Risk Disclosure Statement - OKX Middle East Fintech FZE

Published on 17 Sept 2024

Capitalised terms used in this Risk Disclosure Statement shall have the same meaning as in the Terms of Service which is available on https://www.okx.com/help/okx-middle-east-terms-of-service.

Nature of Virtual Assets

Virtual Assets are not legal tender and are not backed by any government.

There is no assurance that a Person who accepts Virtual Assets as a form of payment or a store of value will continue to do so in the future.

Value of Virtual Assets and the risk of loss

Investing in Virtual Assets carries a high level of risk and, as such, may not be suitable for all investors. A User should not transact in Virtual Assets if they are seeking a regular or low risk return on their invested capital. Unlike traditional investment products, Virtual Assets do not generally have any underlying or intrinsic asset value or any assets supporting their price.

Trading in Virtual Assets is highly speculative and involves significant risk. There is limited or no fundamental reasoning behind the pricing of Virtual Assets which may be subject to irrational and uncontrollable market forces. Whether the future price for a Virtual Asset will increase or decrease is unpredictable and purely speculative. Likewise, there is a risk that a Virtual Asset may not have any value whatsoever.  Virtual Assets are therefore traded at the User's own risk. 

Virtual Asset values are highly volatile and can fluctuate substantially in comparison to Fiat Currencies or traditional investment products. As a result, market conditions can change significantly in a very short period of time. Furthermore, the value of a Virtual Asset may never recover if there is no interest or development in the Virtual Asset. A User is therefore at risk of losing all or a substantial portion of the value of its Virtual Assets. Such losses can occur in a very short period of time.

The use of instructions in relation to Orders may not necessarily limit losses to the expressed amount and market conditions may make it impossible to Fill an Order or to obtain the limit price.

A User understands that it should be able to bear the risk of potential losses up to the full amount of their invested capital and Users who are Natural Persons should only invest capital that they can afford to lose without impacting their standard of living and proportionate to his or her income. A User should cease trading in Virtual Assets if his or her personal situation no longer permits it. 

Trading in Virtual Assets is not appropriate for Persons with:

(a) limited resources;

(b) limited investment experience; and/or

(c) a low risk appetite to investment or trading losses. 

A User should ensure that it has an understanding of the economic and other types of risks involved in trading Virtual Assets. A User should seek professional advice where appropriate. 

Before opening an Account, a User is deemed to have evaluated and confirmed that they understand the risks involved.

Past performance

The value of any Virtual Asset may decrease as well as increase. Trading in Virtual Assets may be susceptible to irrational market forces.  Any data on the past performance of a Virtual Asset does not guarantee, and may not be a reliable indicator of, future performance.

Suitability

OKX provides an execution-only service and does not advise on the merits of any particular Trade, trading risk or associated tax consequences, and OKX does not provide any other financial, investment or legal advice in connection with the Services. 

OKX acts as a platform for the trade execution of Orders and the custody of Virtual Assets and Fiat Currencies. 

OKX is therefore not responsible for assessing whether: 

(a) the Services are suitable for a User; or

(b) any Trade is suitable for a User's needs. 

Any information provided on the Website is for information purposes only and is not, nor intended to be, financial advice, investment advice, a trading recommendation or any other advice. OKX does not warrant the accuracy, completeness or usefulness of such information and such information should not be considered as an offer to buy or sell a Virtual Asset. A User is solely responsible for determining whether any Trade is appropriate.

By opening an Account, a User accepts the risk of trading in Virtual Assets. In entering into any Trade, a User represents that it has been, is, and will be solely responsible for making its own independent appraisal and investigation into the risks of each Trade and the underlying Virtual Assets. 

By utilising OKX’s services, each User represents that they have sufficient knowledge, market sophistication, professional advice and experience to make their own evaluation of the merits and risks of any Trade or any underlying Virtual Asset prior to opening an Account. 

Each User must ensure that it seeks professional advice, if necessary, taking into account its investment objectives, level of experience and risk appetite. 

Each User should be fully aware of the specific characteristics and risks relating to the particular Virtual Asset that the User is planning to trade. 

