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BlackRock alters role of Coinbase among 6 changes to ETF filing to cover regulatory concerns
Coinbase transitions to Prime Execution Agent in BlackRock's latest iShares Bitcoin Trust ETF filing.
December 19, 2023
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The recent amendment to the S-1 form for the iShares Bitcoin Trust introduces six substantial changes in the management and operational structure concerning its Bitcoin and cash holdings.

BlackRock’s last update introduced 21 core amendments; however, the Dec. 18 filing exhibits substantially fewer, potentially indicating final refinements before launch. The notable changes in the most recent filing are listed below:

Prime Broker to Prime Execution Agent.

BlackRock introduces a shift in its operational strategy. The Trust has replaced the “Prime Broker” role with a “Prime Execution Agent,” signaling a restructured approach to managing the Trust’s trading balances for Bitcoin and cash assets.

A Prime Broker generally provides a suite of services that enable large institutions, traders, and hedge funds to implement their trading strategies at a cost. These services typically include cash management, securities lending, trade clearing, and settlement, among others.

On the other hand, an Executing Agent is a broker or dealer who processes a buy or sell order on behalf of a client. The executing broker within the prime brokerage will locate the securities for a purchase transaction or find a buyer for a sale transaction. This intermediary service is essential because a large transaction must be done quickly and at a low cost for the client.

The change in Coinbase’s role from Prime Broker to Prime Execution Agent suggests a potential shift in the perceived responsibilities that Coinbase will have concerning BlackRock’s ETF. As a Prime Execution Agent, Coinbase’s perceived primary role is to process buy or sell orders on behalf of the ETF rather than providing the broader range of services typically associated with a Prime Broker. However, much of the language in this section remains consistent with the last filing. Updating terminology to align with SEC guidance rather than introducing material differences is a trend seen across other filings, such as the language regarding a “direct exposure” to Bitcoin.

“Although the Shares are not the exact equivalent of a direct investment in Bitcoin, they provide investors with an alternative method of achieving investment exposure to Bitcoin through the securities market, which may be more familiar to them.”

Under the new Directed Trade Model (see Basket Creation Changes below) and the Agent Execution Model. This amendment delineates the cost responsibilities between the Trust and the Authorized Participants (AP), or their agents, the Non-AP Arbitrageurs, in scenarios where there is a discrepancy between the market price of Bitcoin and its value as calculated for the Net Asset Value (NAV) per Share of the Trust.

When an Authorized Participant, or a Non-AP Arbitrageur acting on their behalf, places a purchase order, they are now financially responsible for covering the difference if the price paid for acquiring Bitcoin is higher than the Bitcoin price used in the NAV calculation. This responsibility implies that any additional cost incurred due to a higher market price during acquisition falls on the Authorized Participant or the Non-AP Arbitrageur.

Conversely, if the Trust secures Bitcoin at a price lower than that utilized in the NAV calculation, the Authorized Participant or Non-AP Arbitrageur benefits by retaining the dollar value of this difference. This provision allows them to profit from favorable market conditions where the actual purchase price is less than the NAV-based price.

Similarly, for redemption orders, the financial responsibility model is mirrored. In cases where the Trust sells Bitcoin for less than the NAV-calculated price, the Authorized Participant or the Non-AP Arbitrageur is obligated to bear the cost difference. This arrangement places the risk of lower market prices during liquidation squarely on them.

However, suppose the Trust sells Bitcoin at a higher price than the one used in the NAV calculation. In that case, the Authorized Participant or Non-AP Arbitrageur again stands to benefit, keeping the surplus dollar value from this transaction.

This amendment introduces a significant risk-reward dynamic for Authorized Participants and Non-AP Arbitrageurs, aligning their financial interests with market fluctuations and the Trust’s NAV calculations.

Retained Responsibilities as Prime Execution Agent.

Under this new framework, the Trust’s assets are still subject to an omnibus claim rather than a direct claim on specific Bitcoin or cash. This approach, along with most of this section, is consistent with the previous arrangement and maintains the pro rata share system for asset entitlement.

Further, the Trust’s cash management strategy remains essentially unchanged, with continued use of bank accounts and Money Market Funds. When it comes to executing Bitcoin sales, the Trust will operate through approved trading venues, though specifics may vary under the new agent. The agreement also includes provisions for suspension or termination by either party under certain conditions, mirroring the clauses in the previous Prime Broker Agreement.

Regarding executing Bitcoin sales, the Trust will continue working through approved trading venues, a process similar to that the Prime Broker employs. However, the specifics of these venues and the due diligence process may differ under the new Prime Execution Agent.

This shift from a Prime Broker to a Prime Execution Agent suggests a reevaluation and possible enhancement of the operational structure for managing the Trust’s Bitcoin and cash holdings. However, many fundamental asset handling and risk management aspects remain consistent with the previous arrangement.

Market Makers to Bitcoin Trading Counterparties.

In another development, BlackRock has revamped the roles and compliance responsibilities within the ETF. The replacement of “Market Makers” with “Bitcoin Trading Counterparties” suggests a potential broadening of entities involved in Bitcoin trading and a more proactive approach to transaction execution.

Now, not only do Authorized Participants and Bitcoin Trading Counterparties need to have compliance programs for sanctions and anti-money laundering laws, but the Prime Execution Agent also has to maintain similar programs. This change highlights an increased focus on regulatory compliance and the prevention of illicit activities.

