Bullish

What they do

Bullish operates a digital asset exchange that records transaction fee income from peer-to-peer spot trades, holding and lending digital assets, and investing in financial assets. It holds customer and proprietary balances in stablecoins such as USDC, USDG and PYUSD, and it has loan and receivable arrangements including with related parties. The group was formerly associated with block.one, and related-party borrowings carry a 7% annual rate and are repayable on demand.

Revenue drivers

• Exchange transaction fees — The Exchange recorded $1.8 million of transaction fee income from peer-to-peer spot trades for the year ended December 31, 2025, up from $1.6 million in 2024 and $0.1 million in 2023.
• Digital asset holdings and interest income — The group holds digital assets including USDC ($613.9 million), USDG ($204.3 million) and PYUSD ($161.1 million) as of December 31, 2025; income statements include interest income of $14.8 million in 2025, $12.3 million in 2024 and $12.0 million in 2023, with $65.7 million of interest income from non-customers in 2025.
• Wrapped and other token holdings — BTC and ETH balances include wrapped tokens such as cbBTC (6,236 units valued at $552.9 million at December 31, 2025), wBTC (227 units valued at $20.1 million) and weETH (160.6 units valued at $0.5 million).
• Related-party lending and receivables — Outstanding balances with related parties, formerly parent block.one and subsidiaries, are unsecured, bear interest at 7% per annum and are repayable on demand.

Recent performance

For the year ended December 31, 2025, the Exchange recorded $1.8 million of transaction fee income from peer-to-peer spot trades versus $1.6 million in 2024 and $0.1 million in 2023. Interest income was $14.8 million in 2025, $12.3 million in 2024 and $12.0 million in 2023, including $65.7 million in 2025 from non-customers. As of December 31, 2025, the largest digital asset balances were USDC at $613.9 million, USDG at $204.3 million and PYUSD at $161.1 million, compared with USDC at $127.9 million, SUSDE at $51.3 million and USDT at $19.7 million at December 31, 2024. Amortization of acquired customer relationships and trademarks was $2.2 million in 2025, $2.3 million in 2024 and zero in 2023.

Strategy

The filing shows continued operation of the exchange and management of a digital asset portfolio, with a focus on stablecoin and wrapped-token holdings. In July 2025 the group assigned an office lease in its entirety to an entity controlled by its major shareholder and director for no consideration, terminating a 2024 service agreement and releasing the group from a related lease guarantee. Related-party loan obligations originated with block.one in 2023 and were later transferred to a block.one subsidiary whose majority shares were transferred to certain major shareholders, making the counterparty a related party. The audit committee receives quarterly cybersecurity updates from management and annual updates from the Chief Information Security Officer, who has over 25 years of experience in information security, digital transformation and enterprise risk management.

Risks

• Related-party concentration — Borrowings and transactions are with entities connected to the former parent block.one and its major shareholders, including a 7% interest-bearing, on-demand balance.
• Digital asset price and stablecoin exposure — A large share of assets is held in digital assets and stablecoins such as USDC, USDG and PYUSD, whose values and liquidity can change materially.
• Low exchange fee base — Exchange transaction fee income from peer-to-peer spot trades was only $1.8 million in 2025, indicating a small revenue base relative to the asset holdings.
• Cybersecurity and operational risk — The company relies on internal personnel and external consultants and its Audit Committee receives quarterly cybersecurity updates, indicating cyber threats are a material risk area.

Outlook

The filing does not provide forward guidance. It discloses continued related-party arrangements, including on-demand 7% borrowings and the completed office lease assignment in July 2025, and describes ongoing cybersecurity oversight by the Audit Committee and the Chief Information Security Officer.