OKX

Phase A — Understand the business

Lens 1 · Company Overview

OKX (formerly OKEx, and before that spun out of OKCoin) is one of the world's two largest centralized cryptocurrency exchanges by trading volume, founded in 2013 in China by Mingxing "Star" Xu. The operating entity behind the global exchange is Aux Cayes FinTech Co. Ltd., a Seychelles-domiciled company (d/b/a "OKEx"/"OKX"), which since ~2017 has operated the platform. The group holding structure is OK Group, controlled by Star Xu.

What it actually is: a vertically-integrated crypto financial-services stack, not just a spot venue. Revenue engine = trading fees, and the mix is overwhelmingly derivatives, not spot:

• Derivatives (perpetual swaps, futures, options, margin) — ~88% of platform trading volume. This is the profit center: OKX is the clear #2 in crypto derivatives globally.
• Spot trading — the remainder; most active pair ETH/USDT.
• OKX Earn (savings, staking, DeFi, ETH staking), crypto loans, Jumpstart (launchpad), trading bots, block trading.
• Web3 Wallet + OKX DEX — self-custody multi-chain wallet and on-chain aggregator (the surface that was exploited to launder Bybit-hack proceeds — see Lens 10).
• X Layer — OKX's own Ethereum L2 (Polygon CDK-based), with OKB as the sole gas token.
• OKX Ventures (ex-Blockdream Ventures) — a crypto VC arm investing off the balance sheet.

Fee model: maker/taker starts at 0.10%, tiered down by 30-day volume or OKB holdings. Native token OKB functions as the fee-discount / ecosystem token (now also X Layer gas).

Customers: ~60M+ registered users cumulatively / 120M "accounts" claimed (post-ICE messaging) across 100–160+ countries — but only ~2.5M active users in 2024. ⚠️ Provenance conflict flagged: the user figures are internally inconsistent across sources (50M vs 60M vs 120M "accounts" vs 2.5M active vs a stray "20M registered" on CoinLaw). The 120M "accounts" number is the one OKX and ICE now cite as the JV's distribution reach — treat it as a marketing-grade account count, not active users. Real engaged base is likely single-digit millions active.

Key structural fact for everything downstream: OKX relaunched in the US in April 2025 — a centralized exchange + Web3 Wallet, HQ in San Jose, CA, with Roshan Robert as US CEO — two months after settling with the DOJ for $505M.

Lens 2 · Supply Chain (value chain — an exchange has a liquidity/rails chain, not a physical one)

An exchange's "supply chain" is its liquidity, custody, and settlement stack. Named stakeholders end-to-end:

• Upstream liquidity (the raw input = order flow + market-making):
• Market makers / prop firms — Wintermute, Jump, GSR, DWF Labs and similar are the liquidity providers whose two-sided quotes make OKX's books deep. (No disclosed Wintermute equity stake in OKX was found — that query returned nothing; flag as unconfirmed.)
• Retail + institutional traders — the fee-paying flow itself.
• The venue (OKX): matching engine, risk/liquidation engine, custody (95%+ cold storage, multi-sig), the OKB token economy, X Layer L2, OKX DEX aggregator.
• Custody & settlement rails:
• Stablecoin issuers as the cash leg — Tether (USDT) and Circle (USDC) are the dominant settlement assets on the books (USDT is the deepest pair). This is a single-point dependency on Tether in particular — a USDT de-peg or freeze is a direct chokepoint.
• Banking / fiat on-ramps — the historically fragile link for any offshore exchange; the US relaunch is partly about owning compliant fiat rails (EMI license in the EU — Lens 10).
• Blockchains — Bitcoin, Ethereum, Solana, Tron (USDT rail), plus OKX's own X Layer.
• NEW downstream rail (2026): ICE / NYSE. Via the OKXICE 50/50 JV, ICE becomes both a product supplier (licenses OKX spot prices to launch US-regulated crypto futures; supplies NYSE tokenized equities + ICE futures for OKX to distribute) and a clearing/risk-infrastructure partner. This is the single most important change to OKX's value chain in its history: it plugs a Seychelles-born crypto exchange directly into the plumbing of the New York Stock Exchange.

Chokepoints: (1) Tether concentration on the settlement leg; (2) banking/fiat access in each jurisdiction (the thing the DOJ case was fundamentally about); (3) regulatory license as a gating input — post-MiCA (1 July 2026) an EU license is now a hard prerequisite to serve EEA flow at all.

