OKX Singapore User Specific Risk and Safeguarding Disclosures

Last updated: 18 June 2025

The Monetary Authority of Singapore (“MAS”) requires OKX Singapore to provide certain disclosures to you as a customer of a digital payment token (“DPT”) service provider. Please read these disclosures before using OKX Singapore’s DPT services and depositing any Asset with OKX Singapore. Terms used but not defined herein shall have the same meanings as assigned to them in the OKX

. These disclosures only apply to Users of OKX Singapore only and not Users of other OKX entities.

1. Risk Warning on Digital Payment Tokens Services

The MAS requires us to provide this risk warning to you as a customer of a DPT service provider.

Before you pay your DPT service provider any money or DPT, you should be aware of the following:

(i) Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider if your DPT service provider’s business fails.

(ii) You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.

(iii) You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.

(iv) You should be aware that your DPT service provider, as part of its license to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin."

Please note that the above risk warning also applies to your payment of money or DPT to any third party under any agreement you entered into (a) upon inducement by OKX Singapore for such third party to buy or sell DPTs; or (b) under an arrangement by OKX Singapore for the transmission of your DPTs.

2. Disclosure on Custody Arrangements for Fiat and DPTs

2.1 General Custody/Safeguarding Arrangements

The Fiat Currencies belonging to OKX Singapore Users are directly deposited and held on trust for the benefit of OKX Singapore Users in one or more segregated trust accounts (“Fiat Trust Accounts”) at one or more duly-registered and licensed third-party banking institutions (“Safeguarding Institution”) in accordance to the Safeguarding Institution’ terms of service.

The DPTs belonging to OKX Singapore users are held on trust accounts (“DPT Trust Accounts”) maintained with OKX Singapore or by OKX Singapore on behalf of OKX Singapore users in trust accounts maintained with such persons appointed by OKX Singapore in accordance to safeguarding agreements that gives OKX Singapore strict supervision and control over such Safeguarding Persons (“Third-Party Safeguarding Persons”, and collectively with OKX Singapore, “Safeguarding Persons”). To date, such Third-Party Safeguarding Person include OKBL Pte. Ltd. and OKBL Technology Company Limited, which are affiliates of OKX Singapore.

Where any of such Third-Party Safeguarding Person is located outside Singapore, please note that:

(a) the laws and practices relating to trust accounts in the jurisdiction under which the Third-Party Safeguarding Person is licensed, registered or authorised may be different from the laws and practices in Singapore relating to trust accounts; and

(b) any such differences may affect your ability to recover your assets deposited in the trust account with such Third-Party Safeguarding Person. For example, there may be a prolonged delay in the recovery process due to the need to obtain foreign regulatory approvals, there may be the need to undergo foreign courts processes before the assets can be returned, or the applicable insolvency laws may have changed during the intervening period.

In the event of OKX Singapore’s bankruptcy, current law and practices suggests that your Fiat Currencies and DPTs held in trust accounts will not be subject to claims from OKX Singapore’s creditors. For the avoidance of doubt, OKX Singapore holding your Assets in trust accounts shall not affect the right of set off that The Group may have against your Assets for any sums that you may owe the Group.

Notwithstanding the foregoing, due to operational needs, including for OKX Singapore to facilitate your transactions from time to time, there may be circumstances whereby not all Assets will be held in trust accounts, although we will endeavour to do so as soon as practicable. Assets that are not held in trust accounts may not be afforded the same protection as those held in trust accounts and may be subject to additional risk of losses.

2.2 Commingling of Assets

Fiat Currencies belonging to you will be held together and commingled with the Fiat Currencies belonging to other Users in Fiat Trust Accounts.

DPTs belonging to you will be held together and commingled with the DPTs belonging to other Users in DPT Trust Accounts. Please note that your interest in the DPTs may not be identifiable by separate physical documents or electronic records, although OKX Singapore will maintain records of your interests in the DPTs belonging to you that have been commingled. You may contact customer service for all information relating to the DPTs belonging to you.

Please note that as a result of such commingling, you may not be able to recover the full value of your Fiat Currencies or DPTs in the event of a shortfall in such pooled Fiat Currencies or pooled DPTs respectively.