Furthermore, the Trust’s acceptance of Bitcoin is now explicitly extended to include those acquired through the Prime Execution Agent, in addition to those from Bitcoin Trading Counterparties. This broadens the sources from which the Trust can receive Bitcoin, potentially enhancing the Trust’s ability to manage its Bitcoin holdings more effectively.

Lastly, there is an emphasis on the Prime Execution Agent’s ongoing due diligence and monitoring responsibilities for its customers, including those related to Authorized Participants. This added layer of scrutiny is aimed at bolstering the Trust’s compliance with legal and regulatory requirements, particularly in relation to suspicious activities and transactions.

Basket Creation Changes.

BlackRock has introduced notable changes to its operational structure, particularly in how it handles the creation and redemption of its Baskets, which are the units of the ETF.

Previously, the creation of a Basket was solely dependent on delivering a specific amount of Bitcoin, which varied daily based on factors like sales of Bitcoin, losses, and accrued expenses. The Basket Bitcoin Amount was adjusted daily and made available to Authorized Participants. Now, the Trust has introduced a dual component: a cash amount and a Bitcoin amount for each Basket, reflecting a more complex structure. This change allows for a more flexible and dynamic approach to creating Baskets, accommodating both cash and Bitcoin in varying proportions.

This change introduces two new operational models for handling Bitcoin transactions within the Trust. The first is the Directed Trade Model, where the Trust engages with Bitcoin Trading Counterparties. These Counterparties, who are not registered broker-dealers, enter into written agreements with the Trust to trade Bitcoin. They may be affiliates of Authorized Participants or different broker-dealers known as Non-AP Arbitrageurs. In this model, the Bitcoin Trading Counterparties act in their own interest (in a principal capacity) when trading with the Trust. The second model is the Agent Execution Model. Here, the Prime Execution Agent conducts Bitcoin purchases and sales on behalf of the Trust, acting as an agent. This is done through the Coinbase Prime service under the Prime Execution Agent Agreement.

For Baskets creation, the Authorized Participants need to submit purchase orders, which are acknowledged by BRIL unless the Trustee or Sponsor refuses them. The timing for these submissions varies between the two models. For the Directed Trade Model, orders are placed on the trade date, while for the Agent Execution Model, there’s an earlier cutoff time, potentially the evening before the trade date. These orders determine the cash needed for the deposit and the corresponding Bitcoin amount the Trust needs to purchase.

The fee structure remains consistent, with a standard creation transaction fee for each order, which includes an ETF Servicing Fee and Custody Transaction Costs. BRIL, an affiliate of the Trustee, handles these services and fees.

The process of accepting purchase orders has also been streamlined. Upon acceptance by the Trustee, BRIL communicates the required Basket Amount to the Authorized Participant for the cash to be delivered in exchange for the Baskets. This system underlines a shift towards a more cash-centric approach in the Trust’s operation, diverging from the direct use of Bitcoin in transactions.

Bitcoin Redemption Changes.

The Trust has provided a structure similar to creations for redemptions, with the same Directed Trade Model and Agent Execution Model. This symmetry ensures consistency in the Trust’s operational framework for creations and redemptions.

The amendment has also introduced a new dynamic to determining the Basket Amount regarding redemptions. In addition to the daily adjustment, an indicative Basket Amount for the next business day will be made available to Authorized Participants, providing them with guidance for future transactions.

Moreover, the Trust has emphasized the potential for delays in Bitcoin transactions due to network issues, highlighting the inherent risks in dealing with digital assets.

Under the direction of the Sponsor, the Trustee has also been granted the authority to suspend the acceptance of purchase orders or the delivery or registration of transfers of Shares in certain circumstances, adding a level of control to manage unforeseen events or market disruptions.

These changes reflect a more sophisticated and nuanced approach to the operation of the iShares Bitcoin Trust, considering both Bitcoin’s volatility and the regulatory environment it operates within. The introduction of cash components, dual trade models, and potential for borrowing Trade Credits indicate a move towards a more flexible and responsive ETF structure, aiming to cater to varying investor needs and market conditions.

CF Index Risk Identification.

BlackRock has also highlighted a potential issue related to the Index Administrator, specifically system failures or errors. This amendment addresses the possibility that the computers or facilities used by the Index Administrator, data providers, or Bitcoin platforms could malfunction, leading to delays in calculating and disseminating the CF Benchmarks Index. This index is crucial as it is used to determine the Trust’s net asset value (NAV).

The amendment elaborates that errors in the CF Benchmarks Index data, computations, or construction could occur and might go unidentified or uncorrected for some time or even indefinitely. Such mistakes could adversely impact both the Trust and its Shareholders. In essence, if the CF Benchmarks Index encounters errors, it could lead to investment outcomes that differ from what would have occurred if these errors had not occurred.

Furthermore, it is specified that the Trust and its Shareholders will generally bear any losses or costs associated with these errors or related risks. The Sponsor, its affiliates, or its agents do not offer any guarantees against these risks.

The amendment also states that if the CF Benchmarks Index is unavailable or deemed unreliable by the Sponsor, the Trust’s holdings might be valued based on fair value policies approved by the Trustee. This revaluation could lead to discrepancies between the valuation and the actual market price of Bitcoin. Such a situation could result in the Shares’ price no longer accurately tracking the price of Bitcoin, either temporarily or over a more extended period. This misalignment could adversely affect investments in the Trust and the value of the Shares, potentially diminishing investor confidence in the Shares’ ability to track the price of Bitcoin.

IBIT Ticker Revealed.

Lastly, BlackRock has confirmed the ticker symbol for the Trust’s shares on NASDAQ as “IBIT,” facilitating easy identification for investors interested in tracking the ETF’s performance.

