Author: OKX Ventures

Introduction: Looking ahead, RWA Perps is not merely a shadow market comparable to Nasdaq or CME; it represents a fundamental restructuring of pricing power, global liquidity distribution, and risk transfer mechanisms.

In the third chapter of the previous article, we focused on analyzing projects such as Synthetix, Gains Network, and Ostium. This article will build upon that foundation and expand upon other representative case studies.

III. Representative Projects and Architecture Game Theory: Oracle Pricing + Pool-based Pricing vs. Order Book

3.3 Orderbook represents: Hyperliquid HIP-3 ecosystem

In the order book sector, the Hyperliquid HIP-3 ecosystem accounts for the vast majority of trading volume and open interest. Outside of the Hyperliquid ecosystem, platforms like Lighter and Vest Markets are also competing.

Data Source: https://dune.com/yandhii/rwa-perps

Hyperliquid & HIP-3: Decentralized Nasdaq Infrastructure

Hyperliquid has completed its strategic transformation from a single perpetual contract exchange to a "high-performance clearing and matching infrastructure layer" through the HIP-3 upgrade. Its core vision is to off-chain the functions of the Designated Contract Market (DCM) and Derivatives Clearing Organization (DCO) in traditional finance. Under this architecture, the Hyperliquid chain itself acts as a unified DCO, providing the underlying matching engine, risk control, and fund settlement; while third-party teams act as "deployers," assuming the role of the DCM, responsible for front-end customer acquisition, market operations, and asset listing. This layered design aims to create a "decentralized Nasdaq," supporting perpetual trading of various assets through a unified settlement layer.

The chart above summarizes Hyperliquid's response to the CFTC's concerns about perpetual contracts and 24/7 trading , highlighting its ambition to become "a more open, transparent, and efficient financial system ." For example, it demonstrates how blockchain technology can directly overcome the physical time lag and efficiency bottlenecks of traditional finance by replacing the traditional DCO's reliance on the banking system with a 24/7 automatic clearing protocol, eliminating cumbersome FCM intermediaries with non-custodial technology, and reconstructing the regulatory logic of DCM using real-time on-chain data.

HIP-3 Ecosystem RWA Perps Project

1. Project Overview

• Trade.xyz, built by HyperUnit, the asset layer team officially partnered with Hyperliquid, was the first to launch the XYZ100 perpetual contract tracking the Nasdaq 100 index, as well as several leading US tech stocks. With its rich asset bridging capabilities (supporting cross-chain liquidity injection for mainstream assets such as BTC, ETH, and SOL through HyperUnit), Trade.xyz currently leads all HIP-3 perpetual exchanges in trading volume, contributing approximately 90% of the market's trading volume.

• Markets.xyz is an RWA Perps Dex launched by the Kinetiq team, a Liquid Staking project on Hyperliquid. Markets differs slightly from Trade: it focuses on indices and offers various index/macro perpetual contracts (covering the S&P 500, US tech indices, Euro, US Treasury indices, energy indices, etc.). Another differentiator is the use of USDH as the margin denominated currency, which significantly reduces transaction fees and increases rebates, allowing it to compete with Trade at a cost advantage (USDH is a native Hyperliquid stablecoin issued by the Native Markets team, which has implemented fee reductions and rebate programs to compete with the cross-chain asset project Unit in terms of distribution).

• Felix initially emerged as Hyperliquid's lending and stablecoin protocol, issuing synthetic USD (feUSD) through CDPs and offering the "Felix Vanilla" lending market. Following the launch of HIP-3, Felix expanded its business, becoming one of the deployers in the HIP-3 perpetual market. Felix also uses the USDH stablecoin as its settlement currency.

• Dreamcash is a mobile-focused product developed and incubated by Beam, positioning itself as a mobile trading terminal for RWA perpetual contracts.

2. Core pricing mechanism: Market-driven pricing + oracle risk control

The core technical challenge of 24/7 RWA Perps projects built on the Orderbook model lies in providing a fair and stable price even when the underlying asset is closed for trading. Taking Trade, a leading project in the HIP-3 ecosystem, as an example, its core design relies on a dual-track mechanism of market pricing and oracle risk control.

• The core of price discovery: determined by the market, not oracles.

