorough KYC/AML compliance and/or obtaining the proper
licenses (such as custody and money transmission). It’s readily apparent that crypto companies have two
choices: (1) comply with regulators, or (2) avoid the US entirely. Some exchanges like Coinbase and
Gemini have taken a more conservative route: moving slow on new features, listing only a select number
of cryptocurrencies, and ensuring compliance before moving forward with any business decision.
Ultimately, this conservative approach is required for survival, but it can be cumbersome for companies
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2.1 THE DEX; A REGULATORY “HACK”?
“In general across the globe, most securities regulations are related to reducing risks. The major risks for trading
platforms are the risk of market fairness and funds mismanagement. How will custodial platforms prove no one
else has control of the keys or act on behalf of users? That is simply impossible. They need to implement several
audit and operational control mechanisms. I would also expect regulators to require strong insurances from those
players - bringing their operational costs even higher. The matching fairness is even worse, how do they provide
proof that they have not acted maliciously on behalf of users when they control all the information needed to
impersonate users?”
What is a DEX? A DEX is an acronym for “decentralized exchange.” DEXs are often used to
describe non-custodial or self-custodial exchanges, even though there is a central point of authority
gatekeeping access onto the platform. In this document, DEX is used synonymously to describe non-
custodial exchanges, despite acknowledging the fact that one can make an argument these are not true
DEXs. While not truly decentralized, self-custody as a feature is a massive benefit to both traders and the
Non-custodial DEXs like Nash’s present a lot of legal advantages over centralized exchanges, since
they’re extracting out liabilities from their platform. The SEC and FINRA released a joint statement on
DEX’s that do not keep custody of traders’ assets (also known as self-custodial or non-custodial), stating
that they are not subject to the same level of regulatory scrutiny as centralized exchanges (where custody
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The United States government vies to provide investor protections for its citizens, so they place
extra scrutiny on exchanges to ensure strong custody solutions (customer funds are safely stored).
However, an exchange that does not keep custody of assets is alleviated by this scrutiny, and is given
On Nash, customers keep custody of their assets while utilizing the Nash exchange; assuming
they’ve passed proper KYC/AML checks before gaining access onto the exchange. In other words, Nash
is removing custody from the equation on their platform and this presents a lot of regulatory upsides.
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2.2 THE NASH APPROACH
“The general outcome is that out of the gate we comply with almost all items in securities trading
requirements across the globe, missing items are related to AML/CFT controls. Those we will put in the
market on August 23rd, 2019 and continue to improve in the following months, I expect that most
regulators will like to see our operating history for a few months on these points before they allow us to
enter the larger market of securities trading, platforms that skipped KYC or allowed users infringing basic
According to Nash’s 2019 Quarterly Reports and other various information resources, they have
obtained money transmission licenses in at least 14 states (as of August 1, 2019) 7 , enabling them to
provide fiat onramps in those states at launch on August 23. Nash’s ambitious objective of disrupting the
finance industry will require an effective legal team to obtain the proper licenses and abide by all
relevant regulations. The team has also reportedly obtained approval to allow investor access to NEX
dividend distribution in Europe, the United States, and Canada (among others).8
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Nash has achieved a major legal victory for not just a new cryptocurrency exchange, but any
cryptocurrency exchange by providing US investor access to dividends via their crypto security token,
kept it very low profile while making significant strides on DEX technology and legal.
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Most DEXs today experience extremely low trade volumes and not a single one has garnered much
The human attention span is short. According to the Nielsen Norman Group, viewers typically
leave a website within 10 to 20 seconds if their interest is not captured. It’s reasonable to assume this
standard also applies to crypto exchange websites. Today’s DEXs have limited order types (meaning, not
a lot of tools for experienced traders), confusing wallet integration to utilize their self-custody, and most
importantly, APIs are a pain to effectively plug into which turns away most algorithmic traders (major
liquidity providers for exchanges). Ultimately, today’s DEXs do not hold a candle to the seamless trading
experience users are accustomed to on central exchanges, and, understandably, no DEX has reached
“If I can’t trade BTC on your exchange, I don’t want to use it”
An exchange like Binance has high volume not just because of great UI/UX, but because a user
can trade virtually any crypto for any other crypto with very minimal slippage. What is slippage?