Lens 3 · Competitive Advantages (moats)

The honest read: OKX's moat is real but narrower than Binance's and different from Coinbase's.

• Liquidity / network effects (the core CEX moat): OKX is the clear #2 in derivatives — ~12.5% of 2025 derivatives volume vs Binance ~29.3%; it overtook Binance in monthly derivatives volume in Sept 2025 ($1.3T) at one point and runs ~$33–42B average daily derivatives volume. Deep books beget deeper books — traders go where the liquidation risk is lowest. This is a genuine, self-reinforcing moat, but it is a duopoly-with-a-long-tail (Bybit, Bitget, Gate are credible #3–5), not a monopoly.
• Product velocity / crypto-native edge: OKX ships aggressively — X Layer, the OKB fixed-supply relaunch, and pre-IPO perpetual futures on OpenAI / SpaceX (May 2026). That product cadence is a moat vs slow TradFi entrants and even vs Coinbase.
• The new, potentially decisive moat — the ICE relationship: a board-level, 50/50 JV with the owner of the NYSE is something no other crypto exchange has. If OKXICE delivers regulated US crypto futures + tokenized NYSE equities distribution, OKX gets a regulatory-blessed TradFi bridge that Binance (still a US pariah) structurally cannot replicate and Coinbase would have to build. This is the asymmetric bull.
• Bargaining power: OKX has power over listings (projects pay/beg for Jumpstart slots) and moderate power over market makers (they need the venue's flow). It has weak power over regulators (the $505M plea is the proof) and weak power over stablecoin issuers (Tether dictates terms).

Moat verdict: durable #2 liquidity + a genuinely unique TradFi partnership, offset by a commoditizing CEX core (fees compress, competitors clone) and a founder-control / regulatory-history overhang that caps the multiple.

Lens 4 · Segments

No audited segment disclosure exists (private; segments.csv is header-only). Best public reconstruction, all /, unaudited:

Geography: headquartered operationally across Seychelles (legal entity), Malta (EU/MiCA hub), Dubai (MENA HQ, VARA), Singapore (MAS MPI), San Jose (US). Historically China-origin, now explicitly de-risking toward regulated Western + Gulf jurisdictions. No revenue-by-geography is disclosed — n/a — private, not disclosed.

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Phase B — Measure performance

Lens 5 · Funding & Valuation Trajectory (+private swap for "Earnings Result")

The headline: OKX was effectively bootstrapped for ~13 years, then took its first outside institutional capital in 2026 from the NYSE's parent.

Reconstructed operating scale (unaudited):

• Trading volume: ~$33–42B/day derivatives + ~$5–6B/day spot.
• On-exchange / reserve assets: ~$27–34B ("primary assets" $33.7B in the 34th PoR report; ~$20B+ mid-2025).
• Revenue / profit: n/a — not disclosed. No credible audited figure exists. : at ~$40B/day derivatives × ~365 days × a blended effective take-rate of ~0.02–0.03% (derivatives fees are thin) → order-of-magnitude ~$3–4B annual trading revenue — this is a rough back-of-envelope, not sourced, and could be off by 2× either way. Star Xu's net worth is pegged at ~$1.4B (2025) — notably low for a majority owner of a $25B-valued exchange, which suggests either conservative estimation or that the $25B mark is aspirational/strategic.

Valuation sanity check: $25B on ~$27–34B of custodied (not owned) assets, against Coinbase's public $39.55B market cap on $6.56B TTM revenue (~6× sales). If OKX genuinely earns ~$3–4B, $25B is ~6–8× sales — in line with Coinbase, and ICE's team explicitly called the mark "intentionally conservative to support future returns". That framing is a tell that the true internal number is higher.

Lens 6 · Founder / Leadership Voice (sentiment trend) (+private swap for "Earnings Calls")

No earnings calls (private). Signal comes from founder/exec public statements — and the tone shift over 2025→2026 is stark: from "offshore, move-fast" to "20–30-year durable, regulated institution."

