Author: Ada, Shen Chao TechFlow

In the early hours of April 14, CoinDesk released a personnel news item in an inconspicuous position.

Tom Duff Gordon, Vice President of International Policy at Coinbase, left for OpenAI to serve as Head of EMEA Policy.

In the trending topics of the Twitter crypto circle, this news stayed for less than half a day. Compared to the news on the same day about a major XRP holder dumping over a hundred million dollars into Coinbase, it seemed too quiet.

But quiet news is sometimes truly worth reading.

Because it signifies a class of people starting to move.

Why leave?

Looking at Gordon's resume, the information it contains is far more substantial than the several hundred words in CoinDesk's article.

He spent eight and a half years at Credit Suisse, then four years at Coinbase, recently jumping to OpenAI. From traditional finance to crypto, then to AI. Each job change marked a new inflection point on the industry's curve.

Gordon entered Coinbase around 2021, when MiCA was just being drafted in Brussels, the UK's FCA's registration system for crypto assets was just starting, and the entire Europe had a blank slate on how to regulate "digital assets." Coinbase needed someone who understood investment banking compliance and could enjoy afternoon tea in the City of London to sketch this blank slate out carefully.

Gordon was the right choice. He had been frequently dealing with regulators at Credit Suisse; the habits, tone, and rhythm were consistent.

Leaving Coinbase for OpenAI in April 2026 is also not a random timing.

The EU AI Act had just been enacted, the first batch of penalties had not yet been issued, and the localized implementation rules were still being negotiated among the countries. Although former UK Deputy Prime Minister Nick Clegg and former Chancellor of the Exchequer George Osborne are no longer key political figures, their contact lists are still useful, and the people who use those contacts are switching tracks.

Gordon left at this moment because the policy wars at Coinbase had concluded.

In 2023, the SEC sued Coinbase for operating an unregistered securities exchange, in 2024 the United States Court of Appeals for the Third Circuit accepted the appeal, on January 21, 2025, the new SEC formed a crypto task force, and on February 27, 2025, the SEC withdrew the lawsuit.

Two years were spent transitioning from the strictest regulatory adversaries to handshakes and reconciliation.

Chief Legal Officer Paul Grewal wrote a sentence in a company blog in January 2026, implying that 2025 was a "milestone year" for Coinbase's market business. In other words, the main battlefield of the policy war was no longer in the United States.

The European front that Gordon was responsible for was also nearing its end. MiCA will take effect in phases by the end of 2024, with 2025 being the implementation period for exchanges to obtain licenses and register locally. This is the work of compliance lawyers and localization teams, not the playground of a vice president-level policy lobbyist.

The value of a policy lobbyist is highest during a regulatory vacuum, but plummets during the regulatory implementation phase.

Gordon is not an isolated case. In the past two years, several people have left Coinbase's policy and legal lines. During the 20% layoffs in 2023, at least twenty people were cut from the legal and compliance line. The people who left in the last two years were at higher levels, most of whom were not laid off but left voluntarily.

The reason for leaving voluntarily is not a secret in the circle: because alpha returns have disappeared.

During the regulatory vacuum from 2021 to 2024, a policy expert knowledgeable in crypto equaled someone who could simultaneously write memos for exchanges, VCs, issuers, and project parties. A sentence in an email like "I spoke with FCA yesterday" could open a new round of financing or a collaboration.

But today this statement is no longer valuable. The FCA's stance is public information, EU regulatory bodies hold weekly press conferences, and the information gap on crypto compliance has been smoothed out.

Meanwhile, in AI, the information gap is at its widest.

Replicating Coinbase

In October 2024, OpenAI tweeted that it would open new offices in New York, Seattle, Paris, Brussels, and Singapore. On April 13, 2026, just a day before Gordon's departure news came out, OpenAI announced the further expansion of its London branch, positioning London as one of the most important hubs outside of the US.

When these two pieces of news are viewed together, the script becomes clear.

Currently, OpenAI's recruitment page has been advertising the position of Head of Global Affairs for EMEA for over six months, requiring "over 15 years of experience in government, international affairs, and technology policy," and clearly stating the need to "establish credibility and a network of relationships with EU institutions and regulators, as well as governments of various countries."

Gordon's resume perfectly matches this job description.

According to an earlier report by the Financial Times, OpenAI plans to expand its workforce from 4,500 to 8,000 by the end of 2026, hiring an average of 12 people per day. Policy and government affairs are one of the key focus areas. In January this year, OpenAI officially announced the "OpenAI for Europe" plan, intending to cover education, healthcare, cybersecurity, and disaster response within its lobbying scope.