Investopedia defines slippage as, “the difference between the expected price of a trade and the price at
which the trade is executed”. Slippage often happens when an exchange doesn’t have much liquidity.
Today’s DEXs struggle with liquidity and slippage, mainly because they aren’t a “one-stop shop” where
traders can trade exclusively on their platform. Meaning, almost all DEXs are confined to a narrow list of
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crypto assets they can offer traders — such as IDEX and Etherdelta which are Ethereum exclusive (only
ETH/ERC20 pairs), or Switcheo (only NEO/NEP5 pairs + ETH/ERC20 pairs) which are Ethereum and NEO
exclusive.
As previously stated, UI/UX is a big reason for poor DEX liquidity, but another major contributor is
the lack of Bitcoin integration & Bitcoin trading pairs. BTC is the most liquid and preferred crypto asset
to hold/trade — and is also unquestionably the most preferred trade pair. Forcing users into another
trade pair, such as ETH, will turn away many traders as it forces them into a potential ETH position for
pending orders (a position that many see as far more volatile than Bitcoin). DEXs do not offer cross-chain
trading (eg, BTC to LTC) not because they don’t see the value, but because of the technological barriers
Nash appears to be solving most of the common hurdles holding back DEX’s from high-popularity
in the crypto space. The Nash DEX utilizes state channels to settle all trades, and this is reportedly what
enables them to have a user experience indistinguishable from centralized exchange platforms. More
importantly, the Nash DEX will be the first non-custodial exchange to offer true multi-chain support,
eliminating the problem of limited tradable assets. It’s worth noting that some existing DEXs, such as
Binance DEX or Switcheo, utilize “token wrapping” — meaning, Bitcoin is deposited into Binance and
you are given a 1:1 Binance Chain pegged Bitcoin. However, the Nash team argues token wrapping is
not truly “bitcoin support”, as this is a pegged asset, and the trader has to trust the peg as authentic. On
Nash’s platform, no assets will be pegged, they will be the assets you hold in your wallet today. The
Nash team has announced Ethereum and NEO functionality at launch (8/23/2019), and soon after that
will have support for Bitcoin, Litecoin and other cryptocurrencies later this year (Q3/Q4 of 2019).
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4. THE TEAM
expectations.
Ethan Fast: “Ethan is an entrepreneur and research scientist with a background in HCI, AI, and
blockchain. He has led more than 10 projects to publication in top venues such as CHI, UIST, EMNLP,
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Fabio Canesin: “Nash Co-Founder and act as foundation chair in City of Zion. Nash is a next-generation
Schlumberger.”12
Not many exchange development teams have had this much provable technical and legal
progress at such an early phase in their project. Apart from being highly productive with regulators,
they’ve also redefined the DEX ecosystem by offering an industry-first non-custodial cross-chain trading
Many blockchain companies, such as TRON Foundation, focus on unrelenting hype to build
notoriety.13 The Nash team appears to be doing the opposite of spreading hype. They’ve quietly
achieved regulatory progress, developed and deployed quality blockchain-based technology, all the
while preferring a lack of hype to organically grow their community, as indicated by Fabio in his
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5. THE “LEGAL” SECURITY TOKEN: NEX
Nash’s most eye-catching feature for traders and investors is their security token, NEX. As
previously mentioned, in the Q1 Quarterly Report the Nash team acknowledged that NEX staking (the
dividend issuing smart contract) will be available to US traders. NEX staking will be available to all
traders (after KYC completion) starting 8/23/2019 15 — making it one of the first dividend issuing security
tokens ever accessible to the US general public. Perhaps the more enticing feature of the token is what
type of rights holding the token will provide. The NEX token will offer up to 75% of all revenue
generated from Nash exchange fees. 25 million NEX out of a total of 50 million NEX were sold in their
crowdsale for $1 per token. The remaining 25 million NEX belongs to the team.