Availability of Virtual Assets

The ability for a User to purchase Virtual Assets using the OKX Platform is dependent on the existence of a counterparty willing to sell the same Virtual Asset (and vice versa).  This is outside of OKX’s control. OKX makes no guarantee as to the timing or availability of the ability to purchase or sell Virtual Assets via the OKX Platform.

The value of Virtual Assets may be derived from the continued willingness of Users to trade Virtual Assets for Virtual Assets, which may result in the potential for permanent and total loss of value of a particular Virtual Asset should the market for it disappear. Thinly traded or illiquid markets have an increased potential risk of loss as a result of the enhanced volatility and a User may not be able to establish or liquidate positions in a Virtual Asset when desired, at favourable prices or at all. 

A Virtual Asset may change or otherwise cease to operate as expected due to changes made to or using its underlying technology, including by way of cyber-attack. Such changes may dilute the value of a User's Virtual Asset position and/or distribute the value of a User's Virtual Asset position to another Virtual Asset.

A "fork" refers to an upgrade in the code of a blockchain network, which may, for example, occur as a result of disagreements between stakeholders as to an update to a Virtual Asset's protocol or from a deliberate effort to revert the blockchain history to a point prior to a cyber-attack. In case of a fork, Users are entitled to the Virtual Assets arising from the fork to the extent of the amount of the forked Virtual Assets held in the Users’ Account at the time of the fork’s occurrence, unless when certain conditions are met. In the event of a fork, OKX will assess the impact of such a change as soon as possible once it is made aware of the fork and will communicate with Users affected by the fork.

A Hard Fork may result in a permanent split from a previous version of the blockchain and will effectively create a new Virtual Asset. The occurrence of a fork is outside of OKX’s control.  The supply of Virtual Assets as a result of a fork or similar changes to a Virtual Asset's protocols and OKX’s ability to provide Services for the new Virtual Asset which arises as a result may depend on third party providers which are outside of OKX’s control. OKX does not own or control any of the protocols that are used in connection with Virtual Assets and their related networks. Accordingly, OKX is not liable in respect of such protocols or any change in the value of any Virtual Asset (whether as a result of a fork or any similar change to a Virtual Asset's Protocol or otherwise), and OKX makes no guarantees regarding the security, functionality, or availability of such protocols. In the event of a Hard Fork, OKX will assess the impact of such a change as soon as possible once it is made aware of the Hard Fork and will communicate with Users affected by the Hard Fork.

OKX may delist a Virtual Asset in accordance with its delisting guidelines. The delisting guidelines shall be set forth at https://www.okx.com/help-center/360011875732 and may be updated by OKX from time to time.

A User is deemed to accept all risks associated with the use of the Services, including, but not limited to, the failure of hardware, software, and internet connections.

Currency risk

Trades may be executed in a currency different to the currency that the User deposited in its Account. The User should be aware of the risk of currency fluctuation and any risks related to it. A movement in an exchange rate may have a positive or adverse effect on the gain or loss achieved from any Trade.

Custody risk

OKX may hold Fiat Currencies and Digital Assets with third parties. However, the Digital Assets OKX holds are not “deposits". Further, the Digital Assets that OKX holds are not intended to be held as any other non-Digital Asset / traditional financial regulated product or service under Applicable Laws and Regulations. Fiat currencies held by OKX in its client money account shall be subject to Applicable Laws and Regulations.

OKX will initiate moves of Fiat Currencies to a UAE bank account within 24 hours of receipt in accordance with Applicable Laws and Regulations. However, where OKX arranges for a User’s Fiat Currencies and/or Digital Assets to be held in a jurisdiction other than Dubai, there may be different settlement, legal and regulatory requirements and different practices for the separate identification of Fiat Currencies and/or Digital Assets than those in Dubai.  

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 the 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.

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 for instance in an omnibus account. 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 in respect of pooled assets will be allocated pro rata to each User whose assets are so pooled.

Fiat Currencies and/or Digital Assets may be held by a third party appointed in good faith by OKX, or by OKX’s nominees or sub-custodians. Such third parties are not under the control of OKX, and OKX accepts no liability for any default of any nature by such third parties and, in the event of any such default, a User may suffer total or partial loss in respect of the User’s Account. The extent to which a User may recover its Fiat Currencies and/or Digital Assets in jurisdictions other than Dubai may be governed by specific legislation or local rules.

