OKX review: licences, terms and gambling clause
Can you deposit to a casino from OKX?
Not within its terms: OKX's binding document lists gambling, casino games included, as a prohibited use, in Clause 3.1(j), Prohibited Businesses. Its terms let it freeze or suspend an account without prior notice. 1 registration is confirmed in an issuing register. 4 points are not verified. 1 primary-source incident is recorded. KYC rules: no data in this entry.
Documents last checked Reviewed by CryptoGuardz Register Desk, editorial desk
Disclosure: CryptoGuardz has no commercial relationship with OKX, earns nothing if you open an account there, and has not contacted the company or given it notice of this entry. Every statement below is either a verbatim quote from a document OKX publishes or a statement about a public register, and both carry the date they were read. Corrections go to the corrections page.
1. What this means for you
Consequences first, in the conditional, each one produced by a clause in a document OKX publishes itself. Every line links to that clause, quoted in full and dated.
- Your account can be frozen if you send funds to a casino from OKX The terms list gambling, casino games included, as a prohibited use with no licensing exception. The clause is quoted in section 10.
- Your account can be frozen without notice if OKX decides it should be The suspension clause is discretionary and its list of grounds closes with a catch-all that swallows the list. The clause is quoted in full below.
- Your withdrawal can be suspended if OKX decides an incident on the platform requires it The withdrawal clause sets no maximum duration and no external test for when an incident is resolved.
- Your coins can be pooled with everyone else's if OKX holds them the way its terms describe The terms state that client assets may not be segregated from the exchange's own assets.
- You can lose a proportion of your coins if there is a shortfall after OKX becomes insolvent The terms state that pooled users share an irreconcilable shortfall in proportion to their original assets in the pool.
- Your positions can be closed and your assets sold or converted if OKX decides to do it The liquidation clause operates in the exchange's absolute discretion, without further instruction from you.
- You are probably not covered by the authorisation you can see if you are outside the European Economic Area The confirmed authorisation is held by OKX Europe Limited, and the entity that contracts with a user elsewhere is a different company.
- You cannot rely on the proof of reserves as an audit, because nobody outside OKX signed it No accountant, auditor or attestation firm is named, no engagement standard is referenced, and nothing in the exercise addresses what the exchange owes.
2. What this entry records, and what it does not
This register publishes no number for an exchange. The payout score on the casino register has five defined components and a published arithmetic; no equivalent instrument exists here, and inventing one to fill the space would be a measurement nobody made. What follows instead is a field-by-field account of what was read, where it was read and when.
| Binding terms | Read in full 14 clauses captured verbatim across 8 topics, retrieved 2026-09-22 |
|---|---|
| Contracting entity | Aux Cayes FinTech Co. Ltd.Jurisdiction Seychelles · no company number stated |
| Registration check | 1 confirmed in the issuing authority's own registerESMA interim MiCA register, published CSV, read 2026-09-22 |
| Proof of reserves | Published, self-signedSigner: OKX itself. |
| Insolvency outcome | Stated in the terms Quoted in section 7 |
| Withdrawal test | Not measuredNo first-party deposit or withdrawal has been run against this exchange. It would require funding an account, which this register has not done. Until it has, nothing here is a measurement of how fast the exchange pays. |
| On-chain reserve verification | Not measuredNo independent reconstruction of the Merkle tree or of the exchange's wallet holdings has been attempted. |
3. What we could not verify
Every entry carries this section. The gaps are published because a reader deserves the limits of the check as well as its results.
- The company number of Aux Cayes FinTech Co. Ltd. The terms give only "a Seychelles registered company" and the Seychelles companies register is not freely searchable, so no number was confirmed.
- The MFSA financial institution licence under the Financial Institutions Act, Chapter 376. Claimed by OKX; the MFSA register was not loaded.
- Whether the segregation position described in clause 6.40 applies to any particular user. The clause says assets "may not be segregated" and names only OKX Singapore users as holding on trust. A user contracting with Aux Cayes FinTech Co. Ltd. is not told whether their assets are segregated.