2.3 Fees for DPT Safeguarding Arrangements

OKX Singapore currently does not charge any fees for maintaining the DPT safeguarding arrangements for OKX Singapore Users. However, OKX Singapore reserves the right to charge fees for such DPT safeguarding arrangements in the future upon giving notice to the Users.

2.4 Disclaimers relating to Safeguarding Arrangements

(a) The Third-Party Safeguarding Persons must hold and record your DPTs in accordance with OKX Singapore’s instructions, and your DPTs must be kept separate from any assets belonging to the Third-Party Safeguarding Persons. A director comprising a part of OKX Singapore's board is authorized to provide instructions to such Third-Party Safeguarding Persons.

(b) The Third-Party Safeguard Persons must provide sufficient information to OKX Singapore on a timely basis as OKX Singapore may reasonably require to comply with its record-keeping obligations under any written law.

(c) The Third-Party Safeguarding Persons must not permit any withdrawal of your DPTs from the trust account, except for delivery of your DPTs to OKX Singapore or to any other person upon receipt of OKX Singapore’s written instructions.

(d) Unless expressly stated otherwise, these arrangements do not create any contractual relationship between you and the Safeguarding Institution and/or Safeguarding Person, and you have no rights to enforce or enjoy the benefit of any contractual term against the Safeguarding Institution and/or Safeguarding Person.

(e) Further, the safeguarding arrangements do not guarantee that OKX Singapore will be able to satisfy all of your claims in relation to Assets belonging to you. The Safeguarding Institution and/or Safeguarding Person will not be liable to compensate you where the Assets held in the trust accounts are insufficient to satisfy all of your claims.

(f) If any Safeguarding Institution or Safeguarding Person becomes insolvent, there is a risk that you may not be able to recover all of the Assets held in trust accounts on your behalf.

(g) If the Safeguarding Institution or Safeguarding Person is in default of any obligation in relation to the safeguarding of your Assets, there is a risk that you may not be able to recover all of the Assets that are held in trust accounts on your behalf.

3. Authorization to Deal with Your Assets

By depositing your Assets with OKX Singapore, you appoint OKX Singapore as your nominee for the purpose of buying, selling and holding your Assets on your behalf. This means OKX Singapore hold the legal title to, and you are the beneficial owner of, the Assets OKX Singapore holds on your behalf. As the beneficial owner, you have the absolute rights to the financial value (subject to the OKX Terms of Service) of the Assets OKX Singapore hold for you. Subject to the OKX Terms of Service, OKX Singapore will generally only deal with your Assets upon receiving instructions from you or your authorized representative, through the OKX Platform or otherwise.

OKX Singapore will not hold your assets as collateral and will not otherwise sell, transfer, loan, hypothecate, or otherwise alienate your assets unless instructed by you or by a court of competent jurisdiction.

4. Beneficial Ownership of DPTs

Your beneficial Ownership of the DPTs only means that you only have the absolute rights to the financial value of the DPTs (subject to OKX’s Terms of Service). Unless specifically set out in writing, your beneficial ownership of the DPTs does not entitle you any further rights that comes with legal ownership of the DPT. Such rights include but are not limited to ownership of any new DPT derived from Hard Fork of the original DPT, and token governance rights.

5. DPT Storage Arrangements

5.1 Balancing Between Hot and Cold Wallets

DPTs belonging to OKX Singapore Users are stored in cold wallets and hot wallets. The hot wallets’ private keys are connected to the internet, and a minority of DPTs is stored in the hot wallets to meet liquidity needs for OKX Singapore to provide its Services to you, such as trading and withdrawal of DPTs by Users. The cold wallets’ private keys are stored offline and the majority of DPTs belonging to OKX Singapore Users are stored in cold wallets. As cold wallets are not connected to the internet or any other form of online or wireless communications, they are generally thought to provide a higher level of security as they may be less susceptible to cyber-attacks.

