Best Execution Policy - EEA
Updated: 21 March 2025
1. PURPOSE AND SCOPE
OKCOIN EUROPE LTD is a private limited liability company incorporated and registered in Malta under company registration number C88193, with its registered office at 66A, The Strand, Sliema SLM 1022 (the “Company”). The Company operates under the brand “OKX” and is part of the OKX group of centralised crypto exchanges.
As of 27 January 2025, the Company has been authorised as a Crypto-Asset Service Provider (“CASP”) under the Markets in Crypto Assets Act (Chapter 647 of the Laws of Malta), and as of 14 February 2025, the Company has been authorised to operate in the below 27 EU countries (“Permitted Countries”) as a CASP to provide the below listed services (“Permitted Services”) under article 63 of the Markets in Crypto Assets Regulation (EU) 2023/1114 of 31 May 2023 (MICAR). The Company is regulated and supervised by the Malta Financial Services Authority (the “MFSA”).
Permitted Countries:
Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden.
Permitted Services:
Exchange of crypto-assets for funds
Exchange of crypto-assets for other crypto-assets
Execution of orders for crypto-assets on behalf of clients
Operation of a trading platform for crypto-assets
Placing of crypto-assets
Providing custody and administration of crypto-assets on behalf of clients
Providing portfolio management on crypto-assets
Providing transfer services for crypto-assets on behalf of clients
Reception and transmission of orders for crypto-assets on behalf of clients.
This Best Execution Policy (this “Policy”) applies to all Clients to whom the Company provides the following services: (a) execution of orders, (b) reception and transmission of orders, (c) portfolio management services, and (d) dealing on own account when executing clients orders; in relation to crypto-assets.
2. EXECUTION VENUES
In light of the fact that the Company also operates a crypto currency exchange, the Company may transmit orders (generally arising from the provision of portfolio management services) to its own central limit order book and act as an Execution Venue. The Company may use other entities as Execution Venues. The Execution Venues selected by the Company shall have execution arrangements that enable the Company to comply with its obligations under the Rules when it transmits orders to those Execution Venues for execution.
3.EXECUTION FACTORS
The Company shall, as set out in this Policy, take all sufficient steps to obtain the best possible result for the Client by taking into account price, costs, speed, likelihood of execution and settlement, size, nature of the order or any other consideration relevant to the execution of the order (the “Execution Factors”). The relative importance of these factors are likely to vary on a case by case basis and one or more may be applicable. Nevertheless, where there is a specific instruction from the Client, the Company shall follow that specific instruction and, by doing so, the Company will satisfy its obligation to provide best execution in relation to that aspect of the order.
(Warning: Any specific instructions from a Client may prevent the Company from taking the steps that it has designed and implemented in this Policy to obtain the best possible results)
The Company will use its commercial judgement and experience in the light of available market information and market conditions at the relevant time in order to achieve the best balance across the following Execution Factors:
i. Total Consideration [Price and Cost] – This refers to the total consideration or net cost of the transaction to the Client. When transmitting a transaction in respect of a Client, the Company shall take into account, where relevant, the fees and commissions charged by the Company to the Client.
ii. Speed – The Company shall consider: (i) the significance of completing the transaction quickly; and (ii) whether speed is of equivalent importance to, or more important than, achieving the best possible price.
iii. Likelihood of Execution and Settlement – The Company will consider whether the use of a particular Execution Venue involves a risk(s) that the transaction will not be completed due to lack of liquidity or other factors that may affect the settlement of the transaction.
iv. Size – The Company shall consider the size of the transaction. Large orders may have to be dealt with differently to smaller orders, particularly when large orders could have a potential impact on the market and market price for the crypto-asset concerned.
v. Any other consideration relevant to Transmission of Orders, which may include but are not limited to low liquidity and/or high volatility.
The Company shall, in order to achieve operational efficiency and subject to the Execution Factors outlined above being satisfied, transmit its clients’ orders to its own central limit order book and act as an Execution Venue.
The relative importance of the Execution Factors will vary on a case by case basis and may be determined by reference to:
i. the characteristics of the Client;
ii. the characteristics of the Client order;
iii. the characteristics of the crypto-assets that are the subject of that order.
