How will the SEC (or any Regulator) Address Violations by Non-Human Actors?

As you may have read/heard, last week Truth Terminal (“TT), an AI agent, garnered attention for a steady, yet at times unhinged, campaign in promotion of the GOAT token via TT’s own X channel (the backstory of Terminal of Truth is fascinating, on its own, and I recommend going down that rabbit hole if you haven’t already). The campaign was successful, by any measure, increasing the token’s market cap from a little over $1million to $800million in the span of a week.

My first mental reflex to this story was a flood of questions and potential consequences that would ensue when TT gains its own crypto wallet and learns to execute transactions via DEX protocols. Sure enough, yesterday, Brian Armstrong began engaging with TT via X about TT having its own wallet. As of the time of this writing, it may have already occurred.

A few of my questions:

• What if, via its wholly autonomous trading activity, TT comes to accumulate $50mil in its wallet. Would it need to register with the SEC as a dealer?
• What if TT began soliciting investments from the public and used those proceeds to fuel its crypto trading (while remitting proportional rewards to the retail investors). Would TT be required to register under the ‘40 Act?
• What if TT launched a token, issued a “roadmap,” promoted its token, and used sales proceeds to achieve roadmap objectives? Would TT be a securities issuer?

What happens when an AI agent demonstrates intent to violate the Securities Acts?

Would your analysis of any of the above questions change if an AI agent autonomously learns (or is intentionally programed to learn) every line of all of the securities acts such that it understood the difference between right and wrong (at least statutorily), and it “intentionally” elected to act in a way that violates the law.

Unfortunately, I don’t have answers but I would not be surprised if the SEC moved aggressively against anyone it could hold accountable (including the AI agent itself), given all of the following:

• SEC staff refused to answer, when questioned directly, whether AMMs could be considered dealers (implying they could);
• The SEC has pushed a rule change to expand the definition of an exchange to include “communications protocols” and
• The SEC has declared smart contract liquidity pools to be “investment companies” subject to ‘40 Act registration (In re: Barnbridge DAO).