OKX Pay Target Market Determination

Peer-to-Peer Stablecoin Transfer Non-Cash Payment Facility

What is a Target Market Determination? A Target Market Determination (TMD) describes the cohort of customers that the product is targeted at (the target market) and any conditions around how the product is distributed to customers. It describes events or circumstances where we are required to review the TMD for a financial product (review triggers).

1. Purpose and Status of This Document

This document is not a substitute for the product’s Terms and Conditions or other disclosure documents. When making a decision about this product, customers must refer to the relevant Product Disclosure Statement (PDS) or other disclosure documents.

This Target Market Determination (TMD) is prepared by Bano Pty Ltd (ABN 93 643 260 431, AFSL 536984) (Issuer) for the purposes of Part 7.8A of the Corporations Act 2001 (Cth) (Corporations Act) and applies to the issue and distribution of OKX Pay to retail clients in Australia.

This document describes the class of retail consumers for whom OKX Pay is likely to be appropriate (the target market), the conditions and restrictions on distribution, review triggers, and reporting obligations.

This TMD is not a Product Disclosure Statement (PDS). It does not take into account any particular client's objectives, financial situation, or needs. Prospective users should read the PDS, and Financial Services Guide (FSG) available at www.okx.com/en-au/pay before deciding to acquire OKX Pay.

This TMD should be read together with the PDS, which sets out the detailed terms of the product and the legal rights and obligations of users.

2. Product Description and Key Attributes

2.1 Overview

OKX Pay is a peer-to-peer (P2P) stablecoin transfer non-cash payment (NCP) facility issued by Bano Pty Ltd under AFSL 536984 and distributed by OKX Australia Pty Ltd (ABN 22 636 269 040). It enables retail clients to send and receive supported stablecoins to and from other OKX users via P2P transfers at no cost.

2.2 Key Attributes

3. Target Market

OKX Pay is likely to be appropriate for retail clients who satisfy each of the criteria below.

3.1 Eligibility

3.2 Objectives and Needs

Retail clients in the target market are likely to have one or more of the following objectives:

• Zero-fee P2P transfers:

  Sending and receiving stablecoins to and from other OKX users without transaction fees, gas fees, or network fees.

• Convenient access:

  A simple, app-based way to transfer stablecoin holdings to other OKX users without on-chain gas fees or mainnet confirmation delays.

• Near-instant settlement:

  P2P transfers processed on X Layer with near-instant confirmation, without waiting for Ethereum mainnet block confirmations.

• USDG Promotional Rewards:

  Earning promotional rewards (where available) for holding USDG in the Pay Wallet, credited in USDG.

• Enhanced security:

  2-of-2 smart wallet architecture requiring authorisation from both user and OKX, with PassKey biometric authentication.

3.3 Financial Situation

The target market consists of consumers who:

• Have discretionary funds available in the form of stablecoins and are not reliant on those funds for essential living expenses, rent, or near-term financial obligations.

• Understand that stablecoins held in the Wallet are not bank deposits and are not covered by the Financial Claims Scheme or any government guarantee.

• Can absorb potential losses arising from stablecoin de-peg events or exchange rate movements without material financial hardship.

3.4 Knowledge and Risk Tolerance

Consumers in the target market should:

• Have a basic understanding of stablecoins and digital assets, including the concept that stablecoins aim to maintain (but may not always maintain) a 1:1 peg to USD.

• Understand that P2P transfers are irreversible once claimed by the recipient and that

  unclaimed transfers are returned after 2 days (48 hours).

• Appreciate that the Issuer is not a subscriber to the ePayments Code and that a bespoke (not code-based) liability framework applies to unauthorised and mistaken transactions.

• Be comfortable with technology-dependent payment infrastructure (smart contracts, blockchain, mobile apps) and accept associated availability and operational risks.

• Understand that P2P transfers may be delayed, blocked, or cancelled due to AML/CTF screening or other risk or regulatory reasons.

• Have a low-to-moderate risk tolerance regarding the value of stablecoins and accept that purchasing power may fluctuate.

4. Negative Target Market and Ineligible Consumers

OKX Pay is NOT suitable for- and must not be distributed to - retail clients who fall into any of the following categories:

4.1 Financial Capacity

• Clients who cannot afford to lose some or all of the value of stablecoins held in their Wallet.

• Clients in financial hardship, bankruptcy, or unable to meet day-to-day financial needs.

• Clients who intend to use the Wallet as a substitute for a bank savings account, term deposit, or guaranteed-return product.

4.2 Knowledge and Understanding

• Clients who have no understanding of digital assets, stablecoins, or blockchain technology.

• Clients who lack the capacity to understand that stablecoins are not bank deposits and may lose value.

• Clients who do not understand that P2P transfers are irreversible once claimed by the recipient.

• Clients who do not understand that the ePayments Code does not apply and that liability allocation differs from standard bank cards.

4.3 Purpose

• Clients who require merchant payment or card functionality (Pay is not a card and cannot be used at merchants).

• Clients who require guaranteed real-time settlement without any smart-contract or blockchain dependency.

• Clients seeking a credit facility (Pay is not a credit product, does not offer credit, and all transfers are limited to stablecoins held in the Wallet).