Unless OKX appoints a custodian or sub-custodian to hold any Digital Asset on behalf of Users, your Digital Assets shall be held in a segregated omnibus wallet address(es) belonging to OKX and managed by OKBL Technology Company Limited and OKBL Pte Ltd, affiliates of OKX. Your Digital Assets held in a segregated omnibus wallet address will be pooled with Digital Assets belonging to other OKX Users. 

Risk of Financial Crime and cyber crime

The nature of Virtual Assets means that they may be exposed to an increased risk of Financial Crime or cyber-attack. The transfer of Virtual Assets into a digital wallet exposes the Virtual Asset to the risk of loss from, amongst other things, security breaches from cyber-attacks that hack and steal Virtual Assets. 

The nature of Virtual Assets also means that they may have increased exposure to frauds, scams, ponzi schemes and, or other targeted schemes.

There is limited, or in some cases no, mechanism for the recovery of lost or stolen Virtual Assets.

Technology risk

Understanding Virtual Assets requires advanced technical knowledge. Virtual Assets are often described in exceedingly technical language that requires a comprehensive understanding of applied cryptography and computer science in order to appreciate inherent risks. The listing of a Virtual Asset on the OKX Platform does not indicate approval or disapproval by OKX of the underlying technology regarding that Virtual Asset and should not be used as a substitute for each User's understanding of the risks associated to that Virtual Asset. 

The software protocols that underlie Virtual Assets are typically open source projects, which means that:

(a) the development and control of such Virtual Assets is outside of OKX’s control; and

(b) such software protocols are subject to sudden and dramatic changes that might have a significant impact on the availability, usability or value of a specific Virtual Asset.

The inherent complexity of Virtual Assets may result in technological challenges for OKX, which could potentially hinder a User's access to, or usage of, their Virtual Assets. OKX does not assure uninterrupted availability of the Website and/or Services at all times. Additionally, we might encounter advanced cyber-attacks, unexpected activity surges, or other operational or technical issues. These may disrupt the functionality of the Website and/or Services or might even lead to the loss or theft of Virtual Assets. Users must acknowledge that these operational difficulties might induce delays. By choosing to use the Website and/or Services, Users agree to accept any risks of transaction failure due to unforeseen or exacerbated technical difficulties, including those that might arise from sophisticated attacks. Consequently, users may not always be able to access the Website or Services, including activities like purchasing, selling, or transferring Virtual Assets when they intend to do so.

Virtual Assets are dependent upon new technologies, including distributed ledger technologies for the purposes of, amongst other things, anonymity, irreversibility of transactions, accidental transactions, transaction recording and settlement. 

Virtual Asset transactions cannot be reversed. Once a User sends a Virtual Asset to a wallet address, there is a risk that it may lose access to the Virtual Asset indefinitely. For example, an address may have been entered incorrectly and the true owner of the wallet address may never be discovered, or a wallet  address may belong to an entity that will not return the User's Virtual Assets or which will only do so following action on the part of the User, such as verification of their identity.

A User may lose its private key in certain circumstances, including but not limited to the following:

(a) if the private key has been backed up on paper and subsequently lost or stolen;  or

(b) if the private key has been hacked or stolen.

The person in possession of a private key will own the Virtual Assets.

A User is responsible for complying with the Applicable Laws and Regulations and is solely responsible for determining which laws may apply to its transactions, including any applicable tax laws. A User is solely responsible for reporting and paying any taxes arising from its use of the Services.

Due to the relatively recent development of Virtual Assets, banks and other Competent Authorities have different views as to the risks associated with funds generated from the buying and selling of Virtual Assets or may have a very low tolerance for risk. Accordingly, a User's bank may freeze its account or reject any incoming funds if the User’s bank concludes that such funds are the result of buying or selling Virtual Assets.

OKX may suspend a User's access to its Account. In such circumstances, the User will not be able to make deposits or withdrawals or trade. OKX may also suspend a User's ability to transact on the OKX Platform, in which case it will not be able to undertake the sale or purchase of a Virtual Asset but it will be permitted to make deposits or withdrawals from its Account.

Regulatory risk

Virtual Assets activities conducted outside of Dubai may be unregulated or subject to limited regulation. 