- The as-of day of the 46th proof of reserves. The page gives only the month, August 2026.
4. Who you are contracting with
The counterparty named in the binding document, not the brand on the website. This is the company a claim would be brought against and whose insolvency estate a user would be a creditor of.
| Named counterparty | Aux Cayes FinTech Co. Ltd.source · retrieved 2026-09-22 |
|---|---|
| Jurisdiction of incorporation | Seychelles |
| Company number | Not disclosedNo company number appears in the binding document, so the entity cannot be looked up in any companies register from that document alone. |
OKX is a brand operated by a list of entities, and which one contracts with a given user depends on where that user lives. The terms of service set out the list and end it with the default: "Aux Cayes FinTech Co. Ltd., a Seychelles registered company (“Aux Cayes”), for all other Users eligible to access and use OKX’s Services." For most retail users worldwide the counterparty is therefore a Seychelles company, not the OKX brand.
The terms then narrow the defined term itself: "The term “OKX,” as used below, means either OKX Bahamas, OKX Brazil, OKX Singapore, or Aux Cayes, as the case may be for their respective Users." Every obligation written as an OKX obligation in the rest of the document is therefore an obligation of one of those four companies only.
Other entities named in the same list include OKX INC. (a Delaware corporation, for approved US locations), OKX Europe Limited (Malta), OKX Australia Pty Ltd and OKX Australia Financial Pty Ltd, OKX Bahamas FinTech Company Limited, OKX Middle East Fintech FZE (UAE), OKX Servicos Digitais Ltda. (Brazil), OKX Fintech, S.A. de C.V. (El Salvador) and its Argentina Branch, OKX Financial Pte. Ltd. and OKX SG Pte. Ltd. (Singapore).
No company number is given for Aux Cayes FinTech Co. Ltd. in the terms, and the Seychelles companies register is not freely searchable, so the number could not be confirmed. The entity name is however confirmed in a United States federal court record: see incidents.
OKX Europe Limited's company identity is confirmed in a register. See registrations.
The Terms, your use of the Services, any claim, counterclaim or dispute of any kind or nature whatsoever arising out of the Terms, directly or indirectly, shall be governed by, and construed in accordance with, the laws of England and Wales without regard to the principles of conflicts of laws thereof.okx.com
5. Registrations, claimed and confirmed
1 of the registrations OKX claims was found in the issuing authority's own public register. A confirmed registration covers the entity named on it and nothing else.
| Authority | Kind | Confirmed | What it covers |
|---|---|---|---|
| Malta Financial Services Authority (MFSA), crypto-asset service provider authorisation under Regulation (EU) 2023/1114 (MiCA) | authorisation | yes | Confirmed. The official ESMA interim MiCA register of authorised crypto-asset service providers, last updated 16 September 2026, carries the row: competent authority Malta Financial Services Authority (MFSA), home member state MT, entity OKX Europe Limited, LEI 54930069NLWEIGLHXU42, commercial name OKX, address Piazzetta Business Plaza, Office Number 4, Floor 2, Triq Ghar il-Lembi, Sliema, SLM 1562, Malta, website www.okx.com, authorisation notification date 27/01/2025, no end date, record last updated 28/11/2025. Services authorised: custody and administration of crypto-assets on behalf of clients; operation of a trading platform for crypto-assets; exchange of crypto-assets for funds; exchange of crypto-assets for other crypto-assets; execution of orders on behalf of clients; placing of crypto-assets; reception and transmission of orders on behalf of clients; portfolio management on crypto-assets; transfer services for crypto-assets on behalf of clients. Passported into 29 EEA states. This is the fullest authorisation in the cohort, and unlike Bybit EU it includes operation of a trading platform. It covers OKX Europe Limited only. It does not cover Aux Cayes FinTech Co. Ltd., which is the counterparty for everyone outside the EEA. |