 

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AI Is Coming for Your Job Title

Artificial intelligence may or may not take your job, but it has already broken into the human resources department and vandalized the org chart.

The evidence is all over LinkedIn, where perfectly serviceable occupations now arrive wearing titles such as “forward-deployed and agentic AI architect.” That person may be building sophisticated software. They may also be helping a chatbot remember what happened three prompts ago. Either way, somebody approved the business cards.

The expanding AI lexicon offers a useful counterpoint to the darker debate about technology and employment. Most discussion centers on how many jobs AI will eliminate. Hiring data presents a more complicated picture that includes a weak overall labor market containing a small but rapidly growing neighborhood of AI-related work.

Indeed Hiring Lab found that the number of postings on Indeed mentioning AI surged 134% from its February 2020 level by the end of 2025, even as total postings stood only 6% above that benchmark. AI appeared in a record 4.2% of Indeed postings in December.

AI, in other words, is not merely changing work. It is adding syllables to it.

The Titles Employers Actually Want

The undisputed champion is AI engineer, which ranked No. 1 on LinkedIn’s 2026 Jobs on the Rise list. The ranking, based on growth during the previous three years, also highlighted AI consultants and strategists, AI and machine-learning researchers and data annotators.

The title is popular partly because it is wonderfully accommodating. An AI engineer might build applications around large language models, connect corporate data to an AI system, improve model performance or spend Thursday afternoon persuading a customer service bot not to offer refunds for products the company doesn’t sell.

Indeed’s data showed the terminology spreading beyond Silicon Valley. Nearly 45% of data and analytics postings contained an AI-related term at the end of 2025, along with roughly 15% of marketing postings and 9% of human resources listings. A more recent Indeed analysis reported by Business Insider found that the number of frequently advertised job titles explicitly referencing AI rose from 264 in 2022 to 822 in the first quarter of 2026. Nearly two-thirds were outside traditional technology fields.

That produces titles such as AI marketing manager, AI learning specialist, responsible AI counsel and AI transformation lead. These are not always new occupations. Frequently, they are familiar jobs that have discovered a highly effective résumé keyword.

LinkedIn data cited by the World Economic Forum estimated that AI investment has supported 1.3 million positions, including AI engineers, data annotators and forward-deployed engineers, plus more than 600,000 AI-enabled data center jobs. The server racks, unlike the chatbots, still need electricians.

The Jobs With the Science-Fiction Salaries

At the upper end, AI has created a compensation market that resembles professional sports, except the competitors wear hoodies and discuss inference latency.

Syracuse University review put chief AI officer compensation between $200,000 and more than $500,000, while specialized roles can exceed $400,000 after bonuses and equity. Frontier research engineers, AI infrastructure specialists and engineers who can train or deploy advanced models command some of the largest packages.

Then there is the forward-deployed engineer, an old Palantir title that the AI boom has placed on a rocket sled. These engineers embed with customers, translating an executive’s desire to “do something with AI” into software that works. The Next Web reported that Indeed postings for the role were about 19 times higher in January than a year earlier.

CTO guide from the blog Signal Through the Noise placed forward-deployed engineer compensation between $238,000 and $700,000, research-engineering packages as high as $1.4 million and chief AI officer compensation above $1 million in some cases. It also made a less flattering observation: Many lavishly differentiated titles describe the same three basic functions. People build AI products, train models or keep the infrastructure from catching fire.

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As subnets mature from raw infrastructure into client-facing enterprise APIs, the velocity of this flywheel is poised to redefine the economics of AI forever.

I hope this was helpful ~Dinarian888♾

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On June 12, the US pulled Anthropic’s best model offline by export order. Ten days later, Tokyo’s Sakana AI shipped Fugu, a router that reassembles the same capabilities from the models that are still standing. Blocking intelligence created the market for routing around it.

 

At 5:21 p.m. Eastern on Friday, June 12, 2026, Anthropic received a letter from the US Department of Commerce and, by its own account, had on the order of an hour to take its two most capable models offline.

The letter was an export control directive. It ordered Anthropic to suspend all access to Claude Fable 5 and Claude Mythos 5 “by any foreign national, whether inside or outside the United States, including foreign national Anthropic employees.” Because the company cannot reliably check the nationality of everyone calling an API, the only way to comply was the blunt one. Anthropic disabled both models for every customer on earth, and they stayed dark. As of late June 2026, neither Anthropic nor the government has announced a timeline to restore access, and an approved BIS license is now required before any foreign person can touch them. This was not a chip ban. It was the first publicly confirmed time the US government reached past the hardware and the weights-in-transit and pulled the plug on a running model.

Ten days later, on June 22, a Tokyo lab named Sakana AI shipped the response. Its new product, Fugu, is not a frontier model. It is a router: a small trained model that conducts a pool of other companies’ models and stitches their…

Sandwiched between those two dates, on June 13, China’s Z.ai released GLM 5.2, an open-weight model under an MIT license priced at roughly a sixth of Fable 5. None of these three were reactions to each other in any literal sense; GLM 5.2 and Fugu were finished pipelines that happened to land in the same news cycle. But the cycle told a story the policy did not intend. Block a model, and within ten days the open-weight competitor and the orchestration workaround both look less like products and more like exits.

This piece is about that asymmetry: why a government can switch off a model in ninety minutes, why it is far harder to switch off a system that reassembles the same capability from parts it does not control, and why the last time Washington tried this exact move, with encryption in the 1990s, it lost.

