Custody Policy for Crypto-Assets and Clients’ Money in the EEA

1. Purpose and Scope

OKCOIN EUROPE LTD (operating as "OKX") is a Malta-registered Crypto-Asset Service Provider (CASP) authorized under MiCAR to offer custody and related services across 27 EU countries. This Policy outlines the company’s custody framework for Crypto-Assets and Clients’ Money (collectively, Custody-Assets), ensuring compliance with regulatory standards.

Permitted Countries

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.

Permitted Services

• Exchange of crypto-assets (crypto-to-fiat and crypto-to-crypto)
• Trading platform operation
• Portfolio management
• Custody and administration of crypto-assets
• Transfer services

Core Objectives:

1. Explain OKX’s custody solution (technical/operational).
2. Detail security measures for storage, access, and management.
3. Outline reconciliation and accountability protocols.

2. General Principles

2.1. Segregation

• Client assets are segregated from company assets.
• Crypto-Assets are held in distinct blockchain addresses.

2.2. Protection and Use

• Safeguarded against theft, loss, or unauthorized use.
• No commercial use of Custody-Assets without client consent.

2.3. Ownership Rights

• Clients retain full ownership.
• Clear processes for executing client instructions (e.g., staking/voting).

2.4. Creditor Protection

• Custody-Assets are excluded from company insolvency proceedings.

2.5. Delegation/Outsourcing

• No sub-custodians appointed.

2.6. Liability

• Limited to incidents attributable to OKX (e.g., security breaches).
• Excludes losses from force majeure or external events.

2.7. Reconciliation

• Monthly audits of blockchain records vs. client holdings.

2.8. Record Keeping

• Comprehensive logs maintained per regulatory requirements.

3. Custody Platform

3.1. Service Offering

Wallet Infrastructure:

• Hot Wallets: Internet-connected for daily transactions.
• Cold Wallets: Offline storage for long-term security.

Security Measures:

• Multi-signature approvals, HSMs, 2FA, and role-based access.
• Insurance coverage against theft/loss.

👉 Explore OKX’s security protocols

3.2. Operational & ICT Risks

| Risk Type | Mitigation Strategies |
|--------------------|-----------------------------------------------|
| Human Errors | Training, automated checks |
| Cybersecurity | Encryption, intrusion detection |
| System Downtime | Redundant servers, backup protocols |

3.3. Client Reporting

• Quarterly statements of holdings.
• On-demand access to transaction history.

4. Reconciliations

• Automated monthly reconciliations.

• Discrepancies resolved via:

  1. Immediate investigation.
  2. Shortfall coverage during resolution.

5. Training & Policy Review

• Annual staff training on custody protocols.
• Board-approved updates to reflect regulatory changes.

FAQ

Q1: How are my Crypto-Assets protected?
A: Cold wallets (offline storage) secure 95% of assets; hot wallets use multi-signature access.

Q2: What happens if OKX becomes insolvent?
A: Client assets are segregated and cannot be claimed by creditors.

Q3: Can I delegate custody to a third party?
A: No—OKX does not permit sub-custody arrangements.

Q4: How often are holdings reconciled?
A: Monthly, with ad-hoc checks for high-volume transactions.

👉 Learn more about OKX’s compliance standards

### **Key Features**:  
- **SEO Keywords**: Crypto-Assets, Clients’ Money, MiCAR Compliance, Cold Storage, Reconciliation.  
- **Structure**: Hierarchical headings, bullet points, and a Markdown table for risk mitigation.  
- **Anchor Texts**: Two engaging CTAs linking to OKX.