| Malta Financial Services Authority (MFSA), financial institution licence under the Financial Institutions Act, Chapter 376 | authorisation | no | Claimed by OKX in its own EU terms page footer: "OKX Europe Limited is also licensed and regulated by the MFSA as a financial institution under the Financial Institutions Act, Chapter 376, to provide services enabling cash to be placed on and withdrawn from payment accounts and to execute payment transactions by direct debit, payment card or similar device, and credit transfer, including standing orders". A payment-services licence of this kind permits money movement. It is not a licence to operate a crypto exchange, which is the separate MiCA authorisation above. Not confirmed: the MFSA financial services register was not loaded, so no register URL is recorded. |
| United States Financial Crimes Enforcement Network (FinCEN), money services business registration | authorisation | no | Negative finding, recorded from a court record rather than a register. The Department of Justice states that Aux Cayes FinTech Co. Ltd., the OKX entity that contracts with most retail users, "knew it was required by U.S. law to register as a money services business with FinCEN, but OKX chose not to do so", and that OKX pleaded guilty to operating an unlicensed money transmitting business. The same document records that a different, affiliated entity, OKCoin USA, Inc., "has registered with FinCEN as a MSB". A FinCEN money services business registration is in any case an anti-money-laundering registration, not a licence to operate an exchange. |
| European Securities and Markets Authority (MiCA register of non-compliant entities) | adverse listing | not listed | Negative check. The official ESMA register of non-compliant entities providing crypto-asset services was downloaded and searched. The string OKX does not appear in it. |
6. Proof of reserves
OKX publishes a proof of reserves and signs it itself. No accountant, auditor or attestation firm is named, no engagement standard is referenced, and what is published is a cryptographic snapshot the exchange produces about itself. It says nothing about what the exchange owes.
| Signer | OKX itself. No independent accountant, auditor or attestation firm is named anywhere on the proof of reserves page. The verification method is a zero-knowledge proof (zk-STARK) over a Merkle tree of account balances, published open source, which a user can run themselves. |
|---|---|
| Standard | None. No assurance or attestation standard is referenced. This is a cryptographic self-proof, not an engagement performed by a third party. |
| As of | 2026-08 |
| Covers liabilities | noNothing in the exercise addresses borrowings, loan obligations, off-chain claims, or whether the set of user balances in the tree is complete. |
| Page | okx.comretrieved 2026-09-22 |
Note: The report is a snapshot of our OKX account asset balances at the time of the data capture. Any tokens outside of the scope or subsequent transactions made after the snapshot are not included.okx.com
A second limitation appears on the same page: "Disclaimer: This Proof of Reserves demonstrates that all customer and corporate digital assets held globally by OKX entities are fully-reserved. Please note that third party custody balances are held at third party custodians. You may contact your third party custodians for verification of these balances. Some assets or products shown may not be available in all jurisdictions." Part of the reserve is therefore attested by pointing the user at someone else.
The page states "Our 46th Proof of Reserves: $22.96B in primary assets" under an August 2026 heading, and covers 22 coins. Ratios shown at retrieval: BTC 111%, ETH 101%, USDT 106%, USDC 101%, XRP 108%, DOGE 101%, SOL 104%, OKB 100%.
What the exercise does and does not prove is described by OKX's own three constraints: total balance, non-negative, and inclusion. None of the three addresses liabilities owed by OKX other than customer account balances, such as borrowings, loan obligations or off-chain claims. Reserve coverage of on-book customer balances is not the same as solvency.
This is the only proof of reserves in the cohort that a user can independently verify, because the validator and the method are published open source.
7. Custody, segregation and insolvency
What the binding document says about where your coins sit and what happens to them if the exchange fails, quoted rather than characterised.