Unlike pool-based systems that directly use oracle quotes as transaction prices, Trade's transaction prices are entirely determined by the interplay between buyers and sellers in its order book. Oracles do not act as "pricing makers" here, but rather as "referees," with their prices primarily used for risk control.

• Price Tag: Used to calculate the profit and loss of a user's positions and to determine whether to liquidate.

The system's profit and loss calculations, funding rates, and forced liquidation do not use instantaneous transaction prices, but instead rely on a more robust mark price. Trade's mark price is generated by taking the median of the following three components: oracle price, long-term deviation from the mean, and real-time order book price. This design aims to smooth out market noise and prevent malicious manipulation, ensuring that user accounts are not mistakenly liquidated due to price flashes in the order book.

• Oracle data source switching during all trading hours: To achieve 24/7 operation, the oracle's data source will be seamlessly switched according to the US stock trading hours: During normal trading hours, external oracles such as Pyth are used; during night trading hours, the night trading price provided by ATS (alternative trading systems, such as Blue Ocean) is used; and the internal pricing mode is activated when the market is closed on weekends.

3.4 Ostium vs Trade: Pricing Logic and Oracle Role Comparison

Ostium prioritizes security and price accuracy, sacrificing some availability (unavailable on weekends). Trade prioritizes availability and game theory, sacrificing some price stability (potential for price decoupling or high funding rate fluctuations on weekends). The role of oracles also differs significantly between the two projects. In Ostium's pool-based model, oracles act as price setters (determining trades), while in Trade, oracles are referees (only influencing funding rates and deciding whether to liquidate, regardless of how trades are executed).

Chapter 4: Analysis of Regulatory Restrictions on RWA Perps

4.1 The core logic of US derivatives regulation: the nature of the underlying assets determines the compliance path

In the U.S. financial regulatory system, the first step in determining whether and how a derivative can be listed is to ascertain the legal nature of its underlying assets. This directly determines the jurisdiction of the regulator and, consequently, the type of license the exchange must obtain.

For assets such as gold, silver, foreign exchange (FX), and Bitcoin, U.S. law defines them as "commodities." Perpetual contracts based on these assets fall under the category of commodity futures, and their regulatory path is relatively straightforward and clear: they fall entirely under the jurisdiction of the Commodity Futures Trading Commission (CFTC). Exchanges only need to register as a Designated Contract Market (DCM) and connect to a Derivatives Clearing Organization (DCO) to conduct business.

However, the situation changes fundamentally once the underlying asset of perpetual contracts becomes a single stock or a narrow-based security index: derivatives involving a single security or a portfolio of a few securities must be subject to joint regulation by the SEC and the CFTC .

The requirement for joint regulation by both the SEC and CFTC is the primary reason why the US market still lacks compliant perpetual stock contracts. The background to this regulation dates back to a regulatory turf war between the SEC and CFTC in the 1980s: a battle for regulatory power over emerging stock futures contracts. The final solution was the Shad-Johnson Agreement signed in 1982, which abruptly banned trading of single-stock futures and narrow-based stock index futures on US exchanges, intended to prevent further friction between institutions. Although the Commodity Futures Modernization Act (CFMA) of 2000 amended this ban, allowing such contracts to be traded as "Security Futures Products," the conditions were extremely stringent: these products must be subject to dual regulation by the SEC and CFTC, becoming a fundamental legal obstacle to innovation in equity derivatives.

Any platform wishing to offer perpetual stock contracts to U.S. retail customers cannot hold only a single license; it must complete both of the following registrations simultaneously:

• Register with the CFTC as a Designated Contract Market (DCM) or Swap Execution Facility (SEF)

• Registered with the SEC as a national securities exchange

This means that platforms must simultaneously meet two sets of compliance standards set by different institutions, which may conflict in areas such as margin calculation, information disclosure, and transaction reporting. This extremely high compliance threshold and operating cost effectively constitute an "entry ban" on single-stock perpetual contracts, resulting in the near absence of compliant retail products of this kind in the United States.

4.2 Conflicts in Exchange Architecture: Why Compliance Migration Costs Are Extremely High

If exchanges in the United States, such as Coinbase and Robinhood, really want to list Equity Perps, in addition to facing the difficulties of obtaining the aforementioned legal licenses, they will also need to face architectural conflicts in the underlying infrastructure.