To ensure that the majority of DPTs belonging to Users are stored in cold wallets, DPTs are moved automatically from the hot wallets to the cold wallets on a daily basis if the DPTs in the cold wallets fall below 90% of the total DPT value belonging to customers. If the DPTs in the hot wallets fall below the threshold required to meet liquidity needs, OKX Singapore will conduct a review to determine the number of DPTs to be transferred into the hot wallets initiate a manual transfer of the required DPTs.

5.2 Security Measures

OKX Singapore implements appropriate security measures to mitigate the risk of loss of customer DPTs due to cyber attacks. This includes storing the majority of customer DPTs in cold wallets and requiring manual authorization by more than one person for any transfer of DPTs out of cold wallets, implementing MAS’s principles of “never alone”, “segregation of duties” and “least privilege” in our internal custody and wallet management policies, implementing a risk monitoring system for any withdrawals out of hot wallets, and conducting internal audits on our custody and custody management systems.

6. Other Disclosures

In the event that you believe that DPTs are lost due to fraud or negligence by any Third-Party Safeguarding Person or OKX Singapore in the course OKX Singapore performing its duty to you as a Safeguarding Person, please contact customer service immediately.

If it is determined from our internal investigation that your loss of DPTs is caused by negligence or fraud of OKX or our employees, we will compensate affected customers for the full value of the lost assets at the time the loss is discovered to the extent of our negligence or fault. In no event shall OKX and/or OKX’s Related Parties be liable to you for any Indirect Losses. Any Losses that are not due to fraud or negligence by OKX Singapore in the course OKX Singapore performing its duty to you as a Safeguarding Person shall follow the exclusions and limitations set out in the OKX Terms of Service.

The Third-Party Safeguarding Person will be fully liable in the event of any loss of your assets maintained in the trust account caused by fraud or negligence on the part of Third-Party Safeguarding Person or any of the Third-Party Safeguarding Person's agents.

Should you wish to have more information relating to the safeguarding of your DPTs, you may reach out to customer support on the OKX Platform.

7. Dealing with Authorised Persons

You agree that OKX Singapore is entitled to deal with any individual who has been duly authorized by you to act on your behalf in connection with all dealings, instructions, and communications between you and OKX Singapore. You shall provide written proof of such authorization, including the full name, contact details, and scope of authority of the authorized person. OKX Singapore may rely on such authorization until it receives written notice from you of any revocation or amendment of the authorization. You acknowledge that OKX Singapore shall not be responsible for verifying the authenticity or validity of any instruction or communication received from an authorized person unless you have provided notice of revocation or amendment of the authorization.

8. Rights arising from DPTs, Forks and Airdrops

You acknowledge that in using the services provided by OKX Singapore, there is a risk that forks and / or airdrops will have a potential adverse effect on the value and operation of DPTs you participate in, and OKX Singapore is not responsible for this.

OKX Singapore will assess at its sole discretion whether it supports a fork or airdrop, and OKX Singapore is under no obligation to support any fork or airdrop.

OKX Singapore will use reasonable endeavors to provide you with notice of forks and airdrops we accept by publishing such notice on our Site.

If there is a fork or airdrop we accept, OKX Singapore may determine in its sole discretion, whether to credit any DPTs and/or received by us to your account, and upon what terms to do so. OKX Singapore will not be liable to you for failure to credit any DPT and/or benefits to you. You further agree that any DPTs and/or benefits in relation to an airdrop or fork do not create or represent any relationship between us and the sender and/or the related DPT network, and that we are not subject to any obligations whatsoever as they relate to the sender and/or the related DPT network.

9. Conflicts of interest

OKX Singapore maintains and operates effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest.

An example of potential or actual conflicts of interest that may arise in the course of us provide our services to you are conflicts of interests related to ‘vertical integration’ of DPT trading activities. We operate vertically integrated business models by conducting multiple types of DPT trading activities through a single legal entity, or through an affiliated group of entities that is part of a wider group structure.

With multiple types of DPT trading activities conducted with an affiliated group of entities, the primary risk identified is misuse of information. One example of this would be ‘front-running’, where an affiliated entity acts on advance knowledge of orders or transactions from another group entity.