Any regulatory changes or actions by the Competent Authorities or any authorities that are not connected to OKX may adversely affect the use, transfer, exchange and value of a Virtual Asset.

The domestic government of a User may make it illegal for the User to trade Virtual Assets.

Stop Loss

A Stop Order is an offer to deal if our quote becomes less favourable to you. A Stop Order is generally placed to provide some risk protection, for example in the event of your Trade moving into loss, and can be used to either open or close a Trade. Each Stop Order has a specific stop level, set by you. Your Stop Order will be triggered if our bid price (in the case of an order to sell) or our offer price (in the case of an order to buy) moves against you to a point that is at or beyond the level specified by you. Notwithstanding the specific stop level set by you, we may be required by Applicable Laws and Regulations to close or part close a Trade prior to your Stop Order being triggered.

You agree and understand that Stop Orders will not necessarily limit your losses to the intended amounts, since market conditions may make it impossible to execute such Orders at a price close to your intended stop price or at all. In extremely volatile markets, the price of a Virtual Asset may fall rapidly through your Stop Order price and you may suffer losses well in excess of the amount realised had your Stop Order been executed at the Stop Order price. 

Margin, Gearing and Leverage

Before you are allowed to enter into a Contract with us, you will generally be required to deposit money with us – this is called the Margin requirement. This Margin requirement will usually be a proportion of the overall Contract value. This means that you will be using ‘leverage’ or ‘gearing’ and this can work for or against you. A small price movement in your favor can result in a high return on the margin requirement placed for the Contract, but a small movement against you may result in substantial losses. 

At all times that you have open positions, you must ensure that your account balance, taking account of running profits and losses, is equal to at least the total Margin requirement that we require you to have deposited with us. Therefore, if our price moves against you, you may need to provide us with significant additional funds immediately to meet your margin requirement and maintain your open positions. If you do not do this, we will be entitled, in our absolute discretion, to close one or more or all of your positions in any Virtual Asset you hold. You will be responsible for any losses incurred as a result.

The need to monitor your positions is of greater importance when you have entered into Contracts with us because of the effect of gearing. Gearing magnifies the rate at which profits or losses can be incurred and, as a result, it is important that you monitor your positions closely.

It is your responsibility to review your account balance and margin levels required. If you are at risk of being liquidated, we will inform you through the OKX mobile application, the OKX desktop website or email.

We will be entitled, at any time, and at short notice, to increase or decrease the Margin required from you on open Trades. You agree that, regardless of the normal way in which you and we communicate, we will be entitled to notify you of a change to Margin levels or the credit arrangements for your account by any of the following means: telephone, email, text message, via our OKX Platform or by posting notice of the change on our website. Any increase in Margin levels will be due and payable immediately on our demand. We will only increase Margin requirements or change the credit arrangements for your account where we, in our absolute discretion, reasonably consider it to be necessary, including but not limited to, in response to or in anticipation of:

(a) a change in the volatility and/or liquidity in the Virtual Asset market;

(b) economic news;

(c) a Virtual Asset is rumored to being suspended from trading on another Virtual Asset trading platform;

(d) you change your dealing pattern with us; or

(e) any change to the Applicable Laws and Regulations.

Subject to Applicable Laws and Regulations, for certain categories of clients we may not be able to accept the payment of margin to be made by credit card or by any other credit arrangement made with third parties.

Staking Disclaimer: 

The staking services offered by OKX Middle East Fintech FZE are subject to OKX Middle East Fintech FZE Staking Agreement and all terms and conditions thereof. OKX does not guarantee any return from staking and does not provide investment or asset recommendations. All displayed estimated return rates are not guaranteed and may change without notice. Past returns are not indicative of future returns. OKX is not associated with the staking protocols associated with the staking services, makes no warranties, representations or undertakings relating to the staking protocols' offerings, and is not responsible or liable for any direct or indirect loss or other damage arising from your use of the staking protocols. Please conduct your own due diligence before buying, selling or holding any virtual asset in relation to the staking services. You further understand and acknowledge that, by receiving the staking services, your assets may be subject to impermanent loss, which is a risk associated when the price of your deposited virtual assets changes from the time you deposited them. If slippage is greater than 10%, your orders may be cancelled and your assets will be returned to you. OKX is not responsible for any potential loss.