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Exchange tokens are some of the most popular and best performing crypto assets over the past
1-2 years.16 The most notable exchange tokens today are BNB (Binance), HT (Huobi), KCS (Kucoin), and
LEO (Bitfinex). None of them offer a tradable token on United States exchanges, many speculate them to
be unregistered securities, and all of the aforementioned exchanges are banning US traders (or will soon
be within the year). It's worth mentioning, once again, that US traders account for roughly 30% of trading
volume on exchanges like Binance, so these traders will prefer to go somewhere as they are geofenced
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5.1 DIVIDEND BREAKDOWN
The major cryptocurrency exchanges generate significant daily volume. Nash won’t see overnight
success, but it's still worth inspecting several hypothetical scenarios in the event they are successful and
A user can stake between 1 month to 24 months. NEX staking dividends issue 25% (for 1 month
staked) up to a return of 75% (for 2 years staked) of trading fees generated. When a user stakes their
NEX, it is illiquid for the selected time. These fees are based on the assumption that all 50 million NEX
are staked, so your NEX stake acts as a percentage of that 50 million NEX. The below chart analyzes
different monthly volumes, the comparable exchange associated with each volume rate, and the
expected dividend based on 1,000 NEX (which currently trades at roughly $3 per NEX).
E X P E C T E D D I V I D E N D PAY O U T
Volume Equivalent as of 8-7-2019 Monthly NEX Dividend
NEX Stake Total Monthly Volume Dividend Rate for 2 Years Staked
(Competing Exchange) (for 1000 NEX Staked)
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5.2 NEX TOKEN PRICE FORECAST
The nice part about analyzing a security token in crypto is a lot of conventional investment
formulas can be applied to value its suggested token price; as opposed to utility tokens which are far
more of a crapshoot. We apply a Dividend Discount Model to give a very rough estimate of what price
What is the Dividend Discount Model (DDM)? Investopedia defines DDM as “a quantitative
method used for predicting the price of a company's stock based on the theory that its present-day price
is worth the sum of all of its future dividend payments when discounted back to their present value.” Put
simply, it takes the total annual dividend, applies a few assumptions, and spits out a suggested share
price — or in this case, token price. In below table we took a popular DDM variant, referred to as the
Gordon Growth Model (GGM), which takes the: The expected total annual dividend paid out for each
NEX token (D1), desired annual rate of return on investment (r), the expected growth rate per year in
total annual dividend pay out (g), and this calculates the suggested NEX Token price derived from the
Calculating growth (g) and rate of return (r) is very challenging for a start up in a new space such as
crypto. There isn’t much historical data to reference for crypto companies, nor is the potential growth
rate in traditional markets very comparable. Crypto is a very disruptive space, so it’s most likely going to
continue on its path of historical growth. However, for these models we wanted to apply traditional rates
to arrive at some conservative “fair value” price forecasts for the NEX token. We used a 15% rate of
return (r) and an 8% expected dividend growth rate (g) to calculate the fair price for NEX — both
The results indicated that NEX is currently overpriced at its current spot price of $3 (as of
8/08/2019), since Nash would need to generate daily volume on par with Poloniex before justifying a $3
spot price. However, the upside for NEX is dramatic: if Nash can generate daily volume above $20m per
day (within the top 80 exchanges according to CoinMarketCap’s Adjusted Exchange Volume chart), NEX
at $3 is fair value. Looking through the most bullish lens, if Nash can capture just 25% of Binance’s
current daily volume, that would place the DDM fair value of NEX at over $30 per token — a crisp 10x
from current trading price. See the tables on the following page for further information.
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NEX TOKEN PRICE (BASED ON ! )
Annual Dividend Per
Volume Equivalent as of Suggested NEX Token
Annual Revenue Token
Total Monthly Volume 8-7-2019 Price
(With Average Fee of .19%) (Based on 2 Year
(Competing Exchange) (using DDM Formula)
Staking Rate)
“DDM” EXPLAINER !