• Haider Rafique (Global Managing Partner & CMO): "We will go public when we have confidence that we can give back shareholder value… We're going to build this company over 20, 30 years". Explicitly cites Coinbase's volatile post-IPO performance as the reason not to rush. Called the ICE $25B mark deliberately conservative.
• Roshan Robert (US CEO): ex-Barclays, ex-Hidden Road (crypto prime broker acquired by Ripple for $1.25B) — an institutional-markets pedigree, not a crypto-degen. Emphasizes crypto's "transparent integration into regulated markets" — hints at eventual listing.
• Star Xu: publicly celebratory on the US relaunch ("OKX Wallet and Exchange are now live in America"), but has stepped back from the front-of-house compliance narrative — the US face is deliberately Robert (Western institutional), not Xu (China-origin founder with a detention history).

Trend read: management is running a deliberate credibility-laundering / institutionalization playbook — new Western CEO, TradFi partner on the board, "we'll IPO on our terms" patience, MiCA maximalism. The recurring phrase is "regulated"; the phrase they've stopped saying is anything that sounds like the old offshore-growth-at-all-costs OKEx.

Lens 7 · Comps — Cap Table & Strategic Marks (+private swap)

Cap table quality (the IPO-proximity tell):

• Syndicate: historically none (bootstrapped, founder/OK Group controlled). The entire institutional cap table is essentially one name: Intercontinental Exchange (NYSE: ICE) — a strategic, not a crossover fund, but arguably a stronger signal than a Tiger/Coatue markup because ICE is a board-level operating partner building a JV, not a passive late-stage tourist.
• No disclosed crossover (Fidelity/T. Rowe/BlackRock) marks — because there was no prior round to mark. This is unusual: OKX skips the entire VC ladder and goes straight from bootstrap → strategic TradFi anchor.

Public/private comparables (multiples are `` or n/a):

Read: the only clean, tradeable comp is Coinbase at ~6× sales. OKX's $25B mark implies a broadly Coinbase-like multiple on estimated revenue — which is either fair (if the ~$3–4B estimate holds) or cheap (if ICE's "conservative" framing is honest and true revenue is higher). Circle is an adjacency (stablecoin rails), not a like-for-like exchange.

Lens 8 · Valuation/Product Catalysts (+private swap for "Stock-Price Catalysts")

No public equity, so the "catalysts that move the mark" are funding/product/regulatory events (and, as a live proxy, moves in OKB):

Pattern: the mark now reacts to regulatory milestones and TradFi integration, not crypto price. The single most catalytic forward event is the MiCA 1-July-2026 cull (OKX's Europe chief claims "80% of crypto exchanges won't survive MiCA") — a licensed-incumbent land-grab.

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Phase C — Judge people & books

Lens 9 · Management

• Star Xu (Founder, controlling owner, OK Group CEO): built OKCoin (2013) → OKEx → OKX into a global top-2 exchange essentially without outside capital — a genuine, rare operating achievement. Skin in the game: total (majority owner). Red flags: material. Xu was questioned/detained by Chinese police in Sept 2018 (a bitcoin-futures liquidation dispute) and again in Oct 2020 (reportedly re-a 2019 Hong Kong backdoor-listing of OK Group), during which OKEx suspended withdrawals for ~5 weeks — a serious custody-trust event. Archetype: founder-operator, China-origin, high-risk-tolerance — which is exactly the profile the US relaunch is engineered to de-emphasize.
• Roshan Robert (US CEO): ex-Barclays, ex-Hidden Road (acquired by Ripple, $1.25B). Institutional-markets credibility — the deliberate Western counterweight to Xu. Track record is in prime brokerage/regulated markets, not consumer crypto. Good hire for the credibility-laundering strategy.
• Haider Rafique (Global Managing Partner & CMO): the public strategy voice; frames the 20–30-year, IPO-on-our-terms patience. Marketing/strategy, not finance.
• Capital allocation: the two defining moves — (1) the OKB supply lock (returned value to token holders by making OKB permanently scarce, ending the buyback-and-burn in favor of a fixed 21M cap) and (2) selling <1% to ICE for a board seat + JV rather than raising a growth round. Both are shrewd, shareholder-friendly signals. OKX Ventures deploys off-balance-sheet into the ecosystem (portfolio undisclosed).
• ROE/ROIC: n/a — private, not disclosed.

Verdict: a founder with a real build but a detention/withdrawal-freeze history and Chinese-origin regulatory baggage, now wrapped in an institutional management veneer (Robert) and a TradFi board member (ICE). The governance question — how much does one man control, and what's the succession/oversight? — is the central management risk (Lens 14).

