OKX Europe Ltd ("OKX") is a Malta-registered Crypto-Asset Service Provider (CASP) operating under the Markets in Crypto-Assets Regulation (MICAR). This document outlines OKX’s organizational measures to identify, prevent, manage, and disclose conflicts of interest, ensuring compliance with EU Regulation 2023/1114 (Article 72).
Understanding Conflicts of Interest
A conflict arises when OKX’s interests—financial, operational, or personal—compete with its duty to act in clients’ best interests. Key scenarios include:
- Financial gain at client expense
- Divergent interests in service outcomes
- Incentives to favor certain clients
👉 Explore OKX’s compliance framework
Identified Conflict Categories
1. Client-Detrimental Conflicts
OKX mitigates risks where conflicts may harm clients, such as:
- Shareholder or employee interests overriding client needs.
- Group entities influencing decisions (e.g., affiliated trading platforms).
- Product promotion where OKX has a financial stake.
2. Internal Conflicts
Conflicts harming OKX itself are monitored via:
- Economic interests in competing entities.
- Supervisory hierarchies with conflicting responsibilities.
Example: An employee holding tokens under OKX review must disclose this to avoid bias.
Mitigation Strategies
Organizational Controls
- Conflicts of Interest Register: Tracks and resolves conflicts transparently.
- Remuneration Policy: Ensures staff incentives align with client interests.
- Token Listing Reviews: Staff recusal for material conflicts; insider trading prevention.
Trading & Execution Safeguards
- Best Execution Policy: Prioritizes speed and total consideration for client orders.
- Market Surveillance: Detects manipulative practices.
👉 Learn about OKX’s trading rules
FAQs
1. How does OKX handle product-related conflicts?
OKX discloses financial stakes in promoted assets and implements review programs to prevent bias.
2. What if an employee has a conflicting interest?
They must report to supervisors and may be excluded from related decisions.
3. How are execution venues selected?
OKX prioritizes its order book but evaluates venues based on liquidity, cost, and speed.
Conclusion
OKX adheres to MICAR mandates through proactive conflict management, ensuring client-first operations and transparent disclosures. For details, refer to the full Conflicts of Interest Register.