DDM
Definition Chosen Values
Assumptions
The expected total annual dividend paid out for each NEX
Depends on Total Monthly Volume
D1 token. Calculated by combining Total Monthly Volume forecast,
achieved (multiplied by 12 months).
.19% average fee, and a 2 Year Staking Rate (75% of revenue).
The expected growth rate per year of total annual dividend pay
g out. Usually you reference past years, but we chose 8% growth 8%
as a conservative estimate.
Suggested NEX Token price derived from the present value of Calculated after unique D1 inputs are
P all of its future dividends applied.
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6. THE BEAR CASE
Nothing in life is a sure thing. The Nash DEX has made a lot of progress, but this doesn't come
without downside risk. The exchange space is increasingly more diluted with hundreds to thousands of
competing exchanges.18 Additionally, the major exchanges such as Coinbase and Binance are
simultaneously innovating to try to keep their position as the top moneymakers.19 There are several
๏ Facebook’s Libra has triggered enormous regulatory scrutiny on cryptocurrencies, and it's
entirely possible that new laws or regulations could derail future progress — or even worse,
๏ It's also possible that an unforeseen technical issue delays or inhibits the launch of multi-chain
functionality with assets like Bitcoin or Litecoin, which would drastically shrink the appeal of
๏ “Build it and they will come” does not always pan out favorably. Fabio has confirmed four years
of minimum runway.20 Given the significant amount of competition within the exchange space,
it’s possible the Nash platform doesn't quite catch on within 4 years, even if everything
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7. IN CONCLUSION…
“TLDR;”
Upside:
First multi-chain DEX (trade BTC, ETH, NEO, etc. via your hardware wallet) with a
trading experience comparable to exchanges like Binance (which is shutting out US
traders in September)
Fiat on-ramps: licenses in the US, Canada, and Europe to offer fiat gateway at
launch
Downside:
Tough competition. The crypto exchange market is highly saturated. Without
effective marketing, even the most impressive tech may not generate user traffic
Unforeseen regulation could dismantle Nash, DEXs, or the entire crypto space
Technical uncertainty. The team could be faced with security problems, significant
delays on features like multi-chain asset trading, or is unable to deliver on any of its
core promises.
Customer service. It’s tough to know whether an exchange can resolve support
tickets at scale until they are actually faced with them.
The NEX Token may only be valuable if Nash becomes a top exchange.
Conventional formulas suggest Nash may need to sustain ~$26m daily volume
(Poloniex) to even justify its current trading price of ~$3 per token (as of
8/08/2019).
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In conclusion, Nash is aiming for the stars in a highly competitive and saturated market. They face
a daunting task but they offer a unique business model, setting them apart from their non-compliant
centralized competitors. The NEX token will be an intriguing experiment for organic community growth.
Token holders will legally accumulate dividends through Nash’s trading revenue, which could trigger a
cascading effect for Nash user growth: the more user traffic a NEX staker helps generate, the more that
staker profits.
While this document is more focused on their crypto exchange, it should build investor confidence
knowing the Nash team is meticulously planning for a long-term future beyond just crypto. Nash is
rolling out several additional pillars such as Nash Pay — which seeks to be a Venmo equivalent that
integrates directly into the exchange — as well as a listing platform for registered security tokens to
compete with the likes of tZero and other popular security token exchanges.
The ultimate irony of today’s crypto exchanges is the customers they profit off of champion the
blockchain and self-custody, yet these exchanges do not leverage blockchain technology to help run
their core infrastructure. In contrast, Nash looks to be the first exchange that actually leverages
As the Nash exchange makes themselves available to the public on August 23rd, 2019, Arturo
capital looks forward to watching this platform launch and participating in this progressive decentralized
ecosystem. Success or failure, crypto is long overdue for a highly innovative and legally compliant
exchange platform.
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