Lens 10 · Forensic Red Flags & Regulatory

Acting as forensic analyst — but with a hard limitation: there are no audited financials to forensically examine. The "red flags" here are therefore conduct/compliance/custody, not accounting-line manipulation.

Regulatory findings (from regulatory/regulatory-findings.md — 0 SEC EDGAR findings because OKX has no CIK and is not an SEC registrant):

• DOJ / SDNY (the big one) — Feb 2025: Aux Cayes FinTech Co. Ltd. pleaded guilty to operating an unlicensed money-transmitting business. Facts: from ~2018 through early 2024, OKX served US retail + institutional customers (violating its own stated US-exclusion policy) who transacted >$1 trillion; the affiliate facilitated >$5B in suspicious transactions / criminal proceeds; an OKX employee told a prospective US customer in April 2023 to "just put a random country" to bypass KYC. Penalty: $505M total — $420.3M criminal forfeiture (disgorging US-customer fees) + $84.4M fine. A compliance monitor was installed through 2027. This is a criminal admission of systemic AML/KYC failure, not a settled civil charge — the single most important negative fact in this dossier.
• Non-SEC / other agencies (web search per regulatory-findings.md guidance): no additional material US enforcement (FTC/CFTC/CFPB) surfaced beyond the DOJ matter. Historically OKX has faced various national market exits/warnings (as most global exchanges have) but no second headline action of the DOJ's magnitude was found.
• EU / MiCA: positive — full MiCA license via Malta MFSA (27 Jan 2025), plus MiFID II (derivatives, via a March 2025 acquisition) and an EMI license (Feb 2026) for stablecoin/fiat — passported across 30 EEA states. ~600 legal & compliance staff as of mid-2025.
• Other jurisdictions: Dubai VARA full VASP license; Singapore MAS Major Payment Institution license.

Custody / security incidents (the exchange-specific "balance-sheet risk"):

• Dec 2023: OKX DEX contract maliciously updated → ~$2.7M stolen; users fully compensated.
• Jun 2024: SIM-swap attack on 2FA → two users' funds stolen; fully compensated.
• Mar 2025: Lazarus Group used OKX's DEX to launder ~$100M of the $1.5B Bybit hack; OKX suspended the DEX aggregator and added controls. This is reputationally serious — OKX's own on-chain surface was a laundering conduit the same month it was rebuilding US trust.
• Proof of Reserves: monthly, >100% ratios (Feb 2026: BTC 106%, ETH 103%, USDT 109%, USDC 101%); 95%+ cold storage, CertiK "AA". The 2020 5-week withdrawal freeze (Lens 9) is the historical counterexample to the "your funds are always available" claim.

Forensic bottom line: the accounting is unauditable (private), so the diligence weight shifts entirely to conduct — and the conduct record is a criminal AML plea + a DEX-as-laundering-conduit episode + a historical withdrawal freeze, only partly offset by best-in-class PoR and a heavy new compliance buildout. Label: structurally compliance-scarred, actively remediating under a monitor.

(Phase C add — Governance & succession, per general +private diligence)

Founder-controlled, no public board oversight until ICE's single seat (Mar 2026). Concentration of control in Star Xu is the governance red flag; ICE's board seat is the first external check. Succession plan: undisclosed.

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Phase D — Project & stress-test

Lens 11 · IPO-Readiness & Path-to-Tradeable (+private swap for "Forward Projection")

This is the be-early payoff lens. OKX is a high-quality, mid-stage private on the crypto frontier — but management has explicitly deferred the IPO.

Stage: post-institutional-anchor (ICE on the cap table + board), pre-S-1. Not imminent.

IPO-readiness assessment:

• Blockers to an S-1:

1. The DOJ compliance monitorship runs through 2027 — it is very hard to price an IPO with an active criminal-plea monitor in place. This is the binding constraint; a US listing before ~2027–2028 is unlikely.
2. No audited financials disclosed — a US IPO requires PCAOB-audited statements; OKX has never published revenue/profit. The audit-readiness gap is large.
3. Founder control / governance — dual-class or founder-supermajority structures are common but invite scrutiny given Xu's history.