Cryptocurrency exchanges typically employ a vertically integrated, monolithic architecture, while US regulations require a three-tiered, risk-isolated structure. If cryptocurrency exchanges wish to comply with regulations, they must dismantle their existing, efficient technology stack to adapt to traditional financial clearing processes.

Comparative analysis of the market structure of Crypto and TradeFi:

Therefore, for a US exchange to list Equity Perps, it not only needs to resolve the legal issues of "dual licensing," but also the physical contradiction between "24/7 trading demand" and "non-24/7 bank settlement systems." This infrastructure mismatch is currently the biggest obstacle.

4.3 Window of Opportunity for Offshore Markets: Regulation S

Due to the difficulty in overcoming regulatory restrictions in the United States in the short term, the liquidity of the vast majority of stock perpetual contracts is squeezed into offshore markets. Offshore exchanges (serving non-US clients) typically obtain compliance exemptions under Regulation S of the US Securities Act. The core logic of this regulation is that as long as the issuance and sale of securities products occur entirely outside the United States, and the issuer does not engage in directed selling efforts against Americans, registration with the SEC is not required. This requires platforms to implement strict geofencing to block US IP addresses technically and to explicitly prohibit US users from using the platform in their legal terms.

Against this backdrop, RWA Perps Dex is entering a unique market window. They have the opportunity to establish a mutually beneficial business distribution model by partnering with traditional long-tail brokers in offshore regions.

The reciprocal model of CFD Broker + RWA Perps DEX: This collaboration may be attractive to traditional brokers. Compared to traditional CFD businesses, which are facing increasingly stringent regulations (such as the EU ESMA's restrictions on leverage), on-chain perpetual contracts often operate in a regulatory blind spot, offering higher leverage. More importantly, brokers only need to maintain front-end user relationships, while outsourcing complex margin management, clearing, and hedging to on-chain protocols (back-end), significantly reducing their back-end operating costs. Simultaneously, the self-custodial nature of DEXs addresses users' trust concerns regarding the misappropriation of funds by small and medium-sized brokers.

For Equity Perps Dex, this model solves the most challenging customer acquisition problem. Crypto-native users have relatively limited interest in US stock trading, while traditional brokers possess a large amount of genuine retail traffic seeking US stock exposure. By embedding itself as a broker in the technology backend, the DEX can maintain technological neutrality while compliant brokers handle KYC/AML processes on the front end, thus having the opportunity to break through the existing DeFi world and achieve scalable growth.

4.4 Potential Legal Risks

While offshore and DeFi models are commercially viable, the risk of "long-arm jurisdiction" by US regulators must be carefully considered. If offshore protocols cannot completely sever ties with US users at the technical and compliance levels (e.g., through front-end censorship or IP blocking), or if their business activities are deemed to involve the US market, they will still face severe regulatory penalties.

Chapter 5 External Variables: The Dual Impact of the NYSE 24/7 Plan

The news that ICE, the parent company of the New York Stock Exchange (NYSE), plans to launch a 24/7 trading market constitutes the biggest external variable for the RWA perpetual contract sector. If this change comes to fruition, it will have a profound dual impact on DeFi. If users can legally and securely trade Tesla stock 24/7 on a regulated NYSE or Interactive Brokers, the "24/7 trading" advantage upon which DeFi protocols rely may be affected. At that point, DeFi may need to find new value propositions, such as higher leverage, permissionless access mechanisms, or complex financial products built on composability, to survive in direct competition with traditional financial giants.

Core Driving Force and Mechanism Innovation: From "T+2" to "On-Chain 24/7"

The NYSE's planned 24/7 trading platform aims to leverage blockchain technology for tokenized trading of US stocks and ETFs. Its core innovation lies in breaking down the traditional stock market's separation of trading and settlement through stablecoin deposits, instant clearing and settlement (T+0), and multi-chain custody, eliminating settlement risks exposed in events like GameStop. This move is a strategic defense by the NYSE against competition from Nasdaq and other peers, and to meet the global capital market's demand for 24/7 liquidity. It signifies that traditional exchanges are evolving from "electronic order books" to "fully on-chain infrastructure," attempting to integrate the efficiency advantages of DeFi under the highest regulatory standards.