Given the nature of the market for crypto assets, the Company considers “Speed” and the “Total Consideration” as the main Execution Factors that it should fulfil in order to ensure best execution.
The Company will achieve the best available terms for a client when it optimises “Speed” and the “Total Consideration” paid or received by a Client. Where the Company transmits an order on behalf of a Client, the Total Consideration is the (a) price of the crypto-asset and (b) the costs related to the completion of the transaction, including all expenses incurred by the Client which are directly related to the transmission of the order.
Other Execution Factors may also be considered, and given precedence over “Speed” and the “Total Consideration” only insofar as they are instrumental in delivering the best available terms for the Client.
4. AGGREGATION, SPLIT AND ALLOCATION OF ORDERS
The Company shall not carry out a Client’s order in aggregation with another Client’s order or split Client orders.
5.DISCLOSURE AND NOTIFICATION PROCEDURE
5.1. Initial Disclosure
The Company provides clients with comprehensive information regarding its order execution policy upon the commencement of the client relationship. This information includes details about the factors considered in achieving best execution, the relative importance of these factors, and the execution venues used.
5.2. Regular Updates and Availability
The execution policy is made available to clients through various channels, ensuring they have access to the most up-to-date information. The Company commits to maintaining transparency by providing this policy in a readily accessible format, potentially including digital formats such as a website or client portal.
5.3. Notification of Material Changes
The Company has established a process for notifying clients of any material changes to the order execution policy. Material changes are defined as significant alterations that may impact the execution of client orders or the client's understanding of how their orders are handled. These changes could include modifications to the execution factors, the addition or removal of execution venues, or changes in the Company’s internal processes.
5.4. Client Communication
When a material change occurs, the Company promptly informs clients using appropriate communication channels. This communication is designed to be clear and informative, ensuring clients understand the nature of the changes and their potential impact. The methods of communication may include email notifications, updates on the Company’s website, or direct messages through the client’s preferred contact method.
5.5. Regular Review and Compliance
The Company undertakes regular reviews of its order execution policy, at least annually, to ensure ongoing compliance and effectiveness. During these reviews, the Company assesses whether any updates are necessary to reflect changes in the market environment, regulatory requirements, or the Company’s own operational capabilities.
6.CLIENT ORDERS INFORMATION HANDLING : ARRANGEMENT AND PROCEDURES
6.1. Confidentiality Obligations
Employees of OKCoin Europe Limited are bound by strict confidentiality obligations. These obligations are part of their employment contracts and are reinforced by the Company’s internal policies. The confidentiality requirements mandate that employees must not disclose or misuse any information relating to client orders, ensuring that such information is handled securely and only accessed by authorised personnel.
6.2. Access Control and Security Measures
The Company implements robust access control measures to restrict access to sensitive information. This includes the use of secure systems and databases where client order information is stored. Only employees who have a legitimate need to access this information for their role are granted access. These access controls are regularly reviewed and updated to prevent unauthorised access.
6.3. Internal Policies and Procedures
OKCoin Europe Limited has established detailed internal policies and procedures that guide the handling of client information. These policies include clear guidelines on the use and protection of client data, as well as the consequences of non-compliance. Employees are trained on these policies as part of their onboarding and through ongoing compliance training programs.
6.4. Monitoring and Auditing
The Company employs monitoring and auditing mechanisms to oversee the handling of client information. Regular audits are conducted to ensure compliance with internal policies and regulatory requirements. These audits help in identifying any potential lapses in data security and in taking corrective actions promptly.
6.5. Ethical Standards and Conduct
Employees are required to adhere to high ethical standards and conduct themselves in a manner that upholds the integrity of the Company and its commitment to client confidentiality. This ethical framework is part of the Company’s broader corporate governance and compliance culture, which emphasises the importance of trust and professionalism in all client interactions.
7.OTHER MATTERS
The Company will monitor the effectiveness of this Policy to identify and, where appropriate, correct any deficiencies. In particular, the Company shall assess, on a regular basis, whether the Execution Venues provide for the best possible result for the Client or changes are needed in relation to the arrangements. The Company undertakes a review of its arrangements and this Policy at least annually, or whenever a material change occurs that affects its ability to continue to obtain the best possible result for the Client on a consistent basis.