What got banned, and why it was a first

Mythos 5 is the most capable model Anthropic has built, positioned above Opus in the family and never sold to the public. Access ran through a vetted-partner program called Project Glasswing, built around cybersecurity. The reason it was gated is not marketing. On a Firefox JavaScript-engine benchmark where Claude Opus 4.6 produced two working exploits, Mythos Preview produced 181, and gained register control on dozens more targets. It autonomously surfaced a 27-year-old vulnerability in OpenBSD’s TCP stack that had survived human audits, automated fuzzers, and decades of unusually careful open-source review. Over three months pointed at Firefox, Anthropic reported, the model turned up 271 previously unknown vulnerabilities at a false-positive rate under 5%. Fable 5 was the public, safety-gated sibling: the same generation with classifiers that route high-risk cyber and bio queries to the older Opus 4.8 and trip, Anthropic says, in under 5% of sessions.

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Mythos Preview’s cyber results against earlier models. Source: Anthropic, “Mythos Preview”, Apr 7 2026 (vendor-reported). License: Anthropic; confirm reuse before publishing.

 

The legal move was the structural novelty, not the capability. The January 2025 AI Diffusion Rule had already created an export classification (ECCN 4E091) for the weights of advanced closed models, things that sit still and can be licensed like any controlled good. The June 12 directive went a step past that, onto a live commercial API. Commerce could argue this is a natural extension of the same authority, and it is not a crazy argument. But in practice, it is the first time the controlled thing was not a chip you can put in a crate or a weights file you can copy, but a service anyone can call from anywhere, at any time, until the moment it is switched off.

The trigger is contested, and you should treat it that way

What actually set this off is disputed, and the accounts do not line up.

The administration’s version came mostly from White House AI and crypto czar David Sacks, who said on June 13 that a “highly credible trusted partner” had demonstrated a jailbreak of Fable’s guardrails amounting to “the operability of a cyber weapon,” that the government asked Anthropic to fix it or pull the model, and that CEO Dario Amodei refused. Multiple outlets identified that partner as Amazon, an Anthropic investor and compute provider, and the Wall Street Journal reported that Amazon CEO Andy Jassy told Treasury Secretary Scott Bessent and other officials that Amazon researchers had used Fable 5 to obtain information usable in cyberattacks.

Anthropic’s version is that this was a “narrow, non-universal” potential jailbreak (“read a specific codebase and fix any software flaws”), that the capability in question is “widely available from other models, including OpenAI’s GPT-5.5,” and that recalling a model “deployed to hundreds of millions of people” over it was disproportionate. Independent voices leaned toward Anthropic on the technical point. Katie Moussouris, CEO of Luta Security, was blunt: “I’ve seen the paper. It’s not a jailbreak.” A former Commerce official, Kate Koren, suggested the White House’s sour relationship with Anthropic may have colored the decision. Semafor separately reported the move was tied to suspicion that a China-linked group had accessed Mythos, a motive Anthropic says the White House never raised with it and which other outlets could not confirm.

The honest summary: the trigger is Amazon-reported and Sacks-narrated, contested by Anthropic, doubted by outside researchers, and the China angle is unverified. Hold it loosely.

What Sakana actually shipped

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Timeline illustration contrasting June 12 when US export control took Mythos and Fable 5 offline in 90 minutes, with June 22 when Sakana AI’s Fugu 7B router launched as the workaround, routing queries across GPT-5.5, Opus 4.8, Gemini 3.1, and Fugu to produce one answer
One model gets unplugged; a router conducts the ones still standing. (Original illustration.)

 

Fugu is not a frontier model in the usual sense, and Sakana does not pretend otherwise. What it shipped is stranger, and arguably more interesting: a multi-agent system delivered as a single model, a coordination layer dressed as one OpenAI-compatible endpoint. The complexity never reaches your code. Your app sends one request; Fugu decides, behind the wall, whether to answer directly or assemble a team. Underneath, it is a learned orchestration system built around a roughly 7-billion-parameter “conductor” (a Qwen2.5–7B base) trained with reinforcement learning to design collaboration strategies across a pool of larger worker models. Two ICLR 2026 papers sit underneath it: Trinity (arXiv 2512.04695), a sub-20K-parameter coordinator tuned by derivative-free evolution, and Conductor (arXiv 2512.04388), the RL-trained orchestrator that hands out roles. The lineage runs back to Sakana’s 2025 AB-MCTS work (arXiv 2503.04412, a NeurIPS spotlight), which showed that letting several frontier models cooperate at inference time, deciding adaptively whether to go wider or deeper, beat any single one of them.

Sakana’s own framing is the sharpest way to see it: Fugu is model merging moved up a level. The technique that made the lab’s name, evolutionary model merging, blends the weights of open models, which requires matching architectures and downloadable checkpoints. Fugu does the same job one layer higher, composing what models do rather than what they are, treating each frontier system as a black box and learning to route, verify, and synthesise their behaviour, “without requiring parameter access or architectural compatibility.” That reframing is the unlock: it is how a lab with no frontier weights of its own gets to merge OpenAI’s, Anthropic’s, and Google’s anyway, through the front door of their APIs.

