Algorithmic Gatekeeping in Crypto Markets: Governing AI Driven Market Access in Centralized Exchange

Waqar Ahmad; Awais Amjad; Mohammad Salman Iqbal

doi:10.55524/ijircst.2025.13.6.18

Abstract

Centralized crypto exchanges increasingly govern market access through AI-dominated, vendor-supplied infrastructure that performs core gatekeeping functions, including transaction surveillance, risk scoring, listing and delisting decisions, and account restrictions. These systems exercise authority comparable to that of regulated financial intermediaries yet operate within a fragmented U.S. regulatory landscape in which jurisdictional uncertainty, enforcement constraints, and reliance on case-by-case litigation have limited the development of binding oversight. This paper argues that the resulting governance gap is primarily a consequence of the absence of institutional frameworks capable of disciplining automated market access as infrastructure. Drawing on recent enforcement actions, vendor concentration practices, and comparative analysis of the European Union’s Digital Operational Resilience Act (DORA), the paper demonstrates that effective governance of opaque, automated infrastructure is possible and already implemented in other countries through procedural accountability, documentation, and human oversight, rather than technical explainability. The paper contributes a DORA-inspired governance framework focused on internal controls, auditability, and clearly assigned human responsibility for AI-mediated decision-making within centralized exchanges. The analysis does not seek to resolve underlying classification disputes but instead identifies the legal and institutional conditions under which automated gatekeeping could be brought within a regime of enforceable oversight.

Keywords

Algorithmic Governance, Centralized Crypto Exchanges, Digital Market Access, Financial Infrastructure, Risk-Scoring Systems