In relation to the foregoing conflicts of interests, controls are in place which align to those implemented by banks and other financial institutions. These include (but are not limited to): self-trade prevention, physical segregation of trading desks, role-based restrictions related to information flows, along with trade monitoring and surveillance.

However, where these are not sufficient to ensure, with reasonable confidence, that risks of damage to your interests will be prevented, OKX Singapore shall, as a measure of last resort, disclose to you the relevant conflicts and the steps taken to mitigate against them.

10. OKX’s own token

You acknowledge that OKX issues its own tokens from time to time (the “OKX Tokens”).

Potential Conflicts of Interests arising from the issuance of OKX Tokens

As a result of OKX issuing its own tokens, you acknowledge that the following conflicts of interest might arise:

(a) Issuance of OKX Tokens

As both the issuer of the OKX Tokens and the operator of the OKX exchange platform, OKX Singapore has a financial interest in the success of the OKX Tokens. This may create situations where OKX Singapore’s interests as a coin issuer could conflict with OKX Singapore’s role as a neutral marketplace operator.

(b) Preferential Treatment

There may be instances where OKX Singapore promotes, lists, or offers incentives related to the OKX Tokens. While OKX Singapore strives to treat all DPTs equally, you acknowledge that the OKX Tokens may receive preferential treatment in certain marketing or fee structures. This could include lower listing or trading fees for the OKX Tokens compared to other DPTs listed on our platform.

(c) Market Influence

OKX Singapore has control over the market listing and trading of the OKX Tokens and may participate in activities such as market making or promotional trading incentives to support liquidity. While these activities are intended to ensure a smooth trading experience, they may create the appearance of market bias or affect the price and liquidity of the Coin.

(d) Insider Information

As the issuer of the OKX Tokens, OKX Singapore may possess material non-public information about future developments that could affect the price or demand for the Coin. OKX Singapore is committed to avoiding the misuse of any such information, and OKX Singapore adheres to strict internal controls to prevent insider trading and other market abuses.

Steps and Measures to Prevent or Mitigate Identified Conflicts of Interests

OKX Singapore endeavors to prevent or mitigate the foregoing conflicts of interests in the following ways:

(a) Transparency in Operations

OKX Singapore will maintain and publish auditable records of transactions relating to OKX Tokens, including issuance, buyback and employee trading. All incentives tied to the OKX tokens, such as fee discounts, staking rewards, or exclusive access to services will be fully disclosed.

(b) Independent Audits

OKX Singapore will conduct regular third-party security audits of the OKX Token’s smart contract to identify and fix vulnerabilities and engage independent auditors to review OKX Singapore’s handling of the OKX Tokens and other operations to detect and address conflicts.

(c) Internal Trading Policies

OKX Singapore prohibits employees from OKX Token’s during sensitive periods, such as just before token listings or partnership announcements. Sensitive information about upcoming OKX Token listings, supply changes or strategic decisions will be limited to essential personnel only. OKX Singapore may also impose lock-up periods for board members and employees involved in OKX Singapore’s business of operating a market, acting as a broker or agent, or conducting OTC business from OKX Singapore’s own account.

(d) Separate surveillance function

OKX Singapore’s employees involved in the surveillance function will be separate from employees whose duties and responsibilities pertain to OKX Singapore’s business of operating a market, acting as a broker or agent, or conducting OTC business from OKX Singapore’s own account.

Proprietary Holdings at the Point of Listing of OKX Tokens

You acknowledge that at the time of listing new OKX Tokens, OKX Singapore may hold proprietary holdings of such new OKX Tokens.

OKX Singapore’s proprietary holdings of such new OKX Tokens are intended to support the ecosystem of such new OKX Tokens, align incentives with the new OKX Tokens’ long-term success, and facilitate operations on OKX where applicable.

You should consider the OKX Singapore’s proprietary holdings and the potential for conflicts of interest when evaluating your participation in transactions involving the new OKX Tokens.

11. Digital Assets Listing and Governance Policy

OKX Singapore adheres to the OKX Group’s Global Token Listing Policy, as modified by an OKX Singapore addendum, in its conduct of listing and delisting of DPTs.