Smart Contract Risk

Staking Protocols rely entirely on so called ‘smart contracts’. These are contracts that operate on a blockchain network where the terms of the contract are carried out automatically using technology.

Smart contracts are new and untested technology. Any bug or coding error either within the smart contract or in the blockchain network underlying the smart contract may result in a loss of your Virtual Assets. We do not guarantee the return of Virtual Assets staked with a Staking Protocol.

Liquidity Risk

Whilst your Virtual Assets are locked into a Staking Protocol, you will not have access to them. You will not be able to transfer or sell them for as long as they are staked.

Subject to the relevant Staking Protocol, you may not be able to immediately withdraw or redeem your Virtual Assets. If the relevant Staking Protocol allows you to withdraw or redeem early, you may be subject to a penalty as determined by such Staking Protocol.

Slashing Risk

Certain Staking Protocols may impose a penalty if you breach the rules of the Staking Protocol or validate an invalid block on the underlying blockchain as a result of participating in the Staking Protocol. This penalty is commonly referred to as ‘slashing’.

In the event that you are subject to slashing, we will not replace your lost Virtual Assets and you will have lost your Virtual Assets.

No Guarantee of Staking Rewards

The payment of and amount of Staking Rewards is entirely dependent on the Staking Protocol. The staking Protocol may change its payment rules at any time without notice.

Past performance of a Staking Protocol is not in any way a guarantee or predictor of current or future Staking Rewards.

Counterparty Risk

Where OKX provides access to ‘third party’ Staking Protocols, OKX does not warrant or represent the safety or security of that Staking Protocol. OKX only carries out limited checks on the third-party Staking Protocols it offers.

By engaging with a third-party Staking Protocol, you may be subject to counterparty risk in relation to that Staking Protocol. It is your responsibility to carry out your own research to ensure that you are comfortable to stake your assets with a specific third-party Staking Protocol.

Risk Disclosures for Perpetual Futures (“Perps”) and Options Products

Perpetual Futures (“Perps”)

  1. High Leverage Risk: Perpetual futures often allow high leverage, which can amplify both gains and losses. Investors may lose more than their initial investment.

  2. Market Volatility: Perpetual futures markets can be highly volatile. Prices can move significantly in short periods, leading to rapid gains or losses.

  3. Liquidation Risk: Due to high leverage, positions may be liquidated automatically if the market moves against the investor. This can result in substantial losses.

  4. Funding Rates: Investors holding perpetual futures are subject to funding rates, which can fluctuate and add to the cost of holding a position.

  5. Counterparty Risk: Trading on certain platforms may expose investors to counterparty risk if the platform fails or is hacked.

Options Products

  1. Complexity: Options products can be complex and may not be suitable for all investors. Understanding the mechanics and risks of options trading is crucial.

  2. Time Decay: Options lose value over time, particularly as they approach expiration. This is known as time decay.

  3. Volatility Risk: The value of options is highly sensitive to changes in the volatility of the underlying asset.

  4. Loss of Premium: Buyers of options risk losing the entire premium paid if the option expires out of the money.

  5. Liquidity Risk: Certain options, particularly those that are out of the money or far from expiration, may have low liquidity, making it difficult to enter or exit positions.

Investors should carefully consider whether trading in these products is appropriate for them in light of their financial situation, investment experience and risk tolerance.

Lending and Borrowing Public Disclosures

The public disclosures set out below are provided in accordance with Rule I.B of the VARA Lending and Borrowing Rulebook.

Availability of Lending and Borrowing Products

All lending and borrowing products are only available to clients that have been classified as either Qualified or Institutional. If you have been classified as a Retail Client, you will not be offered any lending and borrowing products.

Denomination of Interest Payments

Borrowers: Interest will be payable in the denomination of the Virtual Asset borrowed. For instance, if BTC is borrowed, interest payments will be in BTC. There is no ability to change or amend the denomination of the Virtual Assets used for interest payments. Further details on interest, including its calculation and accrual is contained in the relevant agreement.

Lenders: OKX Dubai does not currently offer lending services. When OKX Dubai begins offering lending services, lenders will lock their Virtual Assets into the relevant lending protocol. When Virtual Assets are locked into the relevant lending protocol, lenders will receive interest in the denomination of the Virtual Assets locked into the lending protocol. For instance, if BTC is locked into the lending protocol, then any interest payments received will be in the form of BTC. There is no ability to change or amend the denomination of Virtual Assets used for interest payments received.

