After bringing cutting-edge models into the regulatory spotlight with the SB53 in California, it is not the legislators driving stricter rules, but the regulated entities themselves. Recently, on a Tuesday, Chan Park, who is in charge of U.S. and Canadian policy and partnerships at OpenAI, sent a letter to Governor Gavin Newsom, publicly supporting the strengthening of AI safety regulations while directly calling for an additional layer of "hard constraints" on top of the transparency requirements of SB53: the establishment of a shutdown mechanism for high-risk models, mandatory annual independent audits, and more stringent cybersecurity requirements to lock in operational boundaries. This means that not only OpenAI but all companies developing or deploying cutting-edge models in California must prepare for a "power switch" that can be activated at any time and third-party audit reports. Concurrently with the AI giants' proactive requests for regulation, there has been a regulatory retrogression in on-chain derivatives: Vladimir Novakovski, founder and CEO of the decentralized perpetual contract platform Lighter, announced that his team has communicated with CFTC staff and plans to formally submit applications for DCM and DCO licenses in November. If approved, this would embed licensed trading and clearing capabilities into Robinhood's services for U.S. users, becoming one of the few, if not the first, to attempt to obtain a U.S. compliance license as a Perp DEX. Cutting-edge AI companies, DeFi perpetual contract platforms, and Robinhood's U.S. users are being pushed into a new regulatory coordinate system: shifting from an industry consensus of "self-disclosure" and "self-restraint" to institutionalized regulation centered around shutdown switches, annual audits, and federal licenses. This compliance gate reinforced by leading players is likely to rewrite the basic operating rules of the tech and crypto industries in the coming years.
OpenAI Supports SB53 Upgrade: AI Companies Request Lockdown
SB53 is the artificial intelligence transparency bill passed in California in 2025, which has initially encased cutting-edge model companies in a layer of "shell": any enterprise developing or deploying cutting-edge models in California must publicly disclose its safety framework, regularly submit transparency reports, and proactively report significant security incidents. This is not a universal rule aimed at all software developers but specifically targets cutting-edge model developers like OpenAI and platforms relying on these models to operate in California, intending to bring the most unpredictable technical entities into a predictable compliance framework.
On this basis, Chan Park chose to write to Gavin Newsom on that Tuesday, urging further measures on SB53—not just "support for regulation" but a clear suggestion to introduce model shutdown mechanisms, mandatory annual independent audits, and stricter cybersecurity requirements, effectively tightening the lock even further. OpenAI did not position itself in opposition to regulation to lobby for relaxation of terms; instead, it bet on accepting constraints in advance to gain the qualification to participate in rule design: indicating to key decision-makers like Newsom that "leading companies are willing to be regulated" while establishing a demonstrative posture in the broader U.S. AI regulatory game, making it difficult for discussions at the state and federal levels to regress to "complete self-restraint." If SB53 is indeed upgraded as per OpenAI's recommendations, every cutting-edge model company operating in California and product platforms using these models would have to make institutional arrangements for shutdown switches, annual audits, and cybersecurity, meaning that leading enterprises would no longer just be regulated objects but would actively pull the entire cutting-edge model chain into a tougher compliance framework.
Shutdown Switch and Annual Audit: Raising the AI Safety Red Line
In Chan Park's letter, what is referred to as a "harder compliance framework" breaks down into three specific and cold components: first, requiring each cutting-edge model company to preset a "shutdown switch" that allows for the rapid termination of systems in the event of significant risk or security incidents, with the collaboration of regulatory and internal risk control, rather than just relying on post-event patches and public relations statements; second, making mandatory annual independent audits a routine obligation, to be conducted by third parties evaluating model training, deployment, monitoring, and incident handling mechanisms from safety and compliance perspectives, meaning companies must prepare traceable logs, permissions, and responsibility chains in advance for audits; third, elevating cybersecurity to a position equal to that of the models themselves, necessitating stricter protective measures to reduce systemic risks of attacks, misuse, or data breaches. The combination of these three tools does not merely add a few compliance clauses but forces companies at the technical architecture level to design "controllable, stoppable, and auditable" model infrastructures, pulling engineering decisions that originally favored efficiency and scale expansion back to a track of risk containment and feasible evidence collection, directly raising fixed costs and long-term compliance expenditures for cutting-edge model development and operation.
Once SB53 is upgraded under these recommendations, the impact will not be limited to OpenAI itself. According to the bill's applicability, any company developing or deploying cutting-edge models in California, as well as product platforms accessing these models, could potentially fall under the same regulatory scope. More and more crypto platforms are invoking AI capabilities in transaction facilitation, risk control scoring, and even customer service systems; if they are using such cutting-edge models or deploying relevant infrastructure in California, they may technically be required to preset the same shutdown mechanisms, undergo annual independent audits, and prove that their cybersecurity meets the new regulatory thresholds. For these crypto and AI integrated projects, compliance will no longer be merely displaying a "transparency report" at the front end, but will need to reserve regulatory cut-off interfaces for AI modules, audit-traceable data structures, and ongoing investments in security behind smart contracts and trading systems, with the deeper the cutting-edge models penetrate into transaction and risk control links, the greater the intensity and cost of these compliance transformations will become.