References

Chainalysis, “Chainalysis,” Chainalysis, 2025. Available from: https://www.chainalysis.com/
S. Hägele, “Centralized exchanges vs. decentralized exchanges in cryptocurrency markets: A systematic literature review,” Electronic Markets, vol. 34, art. no. 33, 2024. Available from: https://link.springer.com/article/10.1007/s12525-024-00714-2
U.S. Securities and Exchange Commission, “SEC v. Bittrex, Inc. and Bittrex Global GmbH, Complaint,” Comp. No. 3:23-cv-04495, United States District Court for the Northern District of California, Aug. 28, 2023.
H. S. Suresh and J. V. Guttag, “A framework for understanding sources of harm throughout the machine learning life cycle,” arXiv preprint, Jan. 2019. Available from: https://doi.org/10.1145/3465416.3483305
European Union, “Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector,” Official Journal of the European Union, Dec. 2022. Available from: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5525144
R. Böhme, N. Christin, B. Edelman, and T. Moore, “Bitcoin: Economics, technology, and governance,” Journal of Economic Perspectives, vol. 29, no. 2, pp. 213–238, 2015. Available from: https://www.aeaweb.org/articles?id=10.1257/jep.29.2.213
N. Gandal, J. T. Hamrick, T. Moore, and T. Oberman, “Price manipulation in the bitcoin ecosystem,” Journal of Monetary Economics, vol. 95, pp. 86–96, 2018. Available from: https://doi.org/10.1016/j.jmoneco.2017.12.004
A. Kirilenko and A. W. Lo, “Moore’s Law versus Murphy’s Law: Algorithmic trading and its discontents,” Journal of Economic Perspectives, vol. 27, no. 2, pp. 51–72, 2013. Available from: https://www.aeaweb.org/articles?id=10.1257/jep.27.2.51
Raun, B. Estermann, L. Zhou, K. Qin, R. Wattenhofer, A. Gervais, and Y. Wang, “Leveraging machine learning for bidding strategies in miner extractable value (MEV) auctions,” IACR Cryptology ePrint Archive, Report 2023/1281, 2023. Available from: https://eprint.iacr.org/2023/1281
M. Harlev, H. S. Yin, K. C. Langenheldt, R. R. Mukkamala, and R. K. Vatrapu, “Breaking bad: De-anonymizing entity types on the bitcoin blockchain using supervised machine learning,” in Proc. 51st Hawaii Int. Conf. on System Sciences (HICSS), Jan. 2018, pp. 1–10. Available from: https://tinyurl.com/2fhxbt6a
G.-G. S. Fletcher and M. M. Le, “The future of AI accountability in the financial markets,” Journal of Entertainment and Technology Law, vol. 24, pp. 14–36, 2021. Available from: https://tinyurl.com/4hwvehat
U.S. Securities and Exchange Commission, “Framework for ‘Investment Contract’ Analysis of Digital Assets,” Apr. 3, 2019. Available from: https://tinyurl.com/aarehn88
SEC v. W. J. Howey Co., 328 U.S. 293 (1946). Available from: https://supreme.justia.com/cases/federal/us/328/293/
S. Nakamoto, “Bitcoin: A peer-to-peer electronic cash system,” White paper, 2008. Available from: https://tinyurl.com/5d58c2b8
V. Buterin, “Ethereum: A next-generation smart contract and decentralized application platform,” White paper, 2014. Available from: https://tinyurl.com/ye2936cd
U.S. Congress, “Securities Exchange Act of 1934,” 15 U.S.C. § 78a et seq., 1934. Available from: https://www.jstor.org/stable/791859
P. Saggese, “Arbitrage in the bitcoin ecosystem: An investigation of the Mt. Gox exchange platform,” Ph.D. dissertation, IMT School for Advanced Studies Lucca, Italy, 2021. Available from: http://e-theses.imtlucca.it/329/
S. Foley, W. Krekel, V. Mollica, and J. Svec, “Not so fast: Identifying and remediating slow and imprecise cryptocurrency exchange data,” Finance Research Letters, vol. 51, art. no. 103401, Jan. 2023. Available from: https://doi.org/10.1016/j.frl.2022.103401
Coinbase, “Exchange matching engine,” Coinbase Documentation, 2025. Available from: https://docs.cdp.coinbase.com/exchange/concepts/matching-engine
U.S. Securities and Exchange Commission, “SEC v. Binance Holdings Ltd., BAM Trading Services Inc., and Changpeng Zhao, Complaint,” Comp. No. 1:23-cv-01599, United States District Court for the District of Columbia, June 5, 2023.
U.S. Securities and Exchange Commission, “SEC v. Coinbase, Inc., Complaint,” Comp. No. 1:23-cv-04738, United States District Court for the Southern District of New York, June 6, 2023.
W. Liang et al., “AI and blockchain for AML: A policy and technology convergence to combat crypto-enabled financial crimes,” pp. 3–20, June 4, 2025. Available from: https://tinyurl.com/469revpz
R. Mafrur, “AI-based crypto tokens: The illusion of decentralized AI?” IET Blockchain, vol. 5, no. 1, 2025. Available from: https://doi.org/10.1049/blc2.70015
Board of Governors of the Federal Reserve System, “Supervisory guidance on model risk management (SR 11-7),” Apr. 4, 2011. Available from: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3332484
H. Yue, “Regulating crypto money laundering: An assessment of current regulatory responses and potentials for technology-based solutions,” Stanford Journal of Blockchain Law & Policy, June 30, 2025. Available from: https://stanford-jblp.pubpub.org/pub/crypto-laundering/release/1
McKinsey & Company, “The stable door opens: How tokenized cash enables next-gen payments,” May 20, 2025. Available from: https://tinyurl.com/3p658ebk
Chainalysis, “2025 Crypto Crime Report,” 2025. Available from: https://go.chainalysis.com/2025-Crypto-Crime-Report.html
Elliptic, “Typologies Report 2024: Preventing financial crime in crypto assets,” 2024. Available from: https://www.elliptic.co/resources/elliptic-typologies-report-2024
Wright, Executive Brief: Chainalysis, Forrester Research, Aug. 15, 2025. Available from: https://www.fourester.com/fourester/executive-brief-chainalysis
Chainalysis, “Reactor: Crypto & blockchain investigations,” 2025. Available from: https://www.chainalysis.com/product/reactor/
TRM Labs, Global Crypto Policy Review & Outlook 2025/26, Dec. 3, 2025. Available from: https://tinyurl.com/mty7kytt
Elliptic, “Elliptic expands coverage to over 97% of all cryptoassets,” May 20, 2020. Available from: https://www.elliptic.co/media-center/elliptic-expands-coverage
Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency, “Interagency guidance on third-party relationships: Risk management,” June 7, 2023. Available from: https://www.federalreserve.gov/supervisionreg/srletters/sr2304a1.pdf
Bank Secrecy Act, 31 U.S.C. §§ 5311–5336, 1970. Available from: https://tinyurl.com/9wva67a9
U.S. Department of Justice, “Binance and CEO plead guilty to federal charges in $4B resolution,” Nov. 21, 2023. Available from: https://tinyurl.com/478zrxd8
Algorithmic Accountability Act of 2022, S. 3572, 117th Cong., 2022. Available from: https://www.congress.gov/bill/117th-congress/senate-bill/3572
White House Office of Science and Technology Policy, Blueprint for an AI Bill of Rights: Making Automated Systems Work for the American People, Oct. 2022.
J. Trump, “Executive Order 14178—Strengthening American leadership in digital financial technology,” Jan. 23, 2025. Available from: https://tinyurl.com/bdfz2669
S. Campbell and R. Taylor, “Crypto exchange Coinbase fined €21.5mn by Ireland’s central bank,” Financial Times, Nov. 6, 2025. Available from: https://www.ft.com/content/21f15153-5f72-4860-97be-74b6c1ad0a60
Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-assets (MiCA), Official Journal of the European Union, OJ L 150, June 9, 2023.
Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency, “Final interagency guidance on third-party relationships: Risk management,” Federal Register, vol. 88, no. 111, June 9, 2023. Available from: https://tinyurl.com/2kme9wj4
Financial Conduct Authority, “Algorithmic trading compliance in wholesale markets: Multi-firm review,” 2024.
Australian Securities and Investments Commission, Report 798: ASIC review of automated advice providers, Oct. 29, 2024. Available from: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5040343

Cites this article as

W. Ahmad, A. Amjad, M. S. Iqbal, "Algorithmic Gatekeeping in Crypto Markets: Governing AI Driven Market Access in Centralized Exchange", International Journal of Innovative Research in Computer Science and Technology (IJIRCST), Vol-13, Issue-6, Page No-169-186, 2025. Available from: https://doi.org/10.55524/ijircst.2025.13.6.18

Corresponding Author

Waqar Ahmad

LLM Scholar, Penn State Dickinson Law, The Pennsylvania State University, Carlisle, PA, USA

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