Catalysts and Challenges for the RWA Ecosystem: The End of the Liquidity Bottleneck

The entry of the NYSE provides top-tier endorsement for RWA tokenization, resolving the "liquidity crunch" and "pricing gap" caused by traditional market closures on weekends. For the RWA perpetual contract market, 24/7 spot price flow will significantly reduce arbitrage costs and funding rate volatility, improving market depth. While the NYSE's compliant "walled garden" model may squeeze the survival space of some non-compliant and synthetic asset projects, it also points the way for compliant stablecoins and clearing facilities. Crypto-native RWA projects need to take advantage of the window of opportunity before 2026 to complement or compete with traditional giants through differentiated positioning (such as high leverage, no barriers to entry, and cross-protocol interoperability).

Future Landscape Outlook: Deep Integration of Traditional and Crypto Finance

Despite ongoing debate within the crypto community regarding the investment pressure and regulatory oversight associated with 24/7 monitoring, the shift of finance to blockchain is an irreversible trend. In the medium to long term, the involvement of traditional giants will reshape the value chain, forcing intermediaries such as securities firms and custodians to transform. The future market will evolve into a competitive yet coexisting ecosystem: compliant platforms like the NYSE will provide highly reliable underlying spot liquidity, while DeFi protocols will continue to offer flexibility in innovative derivatives and global asset allocation. As the boundaries between crypto and traditional assets blur, global capital markets will enter a new era driven by AI, featuring real-time pricing and atomic settlement.

Summarize

• A structural upgrade in demand for Delta One (linear derivatives). Currently, retail traders often rely on inefficient trading instruments when seeking directional leverage. In the US, 0DTE (End-of-Term Options) subject purely directional bets to unnecessary Theta (time value) decay; while the $30 trillion offshore CFD (Contracts for Difference) market suffers from opaque brokerage mechanisms and counterparty risk. RWA perpetual contracts completely eliminate time decay and centralized risk, providing a transparent, mathematically linear on-chain alternative to this real market demand.

• Architectural Trade-offs in Asynchronous Markets. Connecting 24/7 crypto infrastructure to traditional markets constrained by physical trading hours forces protocols to compromise between high leverage, continuous trading, and externalized risk. To address traditional market closures, two distinct models have evolved: Ostium's proactive hedging liquidity pools prioritize solvency, eliminating gap risk entirely by suspending trading during market closures; while Trade.xyz (based on Hyperliquid) maintains 24/7 uninterrupted trading by translating weekend volatility risk into dynamic funding rates and market maker spreads.

• Offshore Distribution Strategy. Given the dual jurisdiction of the SEC and CFTC, launching compliant perpetual stock contracts for retail investors within the US is currently unrealistic. Therefore, RWA Perps' early core growth engine will rely on markets outside the US (through the Regulation S exemption). In terms of distribution, RWA Perps Dex may explore partnerships with traditional CFD brokers in the future. Instead of directly acquiring retail investors at the front end, it could act as a "back-end clearing engine" for regional offshore brokers to achieve scalability—outsourcing KYC and front-end customer acquisition to traditional financial entities while focusing on on-chain margin management and atomic settlement.

• Adapting to 24/7 traditional financial infrastructure. Traditional institutions like the NYSE are pushing for continuous trading in US stocks, which could soon break DeFi's monopoly on "24/7 trading." While this change could completely eliminate weekend price gaps for on-chain protocols, it also forces DeFi to diversify its competitive strategies. In the long run, RWA perpetual contracts must differentiate themselves in areas such as permissionless access, capital efficiency, and higher leverage, ultimately evolving into a "high-speed execution layer" built on top of regulated traditional spot markets.

Looking ahead, RWA Perps is not merely a shadow market mirroring Nasdaq or CME; it represents a fundamental restructuring of pricing power, global liquidity distribution, and risk transfer mechanisms. With the continuous improvement of liquidity infrastructure, it will become the optimal container for global leverage demand to flow onto the blockchain.

BitMEX前CEO Alexander Höptner起诉前雇主非法解雇

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