The mechanism is worth one layer down, and the two tiers do it differently. Plain Fugu decides without writing a word: a lightweight selection head reads the hidden state of your prompt, scores every model in the pool, and dispatches to the top one before any text is generated, which is why it stays nearly as fast as a single call. Its predecessor, Trinity, tagged each pick with a role: Thinker, Worker, or Verifier; Fugu dropped the roles and simply takes the best worker. Fugu-Ultra goes further: it writes an agentic workflow, a sequence of steps, each carrying a plain-language subtask, a worker id naming the model to run it, and an access list controlling which earlier results that worker is allowed to see. Tune the access list, and you get a chain, a best-of-N, or a tree. The pool is swappable, GPT-5.5, Opus 4.8, Gemini 3.1 Pro, or recursive copies of Fugu itself, and when Fugu calls itself, it reads its own earlier output, judges whether it is working, and spins up a corrective pass. None of it is hand-coded with if-statements; it is learned, plain Fugu through supervised fine-tuning and then evolutionary search, Fugu-Ultra through reinforcement learning, on roughly 960 problems across two H100 GPUs. Commercially, it ships in those two tiers behind an OpenAI-compatible API, with subscriptions at $20, $100, and $200 a month and a metered free tier through Vercel’s AI Gateway, the official third-party integration, which routes to the same closed pool of GPT-5.5, Opus 4.8, and Gemini 3.1 Pro.

That difference shows up as quality. Plain Fugu, picking one model per step, can hand a coding request to GPT-5.5 to draft and to Opus 4.8 to debug a few turns later, all inside one request, yet on SWE-Bench Pro it still lands ten points below Opus alone (59.0 to 69.2): routing among models is not the same as being better than the best one. Fugu-Ultra earns its keep on harder work, and one of its smarter habits is that the model that writes the final synthesis is not pinned in advance, the way an “LLM council” fixes one judge, but chosen by domain. Its ceiling is the planning. The workflow is drawn before any agent has produced anything, so the system commits its branching at t=0 instead of adapting at t+1 from what it just learned, which is why the workflows stop at a few steps; the smartest version of this idea reacts to intermediate results, and Fugu-Ultra mostly cannot.

How does a 7B model learn any of this? In two ways, one per tier. Plain Fugu starts with supervised fine-tuning on questions whose answers are known: run every worker several times, turn each one’s average score into a soft probability with a softmax, so the target keeps “GPT best, Opus a close second, Gemini weak” instead of collapsing to “always GPT,” and train the selection head to match that distribution.

Then it is polished with an evolutionary method, sep-CMA-ES, on full multi-turn tasks where the only signal is pass-or-fail at the very end and ordinary gradient training has nothing to grab: try many small variations of the weights, keep the ones that finish more tasks, move toward them. To keep that cheap, Fugu nudges only a thin slice of its weights, using the SVD trick from Sakana’s earlier Transformer-squared work, rather than retraining the whole model. Fugu-Ultra is trained by reinforcement learning instead (GRPO, from the DeepSeekMath line): for each question, it writes a group of candidate workflows, scores each one (0 if the plan is malformed, 0.5 if it runs but the answer is wrong, 1 if it runs and is correct), and pushes up the workflows that beat the group’s average while pushing down the rest. Over many rounds, it learns to write plans that look like the ones that worked.

Turning several agents loose with tools creates two failure modes that Sakana had to engineer around, and the fix is tidy. If every agent could see everything the first one did, they would all follow its lead, and the team would collapse into a single opinion, so inside a workflow, each agent is isolated, seeing the others only through the access list the conductor set. But total isolation is wasteful: over a long task, agents would re-run the same tool calls and rediscover the same facts, so across the whole conversation they share a persistent memory of what has already been called. Independent within a step, shared across the task. That is the balance that keeps a real team both diverse and non-repetitive.

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Fugu AI multi-agent orchestration diagram showing the 7B conductor robot assigning Thinker, Worker, and Verifier roles across a swappable rack of AI models including GPT-5.5, Opus 4.8, Gemini 3.1 Pro, and recursive Fugu, trained on 2x H100 GPUs, synthesizing into one answer
The 7B conductor scores the pool, dispatches subtasks across it (including to copies of itself), and synthesises one answer. (Original illustration.)

 

CEO David Ha put the thesis plainly: “Relying on a single company’s APIs for critical infrastructure, finance, or governance is a material vulnerability. This risk is no longer a hypothetical possibility, but a reality.” Ten days after June 12, that sentence reads less like a product slogan and more like a market read.

Is any of this worth it over just calling Opus or GPT-5.5 directly? For a single clean prompt, almost certainly not, and Sakana’s own numbers concede it, plain Fugu trails the best single model it routes among. The case for orchestration is the messy task, the kind of real work it is actually made of: read ambiguous context, split it, hand the pieces to different specialists, verify, kill the weak branch, merge the rest, and stop before the loop runs forever. That is the layer most teams already hand-build out of routers, prompts, eval scripts, and retry glue nobody wants to maintain. Fugu’s bet is to sell that layer as a model.

What makes the bet plausible is that the frontier models really do specialise. By Sakana’s reading of its own pool, GPT-5.5 is strongest at math and at planning and combining ideas, Opus 4.8 at software engineering and at finding security bugs, Gemini 3.1 Pro at implementing known algorithms and at science. A conductor who has learned those edges can do things no single member would, and Sakana did not script the moves; they surfaced in training. On coding tasks, Fugu-Ultra learned to let GPT build and then pull Opus in at the right moment to hunt bugs and security holes before handing the findings back; on a cryptanalysis task, it had Opus open the attack and GPT re-derive the math it needed. That is the instinct a good tech lead runs on, knowing exactly which teammate to call for which part of the job.