OKX Singapore is accountable and responsible for the DPTs it chooses to list on its platform. This Digital Assets Listing and Governance Policy aims to provide customers with greater clarity and transparency on how DPTs listed on OKX Singapore’s platform are evaluated, enabling more informed assessments as it relates to OKX Singapore’s listing process.

Accordingly, each DPT listed by OKX Singapore undergoes a rigorous multi-stage evaluation process. This includes an initial due diligence assessment conducted by the OKX Global research team. Following which, each DPT is subject to a coordinated evaluation process involving the collaboration of various departments within OKX Singapore (“Evaluation Process”).

OKX Singapore has also established a Token Listing Management Committee (“Committee”) to assist OKX Singapore’s board in discharging its responsibility for maintaining control and oversight over the management of relevant risks associated with the Evaluation Process. The Committee comprises of senior managers including the Chief Executive Officer, Head of Strategy and Operations, Head of Product, and the respective business heads involved in the Evaluation Process.

DPT Listing Evaluation Process

The Evaluation Process considers among others, the following criteria as part of its assessment of a DPT for listing on the OKX Singapore platform:

(a) Compliance Assessment:

Each DPT will undergo a compliance review by OKX Singapore’s compliance team which includes an analysis of the DPT’s Tokenomics (i.e. its function, features, and utility), underlying blockchain ecosystems, as well as any associated sanctions, adverse media, or geographical risks. The compliance assessment also takes into consideration MAS-specific regulatory requirements (e.g. PSN02).

(b) Risk Assessment:

Each DPT will undergo a holistic risk analysis that considers the DPT’s market capitalisation, liquidity and volatility to identify potential market-related risks.

(c) Information Security:

Each DPT will undergo a security review by OKX Singapore’s information security department which includes an assessment of the DPT’s underlying blockchain, associated vulnerabilities, network resilience, and any past security incidents such as vulnerabilities, attacks, or breaches.

(d) Legal Assessment:

Each DPT undergoes an internal legal assessment including a review of its legal characterisation, whether any rights or entitlements are attached to the DPT, whether OKX Group has any material interest associated with the DPT.

DPT Listing Process

Each department involved in the Evaluation Process will assess the DPT against its respective set of criteria and assign a risk rating. The results are presented to the Committee, which will then decide whether the DPT is suitable for listing or requires further review. Once approved by the Committee, the DPT may be listed on OKX Singapore’s platform.

Ongoing Review

All DPTs listed on OKX Singapore's trading platform will undergo ongoing monitoring and be reviewed at least annually, depending on the risk rating of the token.

DPT Delisting Process

OKX Singapore may suspend, cease, or delist a DPT from its platform if it determines, at its discretion and based on ongoing risk-based monitoring, that the DPT poses a material risk. The decision to suspend or delist a DPT from OKX Singapore’s platform is typically conditioned on the DPT’s failure to meet the required standards expected in relation to the criteria set out in the Evaluation Process above. Common reasons for delisting a DPT include, adverse media findings, project termination, liquidity issues, or fraud (non-exhaustive).

OKX Singapore will make best efforts to give affected customers at least 1 weeks’ notice of the delisting to give them an opportunity to trade or sell the affected DPT. On the delisting date, OKX Singapore will suspend trading for the affected DPT, but customers will still be able to withdraw the affected DPT from their account.

In exceptional circumstances, OKX Singapore may delist a DPT immediately without advanced notice, where it determines there is a good cause to do so (e.g. due to legal or regulatory reasons, smart contract security risks, etc). Measures taken by OKX Singapore, and the impact on affected services will be communicated to the customers during the event and will vary depending on the circumstances. OKX Singapore shall not be liable for any losses, damages, or claims arising directly or indirectly from the immediate delisting, suspension, or ceasing of a DPT under such exceptional circumstances, including but not limited to any inability to access, trade, or withdraw the affected DPT, or any fluctuations in its value. Customers acknowledge and agree that OKX Singapore may take such actions without prior notice and that their use of OKX Singapore services is subject to this risk.