• Accelerants:

1. ICE relationship — a NYSE-parent board member and JV is the single strongest IPO-readiness signal on the private frontier; it also gives a natural listing venue and underwriting-adjacent relationship.
2. MiCA + US + Gulf license stack — regulatory legitimacy is being manufactured deliberately.
3. OKXICE tokenized-equity JV could itself become the listing vehicle/narrative ("the exchange that put NYSE on-chain").

• Management's own stated stance: "We will go public when we have confidence we can give back shareholder value… build this company over 20, 30 years" — i.e. no near-term IPO by design.

Estimated window: 2027–2029 — gated on (a) monitorship expiry (2027), (b) an audit/financial-reporting buildout, (c) a constructive crypto-IPO tape (they're explicitly waiting for Coinbase-style volatility to settle). Path-to-tradeable interim: OKB is the only liquid, tradeable proxy today (see below).

No EPS forecast (no earnings, private — and per skill rules, no forecast.ts create in unattended/watchlist mode). The scoreable binary instead would be: "OKX files an S-1 / confidentially registers a US IPO before 2028-12-31" — ** p ≈ 0.30** (monitor + management patience make a pre-2028 filing a minority outcome). Logged here as a note only; not written to the forecast tracker.

Write-back: this dossier should seed a research/private-watch.json entry for OKX — stage: institutional-anchor / pre-S-1, ipo_readiness: medium (blocked by DOJ monitor through 2027), catalyst: OKXICE JV traction + monitorship expiry, dossier: companies/okx/deep-dive-2026-07-01.md. (Per wave boundaries this run does not edit that file; flagged for Connor/next pass.)

Lens 12 · Bull vs Bear

Bull case. OKX is the #2 crypto exchange globally with a genuinely unique asset no competitor has: a board-level, 50/50 JV with the parent of the New York Stock Exchange. The thesis is that crypto and TradFi converge, and OKX just bought the pole position — regulated US crypto futures (via ICE's clearing), tokenized NYSE equities distributed to 120M accounts, and a MiCA/MiFID/EMI/VARA/MAS license stack that lets it bank the flow the 80% of unlicensed exchanges will lose after 1 July 2026. Layer on the OKB supply lock (Bitcoin-style 21M scarce token, sole X Layer gas) as a clean equity-like proxy, a bootstrapped, founder-aligned economic base (no VC overhang, no down-round risk), and ICE explicitly calling the $25B mark "conservative." If OKXICE ships, this is a >$50B on-chain-markets franchise within 3 years, and the eventual IPO is a Coinbase-plus (derivatives-heavy, globally licensed, TradFi-partnered).

Bear case. Three things can permanently impair it: (1) The regulatory tail. A firm that criminally pled to systemic AML failure — and whose own DEX laundered Bybit-hack proceeds a month into its US rebuild — is one enforcement surprise away from losing a license that is now existential (post-MiCA, no license = no EU market). The monitor runs to 2027; a second action resets the clock. (2) Founder-key-man / governance. One China-origin founder with a detention history and a past 5-week withdrawal freeze controls the company; a single Xu event (health, legal, geopolitical China exposure) is a catastrophic single point of failure with almost no external board check (ICE holds one seat). (3) The core is commoditizing. Derivatives fees are thin and Bybit/Bitget/Hyperliquid (on-chain perps) are eroding the #2 moat from below; if the ICE JV doesn't convert into real regulated volume, OKX is just a slightly-smaller Binance with worse China optics.

Pre-mortem (18 months out, thesis broke): OKXICE stalled in US regulatory approval (tokenized NYSE equities need SEC blessing that didn't come); a fresh AML/sanctions enforcement action (or a Xu-related China headline) triggered a license review in the EU; OKB round-tripped its 2025 pump; and the "$25B conservative mark" turned out to be a strategic-partner courtesy, not a market-clearing price — a later secondary printed lower.

Contrarian view (what the market refuses to see): the consensus treats OKX as "the tainted #2 that got lucky with an ICE bailout-by-association." The contrarian read is the opposite — ICE didn't rescue OKX, ICE needs OKX: the NYSE's parent could not build crypto-native distribution to 120M accounts organically, so it paid a $25B-valuation entry to rent OKX's rail. In that frame OKX is not a compliance cripple but the single most strategically-positioned bridge between TradFi and crypto — and the DOJ plea, by forcing the compliance buildout, is what made it acceptable for ICE to sit on the board at all. The scar is the moat.