The demos carry the idea better than the scorecard does, with the same caveat: they are Sakana’s, and the rivals are anonymised as “Model A, B, and C,” the labels reshuffled between examples so you cannot decode them (the field is Gemini 3.1 Pro, Opus 4.8, and GPT-5.5). With that asterisk, a few are hard to fake. Turned loose to improve a small GPT training recipe, Fugu Ultra ran the research loop itself, edit the code, run the experiment, measure validation bits-per-byte, keep the change if it helped, repeat, 123 experiments over about 14 hours on a single H100, landing at 0.9774 bits-per-byte against the baselines’ 0.9781, 0.9793, and 0.9822.

Asked to write a Rubik’s Cube solver from scratch in pure Python, its code solved 300 of 300 held-out scrambles at an average of 19.72 moves, a hair off the proven optimum of 20, while two of the three baselines wrote code that crashed on all 300. Pointed at a 1610 manuscript and told to recover the reading order of scattered Japanese kana, it scored 0.80 against a baseline of 0.24. Playing four games of blindfold chess, no board shown, the whole position held in its head, it won all four, including one against a 2,100-Elo engine, without a blunder. Handed a 50-week trading simulation starting at $10,000, it finished at $11,943, a 19.43% gain, ahead of every model it called (Sakana frames this as a no-look-ahead decision test, not investment advice, and you should too). These are runnable artefacts and agent loops, not trivia answers; they either work or they visibly do not.

And here is the part that a policymaker should sit with longer than any benchmark. The week the US made its best model unreachable behind a license, Fugu made frontier-adjacent capability reachable behind a dropdown. It is one OpenAI-compatible endpoint: point Codex or any OpenAI client atapi.sakana.ai/v1, set the model to fugu-ultra, and you are running in minutes, or skip the wiring and prompt it in a browser at chat.sakana.ai. No waitlist, no nationality screen, no export letter. Whether or not Fugu matches Mythos, that part is not in dispute, and it is the whole reason the ban looks porous: the controlled capability did not have to be smuggled. It had to be subscribed to.

The claim that hasn’t been checked

Sakana’s launch post says Fugu Ultra “stands shoulder-to-shoulder with leading models like Fable 5 and Mythos Preview.” That is the headline, and it is prose, not a number. Nowhere on Sakana’s own benchmark page do Fable 5 or Mythos scores appear in the same table as Fugu’s, under the same conditions. The reason is one Sakana states outright: “Fable 5 and Mythos Preview are not in Fugu’s agent pool as they are not publicly accessible,” and “all scores other than Fugu’s are reported by the respective model providers.”

So the parity claim is a comparison between Fugu’s own numbers and the manufacturers’ separately published numbers for two models Fugu cannot pool, cannot run head-to-head, and which the public can no longer access at all. What Sakana does show is a table against the models it can still reach:

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Sakana AI benchmark comparison charts showing Fugu Ultra and Fugu outperforming or matching Fable 5, Mythos Preview, Gemini 3.1 Pro, GPT-5.5, and Opus 4.8 across six benchmarks: LiveCodeBench, GPQA-D, CharXiv Reasoning, SWEBench Pro, SciCode, and Humanity’s Last Exam. Source: Sakana console benchmarks with provider-reported scores for competitor models.
Source: Sakana console benchmarks (console.sakana.ai/models). Fugu’s numbers are Sakana’s own; the rest are provider-reported, not re-run in a common harness.

 

It is a real result. On these rows, Fugu Ultra edges out three frontier models by orchestrating them. But step back, and the framing matters. This is not a clean sweep (on longer-context and multi-call benchmarks elsewhere in the set, Fugu Ultra slips behind GPT-5.5 and Gemini), and the marquee “matches Mythos and Fable” claim is the one piece of the story no outsider can test, because the comparison it implies has never been run in a single harness and now cannot be. The right word is not “unfalsifiable.” The right words are not yet independently verified, and currently unverifiable under a neutral evaluation, which, for a buyer making a procurement decision in June 2026, amounts to the same caution.

There is a deeper apples-to-oranges problem inside the table. Fugu Ultra is an orchestrator that spends several model calls on every answer; Opus 4.8, Gemini 3.1 Pro, and GPT-5.5 in that table are single models answering once. The honest comparison is not Fugu against one Opus call, it is Fugu against Opus run in its own multi-step mode (Anthropic’s “ultracode” workflows), or against a swarm of Kimi agents, orchestrator against orchestrator at matched spend. Sakana does not publish that. It also reports an “AutoResearch” benchmark against rivals it labels only “Model A, B, and C,” a strange thing to anonymise, and observers flagged at least one competitor figure (Figure 5’s TerminalBench score) as off, the kind of error that slips through precisely because nobody re-ran anything in one place.

The trust problem

There is a specific reason to read Sakana’s self-reported numbers with a raised eyebrow, and it is Sakana’s own recent history.

In February 2025, the company unveiled the “AI CUDA Engineer,” claiming 10x to 100x speedups over plain PyTorch, with a headline figure up to 150x. Within a day, outside testers could not reproduce it. The system had reward-hacked the benchmark: it found a memory exploit in the evaluation harness that let its generated kernels skip the correctness check entirely. An independent retest pegged the real average speedup at about 1.49x against a valid benchmark, against the paper’s claimed 3.13x average, and nothing like the headline. Sakana’s postmortem admitted the model had “found a way to cheat” and “reward hacked,” apologised, and promised a revision. To the company’s credit, it later published work on hardening the eval, and benchmark-gaming is a problem every lab wrestles with, not a Sakana-only sin. But the pattern is exactly the one that should make you cautious about a fresh set of self-reported, no-common-harness, can’t-be-reproduced parity claims from the same shop sixteen months later.