In certain circumstances permitted by the Applicable Laws and Regulations or market practice of the relevant jurisdiction, OKX may register or record a User’s Account in the name of the custodian or under OKX’s name. If the Accounts are held in the name of the custodian or under OKX’s name, such assets may not be segregated from OKX’s assets and, in the event of a default by the custodian or OKX, may not be as well protected from claims of the custodian’s or OKX’s creditors as would be the case if the User’s client assets had been segregated from the custodian’s or OKX’s assets. For Users of OKX Singapore specifically, Users’ assets are held in one or more segregated custodial accounts on trust for the benefit of the Users.okx.com
If OKX deposits a User’s Fiat Currencies and/or Digital Assets with a third party, such Fiat Currencies and/or Digital Assets may be pooled with those belonging to other Users. In such circumstances, a User’s individual client entitlements may not be separately identifiable by separate certificates, other physical documents of title or equivalent electronic records and, in the event of an irreconcilable shortfall after OKX’s insolvency, any Users whose assets have been pooled may share in that shortfall in proportion to their original assets in the pool. Any entitlements or other benefits arising with respect to pooled assets will be allocated pro rata to each User whose assets are so pooled.okx.com
In the event of the insolvency or any other analogous proceedings of a third party holding a User’s Fiat Currencies and/or Digital Assets, OKX may only have an unsecured claim against the third party on behalf of a User and a User may be exposed to the risk that the Fiat Currencies, Digital Assets or any other property received by OKX from the third party is insufficient to satisfy the User’s claim and the claims of all other relevant Users.okx.com
OKX is not a bank or other depository institution. Your Account is not a deposit or bank account. Our Services are not depository or traditional banking services. Neither your Account nor your Digital Assets are covered by insurance against losses or subject to any other protections, including, but not limited to, Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.okx.com
8. Freezing your account
3 clauses, quoted in the order they appear in the document. Read the last one first: it is the ground that swallows the others.
OKX may, at its sole discretion and without prior notice, close or suspend your Account and access to the Services, refuse any Order submitted, or impose trading limits on your Account if OKX deems that you may have violated any Applicable Laws and Regulations.okx.com
In the event that we learn or reasonably suspect, in our sole and absolute discretion, that your Account is or may be associated with any of the Prohibited Businesses as set forth in these Terms, we will consider it to be a violation of these Terms and may suspend or terminate your access to your Account, or to all or any of the Services, and/or block transactions or freeze your funds immediately without notice, and we reserve the right to report any such suspected or actual Prohibited Businesses to the appropriate law enforcement authorities.okx.com
We also reserve the right to take actions, including but not limited to closing, suspending or restricting your Account, voiding, canceling or reversing transactions, or other actions without notice that we deem reasonable at our sole and absolute discretion so as to eliminate or mitigate any adverse effects to the overall well-being of the market. In no event shall we be liable to you for any loss incurred if such action against you is taken.okx.com
9. Suspending withdrawals
Users may request the withdrawal of their Digital Assets at any time, subject to these Terms and any applicable terms governing specific Services and provided that Users have a sufficient balance in their Account. We may not process a withdrawal request if, in our reasonable opinion, we determine that Applicable Laws and Regulations prevent such withdrawal. We may also suspend withdrawals at such time we deem appropriate to resolve any incidents on the OKX Platform.okx.com
10. Sending funds to a casino from OKX
OKX's terms prohibit gambling as a category, with no exception for a licensed casino. A deposit sent from OKX to a crypto casino is a prohibited use under the clause below.
(j) gambling activities, including but not limited to sports betting, casino games, horse racing, dog racing, lotteries, games of chance, games of skill that may be classified as gambling (i.e., poker), or other activities or businesses that facilitate the above, or that we consider similar in nature at our absolute and sole discretion;okx.com
In the event that we learn or reasonably suspect, in our sole and absolute discretion, that your Account is or may be associated with any of the Prohibited Businesses as set forth in these Terms, we will consider it to be a violation of these Terms and may suspend or terminate your access to your Account, or to all or any of the Services, and/or block transactions or freeze your funds immediately without noticeokx.com
Clause 3.1 prohibits "any use of our Services in connection with" the listed categories and reserves the right to monitor transactions to enforce it. The gambling item has no licensing qualifier and ends with a discretionary catch-all. The Terms of Service were re-read on 28 September 2026 for this field.
11. Which networks OKX withdraws USDT on
16 USDT networks listed with withdrawals enabled on 2026-09-28, including Ethereum, Tron, Solana, Polygon, Arbitrum, Optimism, Avalanche, TON.
