🚨 SEC Commissioner and crypto advocate Hester Peirce stated: Any Layer 2 that relies on centralized sequencers may be classified as an "exchange" by the SEC.

The core logic is simple—what it's called doesn't matter; the key is its actual function. If the matching engine and transaction ordering are controlled by a single entity, then it is no different from a traditional exchange.

In the past few years, to combat MEV and improve efficiency, most L2s have chosen centralized sequencers. While issues like front-running and sandwich attacks have been alleviated, this has left a compliance risk of single-point accountability.

So if this issue is formally brought up for regulation, L2s will have only two paths:

1️⃣ Either register obediently, acknowledge that they are exchanges, and accept a complete compliance framework;

2️⃣ Or dismantle single-point control, moving towards multi-signature, ordering networks, or other trust-minimized solutions.

Currently, the L2s that completely rely on centralized sequencers are:

Arbitrum (single Arbitrum Sequencer node)

Optimism (single block producer)

Base (single Coinbase Sequencer node)

Linea (centralized sequencer based on Besu)

Starknet (single sequencer)

Projects that have achieved decentralization:

Metis (the first Layer 2 to operate a decentralized sequencer)

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