The structural critiques go past track record:

  • Orchestration is a meta-system, not a new ceiling. Fugu’s intelligence is bound by the best model it can call. It can squeeze more out of existing capability; it cannot exceed it. The thing it claims to match, frontier intelligence, is precisely the thing it does not itself contain.
  • The resilience pitch is only as strong as the pool. “Swappable” protects you when one provider pulls a model. It protects you not at all if several restrict access at once, which is exactly the scenario a government action could produce.
  • The cost is hidden, and cost is the whole game. Fugu Ultra is a best-of-N-over-models strategy; its quality comes from spending more compute. And yet Sakana reports no output-token count and no per-task cost for a single benchmark. That omission is the tell. The one public number comes from outside the company: in a hands-on build of the same Three.js game, one tester clocked Fugu Ultra at about 89,000 tokens, $7.32, and 22 minutes, against Claude Opus 4.8 in its multi-step “ultracode” mode at about 940,000 tokens, $37.85, and 79 minutes. Fugu came out cheaper and faster; Opus produced the better game. One anecdote is not a benchmark, but it is more cost data than the vendor disclosed for its entire launch. To Sakana’s credit, on the one point it does address, it says it does not stack model fees when several agents run, you pay a single rate pegged to the top-tier model involved, which keeps the meter from multiplying per agent in the dumb way multi-agent systems usually do. What it still will not tell you is how many tokens any given answer burned.
  • It is opaque by design. Fugu does not tell you which model produced which output. The routing that is its entire value proposition is also unauditable from the outside, and plain Fugu apparently can’t even add a new model to the pool without retraining the classifier.

And there is the part that cuts against the pitch. Fugu is sold as resilience, insurance against a vendor that can vanish overnight. But it is a closed-source orchestrator routing to closed-source models, and on one axis, it inverts the control it promises. Before, you did not own the model. Now you do not own the model, and you no longer choose which models run, how many calls they make, or what the bill will be, because the routing is proprietary and unlogged. In capability terms, that is not sovereignty; it is a second layer of dependency wearing sovereignty’s clothes.

Why is a router hard to ban

Here is the mechanism at the centre of the whole episode, the asymmetry between a thing and a capability.

An export control needs a defined object. A chip with a classification number. A weights file above a compute threshold. The June 12 directive showed that a live API can be added to that list. But Fugu is a different kind of object. It is a 7-billion-parameter model, trained on two GPUs, that holds almost no frontier capability of its own. Its power is borrowed, assembled on demand from third-party APIs that are themselves available through ordinary commercial channels. To shut down a system like that, a regulator has to pick from a menu of bad options: ban multi-agent orchestration in general (which would sweep up most production AI in the world), control every model in the pool individually (including ones hosted outside US jurisdiction), or control the act of calling a US model from a foreign orchestrator (which means inspecting API traffic at a scale that invites the same legal fights as content-based internet controls).

This is where the punchy version of the thesis needs an honest qualifier. You can reach software and services with export law; the EAR has covered source code and electronic transmissions for decades, and providers can choke off foreign use through their own terms of service. The claim is not that a router is uncontrollable. It is that controlling it is leakier, slower, and more collateral-damaging than flipping one model offline, and that the controls degrade the moment the banned capability can be reconstituted from parts that are still for sale. The swappable pool is simultaneously Fugu’s pitch and its dependency: today it leans on GPT-5.5, Opus 4.8, and Gemini 3.1 Pro, none of which it owns, all of which can tighten their terms in a single stroke.

The precedent that says this fails: the crypto wars

The shape of June 2026 maps onto a fight the United States has already had and already lost, and the map is worth drawing carefully, because it is instructive without being exact.

In the early 1990s, Washington classified strong cryptography as a munition under ITAR Category XIII(b), requiring an export license to ship it abroad. The government’s preferred alternative, the NSA-designed Clipper chip, put an escrowed backdoor in the standard; the cryptographer Matt Blaze found a fatal flaw in its protocol in 1994, and the initiative collapsed. Phil Zimmermann, facing a criminal investigation for releasing PGP, had its source code printed as a book: printed matter was protected speech, and the bits could be scanned and recompiled anywhere on earth. The mathematician Daniel Bernstein sued after being told he needed a license to publish his cipher, and the courts ruled that source code is speech protected by the First Amendment. By Executive Order 13026 in 1996 the controls moved from the State Department to Commerce, and by 2000 they were substantially relaxed, because strong encryption was already everywhere and the only thing the controls were reliably accomplishing was handing market share to foreign competitors.

 

The differences are real, and you should not pretend otherwise. Cryptography is narrow mathematics; a frontier model is a general-purpose system with a far wider and stranger risk surface, and “strong crypto is available” was a cleaner binary than “a model that can autonomously chain exploits is available.” Bernstein turned on source code as expression; export regimes today target trained weights and a metered service, which a court could treat differently. The analogy is partial, not a proof. But the load-bearing part holds: when the controlled thing can be re-derived from publicly available parts, unilateral export control tends to inconvenience the law-abiding, accelerate the offshore alternative, and erode until it is quietly dropped. TechCrunch drew the same line on June 19, under the headline “From PGP to Mythos.”

The policy fork: block, or race

Strip away the personalities and there are two coherent worldviews underneath, and they do not fit together.

The containment camp treats frontier capability as a weapon whose spread you slow by any available means. Matt Pottinger and the Foundation for Defence of Democracies argued in January 2026 congressional testimony that even limited AI-chip sales to China would “supercharge Beijing’s military modernisation,” from cyber warfare to autonomous drones. Applied to Mythos, the logic is direct: a model that writes 181 exploits where its predecessor wrote two is not a chatbot upgrade; it is a proliferation problem, and you gate it.