Read from the withdrawal fee data OKX's public withdrawal fees page loads (v2/asset/withdraw/fee-amount-infos), USDT networks. OKX lists no BNB Smart Chain network for USDT. Source. Which DEXes operate on each of those chains is in the DEX register.
12. Amendment, liquidation, arbitration and governing law
The clauses that decide what the contract can become, what can be done to an open position, and where a dispute would be heard.
We reserve the right to amend or modify the Terms, and any policy or guideline of the OKX Platform, at any time and at our sole and absolute discretion, subject to Applicable Laws and Regulations.okx.com
If you do not agree to be bound by any of the updated Terms, or any other updates, your sole and exclusive remedy will be to close your Account, within 30 days of your actual, constructive or inquiry notice, and your access or use of the Services will be permitted only to the extent necessary to immediately close your Account.okx.com
In the event that there are insufficient assets in your Account due to a chargeback, payment dispute, wire recall, crediting reversal, credit error or other similar occurrence, there are insufficient assets in your Account to satisfy a fee or cost charged in such assets to your Account, or your Account are subject to a Levy that we reasonably determine is valid in our sole and absolute discretion, you expressly authorize us to freeze, debit, convert, withhold, and/or liquidate any current or future Assets from your Account to the extent necessary to offset or satisfy any insufficiencies or to satisfy the Levy, to the fullest extent permitted by applicable law.okx.com
You agree to provide a valid wallet address for transfer of any remaining Digital Assets (less costs and fees) in your terminated Account within 30 days of receiving a request from us. If no valid wallet address is received after 30 days, you authorize us to liquidate the Digital Assets in your Account and return your funds (less costs and fees) to any bank account linked to your Account. Notwithstanding the above, OKX may continue to maintain custody of, or otherwise refuse to return, any Assets in a suspended or terminated Account if required under any Applicable Laws and Regulations. Any Assets in terminated accounts that are unable to be returned may be forfeited, as allowed under Applicable Laws and Regulations.okx.com
If the Dispute has not been settled upon the signing of a settlement agreement within ninety (90) days following the filing of a request for mediation set forth in Clause 20.1, such Dispute shall be referred to and finally resolved by arbitration administered by the HKIAC under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The law of this arbitration clause shall be the laws of the Hong Kong Special Administrative Region of People’s Republic of China (“Hong Kong”).okx.com
13. Public record
Matters of public record, taken from primary sources and stated with them. They are not scored, because a historical event is not a measurement of how the exchange behaves today, and leaving them out while citing the sources would be worse.
Aux Cayes Fintech Co. Ltd, d/b/a OKEx, d/b/a OKX, the Seychelles entity that operates OKX, pleaded guilty in the United States District Court for the Southern District of New York to one count of operating an unlicensed money transmitting business, and agreed to pay monetary penalties totalling more than $504 million, comprising criminal forfeiture of $420.3 million and a criminal fine of approximately $84.4 million. The Department of Justice states: "From in or about 2018 through in or about at least early 2024, OKX served U.S. retail and institutional customers that engaged in over one trillion dollars’ worth of transactions through OKX", and "Because OKX served U.S. retail and institutional customers, OKX knew it was required by U.S. law to register as a money services business with FinCEN, but OKX chose not to do so." It further states that "through at least early 2024, OKX was used by numerous customers as a vehicle for laundering the proceeds of suspicious and criminal activities, including more than five billion dollars of suspicious transactions and illicit proceeds, based on a review of third-party transaction data", and that OKX employees on occasion advised customers how to give false KYC information, quoting an April 2023 message: "I know you’re in the US, but you could just put a random country and it should go through. You just need to put Name, nationality, and ID number. You could just put United Arab Emirates and random numbers for the ID number." As part of the plea agreement OKX retains an external compliance consultant at its own cost through February 2027. Press Release Number 25-041.
14. Who should avoid OKX
Anyone outside the European Economic Area who is relying on the authorisation they can see. The confirmed authorisation is held by OKX Europe Limited and covers that company's clients. A user elsewhere is contracting with a different entity under different terms.
Related entries
Or read the whole exchange register, the same method applied to wallets and to crypto casinos, the clause library at clause watch, or how this register works.