Unfair or Disorderly Trading Risks

OKX Singapore recognises the risk of unfair or disorderly trading that may arise from the nature of DPT activities. To mitigate this, OKX Singapore has implemented the necessary safeguards to ensure the fair and orderly trading of DPTs by its customers on the OKX Singapore platform.

OKX Singapore customers must agree and accept our OKX

when accessing trading services through OKX Singapore. The OKX Terms of Service includes a comprehensive set of rules and operational controls to prevent and manage unfair or disorderly trading conduct. Examples of key measures include:

(a) Strict prohibition of market manipulation, where a person takes action intended to deceive, mislead, or improperly take advantage of other traders or the platform itself, or to artificially control or manipulate the price or trading volume of an asset, whether on or outside OKX Singapore’s platforms. This prohibition covers activities both on and off OKX Singapore platforms, which includes front-running, wash trading, spoofing, layering, churning, and quote stuffing.

(b) Broad discretionary authority to intervene and take action to preserve market integrity. OKX Singapore is empowered to take actions including, without limitation, halting trading on certain token pairs or the entire platform, modifying risk-mitigating parameters, restricting trader access or order types (e.g., limiting to post-only or limit orders), cancelling resting orders, updating access criteria or other operational controls.

(c) OKX Singapore enforces an employee trading policy and a trade surveillance program to prevent misuse of inside, corporate, or proprietary information. Employees are prohibited from using such information for trading and are required to follow strict compliance protocols.

(d) Self-Trade Prevention. The platform has

to prevent self-trading (where the same trader would be both buyer and seller in a transaction). If such a scenario is detected, the platform cancels the involved orders or decrements them appropriately to avoid self-execution.

(e) Whistleblowing and Handling of Complaints. OKX Singapore takes all complaints relating to unfair or disorderly trading seriously, including those raised through internal or external whistleblowing channels. We maintain policies and procedures to enable the confidential reporting of suspected misconduct, including market manipulation, abusive trading practices, or breaches of internal controls. Reports received are promptly reviewed by OKX Singapore’s compliance department, with appropriate follow-up actions taken where necessary to safeguard market integrity.

Conflicts of Interest

OKX Singapore does not, and does not intend to, receive any incentives or any fees from DPT projects to list any DPTs.

OKX Singapore recognises that the receipt of any incentives in relation to the provision of its services in respect of DTs gives rise to potential and actual conflicts of interest. Such conflicts may unduly influence OKX Singapore’s commercial decisions to support or list certain DPTs and may interfere with the independence and effectiveness of this Digital Assets Listing and Governance Policy. While OKX Singapore acknowledges that appropriate measures (e.g. customer disclosures) must be implemented to address such risks, it reiterates that it does not, and does not intend to, receive any incentives or fees from DPT projects to list any DPT.

In addition, OKX Singapore does not issue its own DPTs. However, should OKX Singapore intend to do so in the future, OKX Singapore acknowledges the actual or potential conflicts of interest that may arise and affect the application of this Digital Assets Listing and Governance Policy. In such circumstances, OKX Singapore will implement appropriate measures (e.g. customer disclosures) to address and mitigate such risks accordingly.

To further safeguard the integrity of its DPT Listing and Evaluation processes, OKX Singapore maintains strict segregation between the various departments involved to ensure independence in their respective roles. All individuals participating in the DPT Listing and Evaluation processes are required to declare any personal conflicts of interest (i.e. such as having personal investments in the DPT under their review). Where such conflicts of interest arise, the concerned evaluator will be reassigned to another qualified analyst. If reassignment is not possible, the concerned evaluator will disclose their conflict of interest to an independent compliance team, which will determine whether the evaluator may be permitted to continue his or her existing evaluation. While affiliates of OKX Singapore may invest in certain projects or hold DPTs in certain projects, these affiliates have no influence or role in the decision-making process for listing of those projects’ DPTs on OKX Singapore.

This Digital Assets Listing and Governance Policy is applied in an objective and neutral manner and should not be construed as an endorsement of any particular DPT that make available forward-looking price expectations or otherwise seek to entice customers to favour the trading of any DPTs.