Lighter Applies for DCM/DCO: Contract Licensing
As cutting-edge models are required to reserve "regulatory switches," on-chain derivatives are also beginning to proactively integrate themselves into licensing frameworks. Lighter was originally positioned as a decentralized perpetual contract trading platform, with its core products being on-chain derivatives, but its founder and CEO Vladimir Novakovski publicly stated that the team is not continuing to hide in the compliance gray area doing purely on-chain matching, but is seeking dual licenses for DCM and DCO under the supervision of the U.S. Commodity Futures Trading Commission (CFTC), and has already communicated with CFTC staff about this plan to formally submit an application in November. For Lighter, this is not merely about "hanging a license" but to use the identity of a designated contract market (DCM) to absorb Robinhood's U.S. user traffic at the front end, and then use the identity of a derivatives clearing organization (DCO) to integrate on-chain settlement with traditional risk management, becoming the first to attempt to access the U.S. compliance system as a licensed Perp DEX, fighting for a position that can be "formally referenced" by mainstream brokerages.
Under the CFTC framework, a DCM means that you are no longer just an anonymous on-chain matching contract but must take on the role of an "exchange" to design contract rules and monitor trading behavior; a DCO consolidates clearing and margin management into a subject with responsible boundaries, demanding higher requirements for the platform's fund flows, risk control, and data retention. Once Lighter embarks on this path, it will have to accept constraints brought by licenses in terms of decentralization, user thresholds, and product iteration, but the reward is compliance access for U.S. users after integration with Robinhood, and a transformation in the project's identity from being simply classified as an "unregistered offshore contract platform." According to a single source report, after the relevant licensing news was announced, the LIT token recorded an approximately 15% increase in nearly 24 hours, indicating short-term price feedback from the market favoring this compliance path, but for other perpetual contract protocols, it is more like a mirror: whether to continue to insist on being completely on-chain, rejecting any licenses, or to accept the DCM/DCO regulatory identity like Lighter, trading some anonymity and freedom for deep compliance access to traditional platforms and local users, this balance between compliance and decentralization is now being laid on the table for the entire sector.
Robinhood Accesses U.S. Users: DeFi Regulatory Puzzle
Once Lighter secures DCM and DCO licenses, its integration with Robinhood will likely be designed as a structure of "front-end brokerage and back-end on-chain": U.S. users will still place orders through existing Robinhood accounts and interfaces, fulfilling the role of a regulated online brokerage in the U.S., while actual contract matching and clearing will be handled in the background by the designated contract market and clearing organization under CFTC regulation—namely, the licensed Lighter. For regulators, this means that on top of the original securities and some derivatives regulations, an additional set of capital, risk management, and customer protection requirements will be layered upon DCM/DCO. Robinhood will present itself as the user entry and compliance KYC, while Lighter will be responsible for the on-chain perpetual contract market and clearing security, using the traditional account system as a shell, guiding U.S. retail investors directly into the deep waters of on-chain derivatives.
The real challenge lies in this "broker front-end + DeFi back-end" stitching, which makes the boundary of responsibility unprecedentedly vague: when a user clicks on a perpetual contract powered by Lighter, which provides the underlying liquidity and clearing, if risk control fails, margin mechanisms malfunction, or even if there are vulnerabilities in smart contracts, should the main responsibility lie with the broker regulated by securities, Robinhood, or with the DCM/DCO entity, Lighter, which is subject to CFTC regulation? Regulatory agencies must first provide executable delineation rules. For U.S. users, accessing such products through the Robinhood entrance is superficially covered by a complete set of capital and risk management requirements targeted at designated contract markets and clearing organizations by the CFTC, appearing to have more "regulatory endorsement" than directly accessing on-chain protocols. However, on the other hand, the high leverage nature of perpetual contracts and the technical risks of on-chain infrastructure still exist, and users may find themselves exposed to a new combination of cross-regulatory and cross-technical stack risks, thinking they are merely conducting a protected derivative transaction within the brokerage, while actually becoming vulnerable to a new set of risks and misunderstandings regarding responsibility will force regulatory agencies and platforms to redraw the specific boundaries of who is responsible for which types of risk.
AI and DeFi Walk the Compliance Road Together: From Self-Regulation to Being Regulated
From OpenAI's proactive request to include annual independent audits, model shutdown switches, and stricter cybersecurity into the enhanced version of SB53, to Lighter openly declaring its intention to obtain DCM and DCO licenses and connect with Robinhood while still in the preparatory communication stage, these two seemingly unrelated technical paths are pointing towards the same compliance direction: no longer relying on voluntary disclosures and "self-restraint" from enterprises, but directly placing businesses within a regulatory system characterized by licensed operations, mandatory audits, and clear red lines. SB53 has already taken effect in California, making the safety framework and incident reporting of cutting-edge model vendors transition from "best effort" to "must do," but how to specifically integrate shutdown mechanisms, audit metrics, and cybersecurity protection details is still dependent on subsequent legislation and regulatory procedures, which is one of the largest institutional variables for the AI industry in the coming years. Similarly, Lighter's DCM/DCO path currently relies only on preliminary communications with CFTC staff and plans to submit applications in November, with considerable uncertainty still existing regarding genuine approval and becoming a regulated designated contract market and clearing organization. Whether it can successfully navigate this path and whether it will incentivize more derivative agreements to follow suit in gaining licenses for traditional platform integration will ultimately shape the compliance landscape of DeFi. By around 2026, audits, shutdown mechanisms, and licensed trading are becoming new entry barriers for tech and crypto platforms, and further revisions of SB53, the results of Lighter's licensing decision, and whether other projects choose to continue navigating the gray area or line up for licenses will collectively determine how high and narrow these barriers will be.
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