Best Execution Policy for Crypto-Asset Services in the EEA

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In today's rapidly evolving digital asset landscape, ensuring fair, transparent, and efficient trade execution is critical for maintaining trust and regulatory compliance. This Best Execution Policy outlines how OKX, operated by OKCoin Europe Ltd — a licensed Crypto-Asset Service Provider (CASP) in the European Economic Area (EEA) — fulfills its obligation to achieve the best possible outcome for clients when executing crypto-asset orders.

As a regulated entity under the Malta Financial Services Authority (MFSA) and compliant with the Markets in Crypto-Assets Regulation (MiCAR) (EU) 2023/1114, OKX is committed to upholding high standards of operational integrity across all permitted services and jurisdictions.

Scope of Services and Regulatory Authorization

OKCoin Europe Ltd is a private limited company registered in Malta (registration number C88193), operating under the brand name OKX. Since January 27, 2025, it has been authorized as a CASP under Malta’s Markets in Crypto Assets Act (Chapter 647). On February 14, 2025, it received authorization to provide crypto-asset services across 27 EU countries under MiCAR Article 63.

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The following nations are included in OKX’s permitted service region:

Permitted Crypto-Asset Services Include:

This Best Execution Policy applies to all clients receiving the following services: order execution, order transmission, portfolio management, and any dealing on behalf of clients involving crypto-assets.

Execution Venues and Order Routing Strategy

Given that OKX operates its own centralized cryptocurrency exchange, it may act as an Execution Venue by routing client orders — particularly those arising from portfolio management activities — to its internal central limit order book.

The company may also utilize third-party execution venues that meet strict criteria for reliability, transparency, and market depth. All selected venues must support OKX’s ability to comply with MiCAR rules and deliver optimal execution outcomes.

To maintain best execution standards, the company evaluates potential venues based on:

Only venues that consistently demonstrate strong performance across these metrics are included in the routing framework.

Key Execution Factors for Optimal Trade Outcomes

Under this policy, OKX is obligated to take all sufficient steps to obtain the best possible result for clients. This determination is made by assessing several interrelated factors — collectively known as Execution Factors:

1. Total Consideration (Price + Cost)

This refers to the net cost of a transaction to the client, including:

OKX aims to minimize total cost while ensuring timely and reliable settlement.

2. Speed of Execution

Speed is evaluated based on:

In fast-moving markets, rapid execution may outweigh marginal price improvements.

3. Likelihood of Execution and Settlement

Orders are assessed for risks related to:

High-probability venues are prioritized to reduce failed or delayed trades.

4. Order Size and Market Impact

Large orders are handled with care to avoid adverse price movements. Strategies such as time-weighted or volume-weighted execution may be employed where appropriate.

5. Other Relevant Considerations

Additional factors may include:

While Total Consideration and Speed are typically prioritized due to the nature of crypto markets, other factors may take precedence when they contribute more significantly to overall client benefit.

⚠️ Important Note: If a client provides specific instructions (e.g., “execute at any price”), OKX will follow those directions. However, such instructions may limit the firm’s ability to achieve best execution under this policy.

Order Aggregation, Splitting, and Allocation

For transparency and fairness, OKX does not aggregate multiple clients’ orders nor split individual client orders across different venues without explicit consent. Each order is processed independently to ensure accountability and precise execution tracking.

This approach aligns with MiCAR’s emphasis on non-discriminatory treatment and protects against conflicts of interest.

Disclosure and Client Communication Procedures

Transparency is central to building trust. OKX maintains robust disclosure practices to keep clients informed about how their orders are executed.

5.1 Initial Disclosure

At onboarding, clients receive full details of:

This information is provided via the client portal and service agreement documentation.

5.2 Ongoing Access and Updates

The latest version of this policy is always available through:

Clients can access updates anytime in a clear, readable format.

5.3 Notification of Material Changes

Material changes — such as new execution venues, altered weighting of execution factors, or significant process updates — trigger proactive notifications via:

These communications clearly explain the change and its potential impact.

5.4 Regular Policy Review

OKX conducts a comprehensive review of this policy at least annually, or whenever a material change affects execution quality. Reviews consider:

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Safeguarding Client Order Information

Protecting sensitive trading data is a top priority. OKCoin Europe Ltd enforces stringent controls to prevent misuse or unauthorized access.

Confidentiality and Access Control

All employees are bound by:

Access to order information is restricted to authorized personnel only, using role-based permissions and encrypted systems.

Monitoring and Auditing

Automated monitoring tools and periodic audits ensure adherence to internal procedures and regulatory requirements. Any anomalies are investigated promptly, with corrective actions implemented as needed.

Ethical Standards

Employees must uphold high ethical standards in handling client data. This commitment is embedded in OKX’s corporate governance framework, reinforcing a culture of integrity and professionalism.

Continuous Monitoring and Policy Improvement

OKX actively monitors the effectiveness of its execution strategy through:

If deficiencies are identified — such as declining fill rates or rising costs — adjustments are made swiftly to restore optimal performance.

The company reaffirms its commitment to reviewing this policy at least once per year or whenever market or regulatory shifts demand it.

Frequently Asked Questions (FAQ)

Q: What does “best execution” mean in crypto trading?
A: Best execution means taking all reasonable steps to achieve the most favorable outcome for a client when executing trades, considering price, speed, costs, and likelihood of settlement.

Q: Does OKX ever execute against its own book?
A: Yes. When appropriate and aligned with best execution principles, OKX may route orders to its own central limit order book as an Execution Venue.

Q: Can I give specific trading instructions that override this policy?
A: Yes. Clients may provide binding instructions (e.g., market orders), but doing so may prevent OKX from applying its full best execution process.

Q: How often is this policy updated?
A: The policy is reviewed at least annually and updated whenever there’s a material change affecting execution quality or compliance.

Q: Are third-party exchanges used for order routing?
A: Yes. OKX may use external execution venues that meet strict criteria for liquidity, security, and regulatory compliance.

Q: Is my order data ever shared externally?
A: No. Client order information is kept strictly confidential and is never disclosed to third parties unless required by law.

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