What this implies is: OpenAI aims to do more in Europe than just sell the enterprise version of ChatGPT; it seeks to deeply engage in each area that might be legislated against, proactively setting the table.

In 2021, Coinbase was doing the same thing in Europe.

It’s just that back then it was about crypto; now it’s about general artificial intelligence.

The Value of Gordon

There is a saying in the crypto circle called "regulatory arbitrage." It means leveraging regulatory differences across regions, fields, and time points to find loopholes in rules and turn arbitrage opportunities into business.

Binance was registered in Malta, FTX chose the Bahamas, and Tether moved to the British Virgin Islands, all are textbook examples of regulatory arbitrage.

Behind the business of regulatory arbitrage, there is a hidden profession: the lobbying experts behind the arbitragers.

They do not engage in arbitrage directly; they convert "gaps" into "compliance narratives." They translate the actual operations of an exchange into language that regulatory officials can accept; they convert a regulatory official’s concerns into business compromises that a company can accept.

This work requires three things: first, muscle memory of the internal decision-making processes of regulatory agencies; second, technological understanding of the industry; and third, networking.

People like Gordon sell these three things.

Technological understanding is actually the least valuable among them. There is no underlying technological overlap between crypto and AI, but that does not matter; they do not need to understand technology. What they need to know is which officials are sensitive to which types of issues, which legislators are up for reelection this year, and which industry association chairs will make statements at some summit next month.

This knowledge is highly transferable between the crypto and AI sectors. The people in the EU who were responsible for drafting MiCA are today drafting the local implementation rules for the AI Act.

In other words, what Gordon needs to relearn by moving from Coinbase to OpenAI is much less than what ordinary people might imagine.

But the real value lies in those few hundred contacts in his phonebook that won't show up on LinkedIn.

Coinbase still needs policy talent today. But what it needs are localized compliance managers, execution-oriented roles that can implement the MiCA texts step by step, and litigation lawyers who can handle the aftermath of the second SEC investigation.

It no longer requires a vice president-level public relations-style lobbyist who can drink with top politicians in Brussels, London, and Paris.

This is not just Coinbase's situation. Look at the current market for the crypto industry: Circle has dropped from its peak of $298 after listing to $98, Bullish has fallen from $118 to $38, Kraken has secretly applied, but its IPO plan is currently on hold; from the secondary market prices, the market's valuation expectations have dropped below the $20 billion valuation from the last round of financing. BitGo, on its third trading day after listing, has already given up all gains made on its first day and has dipped below the IPO issuance price.

When the valuation logic of an industry shifts from "narrative premium" to "cash flow discount," its talent demand will also switch accordingly.

The narrative premium period for the crypto industry likely lasted from 2020 to 2025. During these five years, a knowledgeable vice president in regulation could simultaneously be a business asset, public relations asset, and financing asset.

But with the onset of the cash flow discount period, such positions have been replaced by financial directors, operations directors, and compliance directors.

The kind of work that involves "going to Brussels to bring back a blank paper to color in" is almost no longer needed in crypto.

The Direction of the Tide

Gordon's move to OpenAI represents jumping into a bigger, messier battlefield with a larger budget, but with even less clear red lines.

The EU AI Act entered its implementation phase this year, but the specific interpretations of the General Artificial Intelligence model (GPAI) clauses are still being negotiated among countries. The UK still does not have a dedicated AI legislation, and it is unknown whether the FCA's "principles-based regulation" will be reused in the field of AI. Several sovereign funds in the Middle East are pouring money into building data centers while considering AI industry policies. The issue of data sovereignty in Africa is becoming the next topic for trade negotiations.

This chaos is a risk for regulatory agencies but an opportunity for those doing policy lobbying.

OpenAI's offer for people like Gordon is roughly 1.5 to 2 times that of Coinbase-level positions, including early equity.

This does not account for the most valuable part. The most valuable part is that entering now, if OpenAI goes public in the future or maintains private financing valuations, the RSUs you hold at current valuations become a lottery ticket.

This kind of lottery ticket has been issued at Coinbase in 2021. It was issued at Google in 2013. It was issued at Yahoo in 1999.

At every peak of technological narratives, there is a group of people who understand the rules best and know how to tell stories, who get on first. By the time the vehicle reaches its final destination, they have already gotten off to pursue the next ride.

In a certain sense, to determine whether an industry is at its peak or at the foothill, you do not need to look at coin prices, TVL, or financing amounts. One thing is enough: whether the smartest lobbying experts are coming in or going out.

The year Gordon entered Coinbase was 2021.

The year Gordon left Coinbase was 2026.

These five years in between represent the lifespan of this crypto cycle.