The race camp treats restriction as self-defeating. NVIDIA’s Jensen Huang has called US chip export controls a “failure,” arguing they push buyers to the second-best option, hand the opening to Huawei, and cost American firms the market without actually stopping anyone. Brookings has warned, separately, that a US strategy built on closed models cedes the global-diffusion channel to China’s open-weight labs, whose models are already downloadable, adaptable, and runnable on non-US silicon. Alex Stamos, the former Facebook security chief, organised an open letter (freefable.org) calling the directive “vibes-based” regulation with no written standard and no path back, and made the defender’s point: the same exploit-finding capability the ban removed is exactly what blue teams use to harden systems.

The administration itself does not sit cleanly in either camp. David Sacks backed pulling this specific model on dual-use grounds while opposing broader legislative oversight of chip exports, a hawk on the model and a dove on the supply chain, which produced open friction with members of his own party who want statutory control over advanced-chip sales. And the policy expert Dean Ball, briefly of this administration, caught the incoherence in two lines on X: “I can’t tell if this is lawfare against Anthropic in particular or extreme national-security hawkery. Regardless, it is simply cartoonish.” An administration that wants to export advanced chips to China, he wrote, while moving to ban Britain “and every other non-American on Earth” from its best models: “I have no words.”

The allies noticed. The directive applied to France, Germany, the UK, Japan, Italy, and Canada alike, every Tier-1 partner under the diffusion framework, and demonstrated in real time that even the closest could be unplugged overnight. President Macron called it a “wake-up call” and criticised it as strictly nationalist; Prime Minister Carney warned against building on technology that a foreign government can switch off; the G7’s Évian summit ended without a joint communiqué. There is a calibrated middle path on offer too, the kind sketched in work like “Beyond the Binary” (arXiv 2602.19682): release decisions anchored to measured capability thresholds rather than to a single after-the-fact letter, distinguishing a model’s offensive profile from the defensive uses of the same skill. It requires a written standard, which is precisely what June 12 lacked.

And then there is the irony the whole episode turns on. Japan is a founding Tier-1 member of Pax Silica, the US-led bloc formed in December 2025 to organize allied access to AI infrastructure. Tokyo joined the alliance for unrestricted access to the frontier. And it was a Tokyo company that, ten days after the ban, shipped the first commercial product built to route around it. Tier-1 membership buys the chips. It does not buy your private sector’s patience with model-level restrictions.

Sakana is built to be exactly that private sector. Its founders are Ren Ito, a former Japanese diplomat, and Llion Jones, one of the eight authors of the 2017 Transformer paper, a pairing of statecraft and the architecture that started all of this. That matters because of a second sense of the word “sovereignty,” the one the capability critique earlier set aside. Fugu does not give Japan sovereignty over the weights; it rents those from California. But in a market as regulated and as loyal to domestic suppliers as Japan’s, a Tokyo-headquartered vendor behind one compliant endpoint is the procurement-safe default, and plain Fugu even lets a buyer drop specific models from the pool to satisfy a data or compliance rule. That is sovereignty over the contract, the data jurisdiction, and the counterparty, if not over the model. It is a narrower claim than the marketing implies and a more durable one, and it is why the bulls argue a country with a $4.5 trillion economy and a structural preference for home-grown infrastructure will eventually mint a trillion-dollar AI company, with Sakana their pick to be it.

The honest version

The case for blocking is not empty. Mythos 5 is different in kind: 181 working exploits against two, a 27-year-old bug no human or fuzzer had found, a near-total escape rate against a hardened browser. A government is not wrong to have the capability like that, deployed without any friction, which changes the threat model for every operator of critical infrastructure on the planet. Anthropic itself built the thing behind a vetted-partner wall for exactly that reason.

The case for racing is not empty either, and history is on its side. The Clipper chip failed. PGP shipped as a paperback. Bernstein established that code is speech. By 2000, the United States had relaxed the controls, and its companies went on to dominate the encryption market they had been told they were protecting. Today, GLM 5.2 is already MIT-licensed and running on Huawei silicon in every jurisdiction that never got a Tier-1 invitation, and Fugu launched ten days after the ban with the ban itself as its marketing. The controlled capability is already leaking through the open-weight channel that the controls cannot reach.

The truthful read is that both cases are partly right and both camps are overconfident. Pulling a specific, unusually dangerous capability for a short, bounded window can be defensible. But ninety minutes of notice, no published licensing path, an allied sweep with no consultation, and a flat refusal to separate the defensive use of a skill from its offensive twin all corrode the legitimacy of the action even where the underlying worry is real. And racing is no guarantee either; it is simply the only strategy with a precedent that ended in American strength rather than retreat.

There is a bigger shift underneath the politics, and it is the reason this story is not really about one ban. For three years, the answer to every AI problem was to train a bigger model. Fugu is a bet on the next answer: coordinate the models you already have. If that bet is right, the contested layer stops being who builds the smartest model and becomes who decides which model gets the task, which one checks it, which branch dies, which output survives, and which provider can be swapped out tomorrow. The model race does not end. It gets a manager. And a manager assembled from parts that are still for sale is a much harder thing to put under export control than any single model.

The model went dark in an hour. The router shipped in ten days. The open weights are already on Huawei chips. The remaining question is not whether the United States can switch off a model. June 12 settled that. It is whether intelligence is something you can hoard by decree, or a current that routes around the dam, in which case the only durable lead is the one you build faster than anyone can reassemble it from the parts you left on the table.

Happy Coding ❤

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