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mev-the-hidden-tax-of-crypto
Blog

Why MEV Relays Are the New Focus for Watchdogs

The infrastructure designed to democratize MEV—relays and sequencers—has created centralized chokepoints. This analysis explains why these points are inevitable targets for financial surveillance and regulatory enforcement, threatening core blockchain properties.

introduction
THE NEW FRONTIER

Introduction

Regulatory scrutiny is shifting from token classification to the opaque infrastructure that powers blockchain transactions, with MEV relays as the primary target.

MEV relays centralize power. These systems, operated by entities like Flashbots and BloXroute, act as private mempools where validators source transactions, creating a critical chokepoint for censorship and surveillance.

The SEC's new attack vector is infrastructure control. Regulators are not just suing exchanges; they are targeting the transaction supply chain that determines finality, a more effective control mechanism than chasing tokens.

This creates systemic risk. Relays like Titan Builder and Manifold now decide which transactions reach Ethereum's base layer, making them de facto gatekeepers subject to OFAC compliance demands.

Evidence: Over 90% of Ethereum blocks are now built by a handful of centralized builders, with Flashbots' SUAVE protocol aiming to decentralize this process in response.

thesis-statement
THE NEW CHOKE POINT

The Centralization Trap

MEV relays are the new critical point of centralization, concentrating power and regulatory risk in a handful of opaque entities.

Relays are the new validators. The shift to Proposer-Builder Separation (PBS) outsources block production to specialized builders, but the relay is the mandatory intermediary. This creates a single point of failure and censorship that watchdogs like the OFAC now target directly.

Opaque selection creates systemic risk. A relay's builder selection is a black box. The dominant Flashbots relay controls ~90% of Ethereum blocks, making its internal logic and governance a de facto protocol rule. This centralization invites regulatory scrutiny and creates a fragile system.

Regulators target the choke point. The OFAC sanctions compliance demonstrated that relays are the enforcement layer. Censoring transactions at the relay level is more efficient for regulators than pursuing thousands of individual validators, making relays the primary regulatory surface.

Evidence: Post-Merge, over 99% of Ethereum blocks are built via the PBS model, with the Flashbots, BloXroute, and Agnostic relays processing the vast majority. This consolidation makes the network's liveness dependent on fewer than ten entities.

MEV SUPPLY CHAIN ANALYSIS

The Relay Power Concentration

Comparison of key operational and economic metrics for leading Ethereum MEV relays, highlighting centralization vectors.

Metric / FeatureFlashbots (SUAVE)bloXrouteEden NetworkTitan Builder

Validator Market Share (30d avg)

85.2%

8.1%

3.7%

1.5%

Blocks Censoring OFAC Sanctions

99%+

~45%

< 1%

0%

Proposer-Builder Separation (PBS) Compliance

Cross-Chain MEV Capture (e.g., via LayerZero, Axelar)

Avg. Payment to Proposer per Block

0.15 ETH

0.12 ETH

0.18 ETH

0.10 ETH

Private RPC Endpoint for Searchers

Integrated with UniswapX / CowSwap

Relay Operator Profit Margin (est.)

90%

85-90%

70-80%

60-70%

deep-dive
THE NEW CENSORSHIP FRONTIER

From OFAC Lists to Relay Filters

Regulatory pressure is shifting from transaction-level blacklists to the infrastructure layer, targeting the MEV relays that determine block inclusion.

Relays are the new choke point. Post-Merge, validators outsource block building to specialized builders via MEV-Boost relays. This centralizes censorship power, as a relay refusing to propagate a transaction prevents its inclusion in any block built through that relay.

OFAC compliance is now a relay-level filter. Major relays like BloXroute, Flashbots, and Manifold implemented filters to exclude OFAC-sanctioned addresses after the Tornado Cash sanctions. This created a two-tiered system where compliant relays have a higher chance of winning blocks.

The censorship metric is measurable. The 'censorship resistance' metric, tracked by organizations like Rated and EigenPhi, shows the percentage of blocks built without OFAC transactions. Periods of high MEV can push this above 90% on Ethereum, demonstrating systemic risk.

The counter-strategy is PBS bypass. Protocols like MEV-Share and SUAVE aim to decentralize block building by enabling permissionless, competitive markets for transaction ordering. This fragments the censorship vector across many actors instead of a few relay operators.

risk-analysis
WHY MEV RELAYS ARE THE NEW FOCUS FOR WATCHDOGS

The Slippery Slope of Enforcement

Regulators are pivoting from exchanges to the opaque infrastructure that powers them, where MEV relays control transaction ordering and billions in value.