Lens 13 · Devil's Advocate (short-seller)

Dismantling the bull:

• Revenue concentration: ~88% of volume is derivatives — the most regulation-sensitive, most-easily-offshored, thinnest-margin product. A US/EU crackdown on retail crypto perps (a live regulatory theme) hits OKX's profit center squarely. And derivatives volume is mercenary — it chases the deepest book / lowest fees and has near-zero switching cost. Hyperliquid and on-chain perp DEXs are structurally undercutting the CEX perp model.
• The moat is weaker than bulls think: OKX is #2 in a race where #1 (Binance) is ~2.3× larger and #3–5 (Bybit, Bitget, Gate) are one product-cycle behind. There is no durable pricing power — the 2025 "overtook Binance for one month" stat is exactly the kind of transient headline that masks a commoditized core.
• Most dangerous competitor bulls underestimate: not Binance — Coinbase. Coinbase is already public, already US-regulated, already building its own tokenized-equity and derivatives stack, and doesn't carry a criminal AML plea or China-founder optics. If tokenized US equities are the prize, Coinbase (or a Robinhood/Kraken) is better-positioned in the US than a Seychelles-born exchange still under a DOJ monitor.
• Worst capital-allocation / governance: the entire company is controlled by one founder with a detention record and a history of freezing withdrawals for 5 weeks — the ultimate "misaligned incentive / concentration" risk. There is no audited P&L; every financial claim in this dossier is management-adjacent or third-party guesswork. You cannot underwrite the equity because you cannot see the books.
• What must hold for $25B: that OKX earns ~$3–4B, that the monitor exits cleanly in 2027, that OKXICE actually ships regulated products (SEC-gated), and that no second enforcement action lands. Break any one and the mark is aspirational.
• If growth disappoints 20–30%: in a crypto-bear tape, derivatives volume can halve; a $25B mark on a halved-volume, thin-margin, unauditable, founder-controlled exchange under a criminal monitor looks like it could re-rate toward $12–15B in a private secondary.
• Single scenario that permanently impairs: a sanctions/AML enforcement action during the monitorship that costs OKX its EU MiCA or US license — post-July-2026 that is not a fine, it is losing the right to operate the regulated flow the whole thesis depends on.

Lens 14 · Management Questions (15, ordered by information value)

1. Show us the audited financials: what were 2024 and 2025 revenue, EBITDA, and net income, and who is the auditor? (Nothing matters more — the equity is un-underwritable without this.)
2. What is the exact status of the DOJ compliance monitorship, what are its milestones, and does OKX expect a clean exit in 2027 — or any extension/second action?
3. What is the precise cap-table and control structure — Star Xu's economic and voting ownership, any dual-class rights, and what governance the ICE board seat actually carries?
4. What concrete, regulator-approved products has OKXICE shipped or filed for (US-regulated crypto futures, tokenized NYSE equities), and what is the SEC/CFTC approval timeline?
5. What is OKX's realistic IPO window and venue, and what specific conditions (monitor exit, revenue threshold, tape) gate it?
6. What is the revenue split across derivatives / spot / Earn / Web3 / X Layer, and how concentrated is profit in derivatives?
7. What is OKX's exposure to a Tether (USDT) de-peg or freeze, and what is the fiat-rail redundancy across jurisdictions?
8. Post-2020 withdrawal freeze, what is the liquidity/segregation architecture guaranteeing 24/7 withdrawals — and are client assets bankruptcy-remote and fully segregated?
9. How defensible is the #2 derivatives position against Bybit/Bitget and, more pointedly, on-chain perp DEXs (Hyperliquid) that undercut the CEX model?
10. What is the succession / key-man plan for Star Xu, given his concentration of control and China-origin geopolitical exposure?
11. What is OKX's China exposure today — personnel, infrastructure, regulatory — and how is it ring-fenced from the US/EU regulated entities?
12. Post-OKB supply lock (fixed 21M), what is the long-term economic relationship between OKB holders and exchange cash flows — is OKB a value-accrual asset or purely a fee/gas utility?
13. What are OKX Ventures' book value, largest positions, and the accounting treatment on the balance sheet?
14. What is the customer-quality picture — active vs the 120M "accounts," geographic mix of regulated vs offshore flow, and how much revenue still comes from lightly-regulated jurisdictions?
15. What is the capital return / dividend policy the leadership references ("give back shareholder value") — buybacks, dividends, or reinvestment — and against what earnings base?

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