Run your own memo
Real deck · named companyPublished 2026-09-09

FTX

This memo was written from the 2021 deck and the sources available then. Nothing that happened later was used.

Verdict

PASS

Confidence · Highnothing here reopens it

Custody opacity is the dealbreaker.

The deck discloses no custody mechanics and no round terms. At $14.7B average daily volume, the absence of any statement on whether customer assets are segregated from FTX operating capital is the central risk, not a diligence footnote, and no investor can responsibly commit capital without audited proof of segregation and a term sheet.

StageGrowth
SectorFintech / Cryptocurrency Exchange
MarketNot established

Why this stage

  • ·FTX is raising as an established, high-growth crypto exchange with $1.2B annualized run rate, $14.7B average daily volume, and $800M estimated profit in 2021.
  • ·The deck does not state a specific round name or amount being raised, so stage is inferred from the company's demonstrated scale: 75.2x growth in volume between start of 2020 and May 2021, fourth-largest crypto exchange globally by volume, and a team of 75+ employees.
  • ·This is a late-stage growth company, not an early-stage raise.

The one blocker

Customer funds segregation never disclosed.

Grades

4 axes
B+7/10Unicorn opportunity

FTX's $1.2B ARR and fourth-largest global exchange ranking establish a credible large-outcome trajectory, but the category does not concentrate on a single winner, Binance's dominance and Coinbase's regulatory moat in the US mean the market splits rather than tips.

What moves this grade

The grade would move to 9 if FTX US achieves full derivatives licensing and begins compounding the retail-to-institutional flywheel in the largest single market.

the evidence
  • The revenue scale is real and the growth rate is extraordinary: 75.2x volume growth between start of 2020 and May 2021 during the most sustained crypto bull run in history.
  • The $18B Series B valuation set a credible institutional price anchor.
  • The ceiling question is whether crypto exchange economics concentrate on one winner or sustain a multi-player oligopoly.
  • The evidence in 2021 points to the latter: Binance, OKEx, Huobi, and Coinbase all operate at scale simultaneously, and FTX's cross-margining differentiation is a product advantage, not a network-effect lock-in that tips the market.
  • A unicorn outcome is clearly reachable on the trajectory shown; a category-defining winner-take-most outcome requires either Binance's regulatory collapse or a US market entry that FTX.com currently blocks.
A8/10Capital efficiency

A $1.2B annualized revenue run rate and $800M estimated profit achieved with a 75-person team implies a revenue-per-employee ratio that is materially above any public exchange comparable at this stage, though the profit figure is unaudited.

What moves this grade

A Big Four audit confirming the margin profile would move this to 9.

the evidence
  • The implied operating cost of approximately $400M (derived) for a 75-person global exchange operation is at the high end of efficiency for the category, CME Group and ICE both run at lower revenue-per-employee ratios at comparable revenue scales.
  • The Blockfolio acquisition at $150M was a capital deployment that bought a 6M+ user retail distribution channel rather than building one from scratch, which is an efficient use of capital for the milestone it purchased.
  • The grade is capped at 8 rather than 9 because the profit figure is explicitly approximate and the operating cost structure is not disclosed line by line, so the efficiency claim cannot be fully verified.
A9/10Team velocity

Sam Bankman-Fried and Gary Wang built Alameda Research as a functioning market maker before founding FTX in 2019, then scaled from $50M ADV in the first few months to $14.7B ADV by 2021, a build-and-scale arc that is among the fastest in the exchange category.

the full reasoning
  • The founding arc is the strongest signal on this axis: the team identified exchange infrastructure gaps from the inside as market makers, then built the exchange to fill them.
  • Gary Wang's Google Flights low-latency systems background is directly applicable to order-book matching at scale.
  • Nishad Singh's Facebook Applied Machine Learning background and Ramnik Arora's Facebook Libra co-authorship add product and ML depth.
  • The pace of product launches in 2021 alone, options, sportsbook, prediction markets, tokenized equities, spot margin, is evidence of a team that ships rather than plans.
  • The one constraint on a 10 is that the team's velocity has been demonstrated in a bull market with abundant capital; how the same team performs under resource constraint is untested.
B5/10Moat durability

The cross-margining wallet is a genuine product differentiator that creates real switching costs for sophisticated traders, but it is an engineering advantage rather than a structural lock-in, and a well-funded competitor with the will to build it could reach parity within 12-18 months.

What moves this grade

The moat would move to 7 if FTX demonstrates that the cross-margining wallet produces measurable retention lift in cohort data, evidence that switching costs are real rather than theoretical.

the evidence
  • The claimed advantages, unified margin account, compliance positioning, Blockfolio distribution, are real but sit in different durability tiers.
  • The compliance positioning relative to Chinese-founded incumbents is the most durable: Western regulatory relationships take years to build and the CFTC-regulated West Realm entity is a live credential.
  • The cross-margining wallet is durable against exchanges that have not built it, but Coinbase has the engineering talent and capital to replicate it, and Binance has the volume to make any product feature irrelevant for price-sensitive traders.
  • The Blockfolio distribution is the least durable: it is a channel, not a product moat, and any exchange willing to acquire a portfolio-tracking app can replicate it.

Flags

3 flags · 1 critical
01

Deck does not disclose the current funding round being raised: no round name, amount, valuation, or investor information provided.

02

Slide 3 states $800M estimated profit in 2021 with asterisk noting 'numbers are approximate, based on recent performance. They do not incorporate any additional growth.' This qualifier undermines the precision of the headline traction figures.

03

Deck claims FTX is the 'fourth largest crypto exchange' globally by volume (slide 2) but also 'largest non-Chinese crypto exchange' (slide 2). These two claims are consistent only if three of the top four exchanges are Chinese, which is not verified in the deck.

Do next

Pass pending audited financials and custody proof.

Audited financials confirming the $800M profit figure, a written proof of customer fund segregation from a Big Four auditor, and a term sheet with round size and governance terms would reopen this as an Invest conversation.

The full memo

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