01

The Centralized Censorship Point

MEV relays like Flashbots Protect and BloXroute act as mandatory gatekeepers for block builders, giving them unilateral power to filter transactions. This creates a single point of failure for OFAC compliance and market fairness.\n- ~90% of post-merge Ethereum blocks are built via relays\n- Blacklist enforcement is trivial at the relay level, not the protocol level\n- Creates regulatory arbitrage between compliant and non-compliant relay operators

~90%
Block Share
1
Choke Point
02

The Opaque Profit Machine

Relays monetize their privileged position by extracting value through order flow auctions (OFAs) and proprietary block building, creating conflicts of interest and hidden costs.\n- Billions in annual MEV is extracted and redistributed through these systems\n- Lack of transparency on who profits from transaction reordering (searchers, builders, relays)\n- Retail traders face hidden slippage as their orders are optimized for extractable value, not best execution

$B+
Annual Value
0%
Fee Transparency
03

The Protocol-Level Dilemma

Core protocols like Ethereum are designed to be neutral, but their reliance on off-chain infrastructure creates an enforcement loophole. Regulators can pressure relays without changing a single line of code.\n- Enforcement shifts from L1 to L2 and off-chain components like SUAVE or CowSwap solvers\n- Forces protocol designers to choose between decentralization and regulatory compliance\n- Sets precedent for targeting any critical middleware (e.g., The Graph, Chainlink oracles)

L1 -> L2
Enforcement Shift
All
Middleware at Risk
counter-argument
THE REGULATORY PIVOT

The "It's Just Software" Fallacy

Regulators are shifting focus from token classification to the centralized choke points in decentralized systems, with MEV relays as the primary target.

MEV relays are infrastructure. The SEC's case against Lido and Rocket Pool established that staking-as-a-service qualifies as a security. This legal precedent directly implicates relay operators like BloXroute and Agnostic, which control transaction ordering for billions in assets.

Relays create centralized points of failure. Unlike the distributed validator set, the relay network is an oligopoly. This centralized trust layer contradicts the 'decentralized software' narrative and provides a clear target for enforcement actions under existing financial regulations.

The precedent is Uniswap Labs. The SEC's Wells Notice to Uniswap did not target the UNI token or the protocol's immutable contracts. It targeted the frontend interface and wallet, the centralized points of user interaction and fee capture. Relays are the backend equivalent.

Evidence: Flashbots' SUAVE, a decentralized intent network, exists precisely to mitigate this regulatory risk by eliminating the need for trusted relays, demonstrating the industry's anticipatory shift.

future-outlook
THE REGULATORY FRONTIER

The Inevitable Clash and Paths Forward

MEV relays are becoming the primary regulatory target as they centralize transaction flow and control.

Relays centralize transaction flow. They are the single point where builders submit blocks to validators, creating a natural chokepoint for surveillance and control. This centralization is more actionable for regulators than the distributed network of searchers or validators.

The clash is jurisdictional. Regulators will target relay operators like BloXroute and Flashbots for their role in enabling front-running and sandwich attacks, treating them as financial intermediaries. This contrasts with the hands-off approach to the underlying consensus layer.

Evidence: The SEC's case against Coinbase cited its staking service as a security; the same logic applies to relays that profit from transaction ordering. The PBS (Proposer-Builder Separation) framework, designed for decentralization, ironically created this centralized, targetable entity.

takeaways
THE NEW FRONTIER OF BLOCKCHAIN SECURITY

Architectural Imperatives

MEV relays have evolved from simple block-building utilities into critical, centralized choke points, making them the primary target for regulators and protocol architects.

01

The Problem: Centralized Control of Block Space

The proposer-builder separation (PBS) model outsources block construction to a handful of dominant relays like Flashbots Protect and bloxroute. This creates a systemic risk where ~90% of Ethereum blocks flow through a few opaque entities, enabling censorship and front-running at the network's core.

~90%
Block Share
<10
Key Entities
02

The Solution: Enshrined PBS & Permissionless Relays

The long-term fix is to move PBS into the protocol layer, as envisioned by Ethereum's roadmap. Short-term, projects like SUAVE and Shutter Network are building decentralized alternatives. The goal is to make relay operation permissionless and verifiable, breaking the oligopoly.

  • Protocol-Level Guarantees: Eliminate trusted intermediaries.
  • Cryptographic Privacy: Use TEEs or FHE to hide transactions from builders.
0
Trust Assumption
100%
Uptime SLA
03

The Watchdog's Dilemma: Regulating a Black Box

Regulators like the SEC and CFTC are targeting MEV relays because they are identifiable, centralized businesses with clear jurisdiction. However, the technical opacity of MEV strategies (e.g., sandwich attacks, arbitrage) makes enforcement a game of whack-a-mole. The real battle is over data transparency and consumer protection.

  • Auditability: Who gets front-run and why?
  • Compliance: Can KYC/AML be applied to block builders?
$1B+
Annual MEV Extracted
High
Regulatory Risk
04

The Builder's Arms Race: Latency as a Weapon

The competitive edge for relays is sub-second latency to searchers and exclusive order flow (EOF) agreements. This creates a toxic incentive to centralize infrastructure (proximity to validators) and form backroom deals, undermining decentralization. Projects like EigenLayer and AltLayer are exploring decentralized sequencing to combat this.

  • Speed Kills: ~100ms advantages win billions.
  • EOF Fragmentation: Splits liquidity and user experience.
<100ms
Latency Edge
Exclusive
Order Flow
ENQUIRY

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