Ability to withdraw Virtual Assets

Borrowers: Borrowers are able to withdraw Virtual Assets from their accounts at all times including in times of extreme market volatility. However, in time of extreme market volatility, there may be a delay in processing withdrawal requests subject to network conditions. 

Lenders: OKX Dubai does not currently offer lending services. When OKX Dubai begins offering lending services, lenders will lock their Virtual Assets into the relevant lending protocol. Once locked, any withdrawal of virtual assets will be subject to the terms and conditions of that lending protocol. Lenders may therefore not have access to and the ability to withdraw their Virtual Assets in times of extreme market volatility.

Use of Virtual Assets by OKX

Borrowers: Any collateral provided by borrowers will be held by OKX Dubai in its omnibus accounts. OKX Dubai will not use the collateral to enable other products provided by OKX Dubai.

Lenders: OKX Dubai does not currently offer lending services. When OKX Dubai begins offering lending services, lenders will lock their Virtual Assets into the relevant lending protocol. When Virtual Assets are locked into the relevant lending protocol, they will be used in accordance with the terms and conditions of that lending protocol. Such uses may include providing Virtual Assets to users to trade on margin.

Counterparty Risk

Borrowers: Borrowers do not face any counterparty risk when borrow Virtual Assets.

Lenders: OKX Dubai does not currently offer lending services. When OKX Dubai begins offering lending services, lenders will lock their Virtual Assets into the relevant lending protocol. When Virtual Assets are locked into the relevant lending protocol, OKX Dubai will mitigate counterparty risk by ensuring that all loans are over-collateralised and that any shortfall in Virtual Assets is met by the insurance fund.

Liquidity Risk Management

Borrowers: Borrowers will not have access to the collateral for as long as the loan is outstanding. In accordance with the product terms and conditions, borrowers are responsible for managing their own liquidity risk by monitoring the adequacy levels of their collateral to ensure that they do not get liquidated.

 Lenders: OKX Dubai does not currently offer lending services. When OKX Dubai begins offering lending services, lenders will lock their Virtual Assets into the relevant lending protocol.

Flexible Loan Risk Disclosures

Liquidity Risk: Whilst your Virtual Assets are provided as Collateral, you shall not have access to them. You therefore cannot make use of these Virtual Assets for as long as they are used as Collateral.

Liquidation Risk: The underlying value of Virtual Assets is volatile and may change rapidly without any notice. As such, the value of the Virtual Assets that you borrow as well as your Collateral is at risk. In a volatile market, you risk liquidation with very little notice and therefore losing your Collateral. In addition, in a volatile market, you risk liquidation whilst you are in the process of topping up your Collateral.

Early Warning Risk: We are not under any obligation to keep you informed of your risk of immediate or pending liquidation in accordance with the Margin Call Ratio. However, if we do so, the notification may be made by email and phone notification or through the Platform.

Volatile Interest Rate: You understand and accept that Interest is determined by matching against the highest demanded amount of Interest by lenders on an hourly basis. As such, the Interest charged to you may be volatile, will fluctuate on an hourly basis and in some circumstances may be as high as 100% APR.

Linked Product Risk: Liquidity for the Products is provided by users making use of the OKX Simple Earn product and not by OKX Dubai.

Responsible Senior Management

At OKX, we prioritize transparency and accountability. Consistent with our commitment, we reveal information concerning any past legal judgments or criminal charges against our Senior Management or Board members.

Responsible Individuals:

1. Rifad Mahasneh - General Manager

2. Sankalp Kathuria - Compliance Officer and MLRO

Disclosure Statement:

As of July 17th, 2024, no member of our Senior Management or Board has faced convictions or prosecutions in the UAE courts or any other legal jurisdiction.

We hold ourselves to the highest ethical standards, and this dedication is reflected in the unblemished record of our leadership team. We recognize the significance of trust in financial services, and we are unwavering in our commitment to providing clients with a secure and dependable environment.

As of today, OKX Middle East Fintech FZE has not identified any actual or potential conflicts of interest arising out of the activities it carries out.