• Clients who intend to use Pay for any illegal activities, including money laundering, terrorism financing, or transferring funds in connection with illegal goods or services.

4.4 Jurisdiction

• Persons who are not Australian residents.

• Persons located outside Australia at the time of acquisition (unless otherwise verified).

• Persons who do not hold, or cannot obtain, acceptable Australian identification.

5. Product Attributes and Consumer Objectives/Needs Matrix

The following table maps each key product attribute to the consumer objectives/needs it serves and the relevant PDS cross-reference.

6. Distribution Conditions and Restrictions

The following conditions and restrictions apply to the distribution of OKX Pay to ensure it reaches consumers within the target market ("reasonable steps").

6.1 Approved Distribution Channels

• Pay may only be acquired via the OKX App.

• Pay must not be distributed through cold-call telemarketing or unsolicited door-to-door solicitation.

6.2 Geographic and Identity Controls

• Acquisition restricted to persons located in Australia at the time of onboarding to OKX Australia.

• Applicants must be identified as residents of Australia at the time of onboarding to OKX Australia.

• AML KYC identity verification must be completed before Pay activation.

6.3 Pre-Activation Acknowledgements

Before Pay is activated, the applicant must confirm (via in-app acknowledgement) that they:

• Understand that stablecoins may lose their peg to USD and are not bank deposits or government-guaranteed.

• Understand that the Issuer is not a subscriber to the ePayments Code and that a bespoke liability framework applies.

• Understand that there are no P2P transfer fees within Pay.

• Understand that P2P transfers are irreversible once claimed and that Pay cannot be used for merchant payments, ATM withdrawals, or cash-out.

• Have read, or have been given access to, the PDS, and FSG.

6.4 Information and Disclosure Controls

• The current PDS, TMD, and FSG are published on the OKX Australia website (www.okx.com/en-au/pay) at all times, and a copy of each is made available to the applicant before Pay is activated.

• The PDS and TMD must be available on the Website and in the OKX App at all times.

6.5 Device and Security Controls

• The applicant's device must have the OKX App installed and internet connectivity to use Pay.

• PassKey (biometric or device-based) authentication must be configured before Pay activation.

6.6 Marketing and Copy Controls

• Promotion of Pay may be conducted through any channel reasonably available to OKX Australia, including:

  • digital advertising and social media,

  • content, editorial, partner and ambassador arrangements,

  • event sponsorships and brand activations

  • in-person promotional booths, stalls and activations, and

  • communications with existing OKX customers,

in each case provided that

• only general financial product advice is provided in connection with Pay; and

• activation of Pay is completed by the customer through the OKX App.

• The Issuer will have oversight over how the product is promoted and distributed. The product can only be distributed to customers in accordance with OKX’s product and process requirements approved by the Issuer.

  All marketing and promotional materials relating to Pay must receive compliance approval before publication.

• Marketing must not overstate benefits or downplay risks (including stablecoin de-peg risk, transfer irreversibility, and non-ePayments Code status).

• Marketing must include the general advice warning and a reference to the PDS. Where the channel does not accommodate the full general advice warning (for example, push notifications, character-limited social media or short-form advertising), a short-form warning or a deeplink to a page containing the warning and the PDS is sufficient.

• Scam-education prompts must be displayed during the onboarding flow (e.g., warnings about authorised push payment scams and never sharing credentials).

6.7 Accessibility

• Accessibility for the application process and use of Pay is supported by the accessibility features of the customer's mobile device operating system (Apple iOS or Google Android), including screen reader and other assistive technologies.

• Alternative formats of the PDS must be made available on request (e.g., large print, screen-reader-compatible).

6.8 Personal Advice Exclusion

• Where a distributor provides personal financial product advice to a retail client in real time, that conduct is excluded from the issuer’s “reasonable steps” for DDO. This TMD assumes distribution is direct-to-consumer via the OKX website/App without personal advice. Any affiliate channel must apply equivalent gating and pre-issuance acknowledgements and be pre-approved by the Issuer.

6.9 Record-Keeping

• OKX Australia must maintain records of each Pay activation, including evidence of identity verification; pre-activation acknowledgements; and timestamp of PDS acceptance.

• Records must be retained for a minimum of 7 years from the date of Pay activation or last transfer (whichever is later).

7. Review Triggers and Frequency

7.1 Periodic Review

This TMD must be reviewed at least every 12 months from the Effective Date (or from the date of the most recent review, whichever is later). The periodic review will assess whether the target market remains appropriate and whether distribution conditions continue to result in on-target outcomes.

7.2 Out-of-Cycle Review Triggers

In addition to the periodic review, this TMD must be reviewed promptly if any of the following events occur (illustrative thresholds in square brackets are subject to calibration by the Issuer):

• Stablecoin de-peg or liquidity event
  Any supported stablecoin (USDC, USDT, or USDG) trades at or below USD 0.95 for a period exceeding 24 hours, or experiences a liquidity event that materially impairs redemption or conversion.

• Materially adverse fee change
  A new fee is introduced for P2P transfers, or network transaction costs for Simple Portfolio transfers are increased in a manner that materially increases the cost of using Pay.

• Regulatory or scheme changes
  Any change to applicable law, ASIC regulatory guidance, or blockchain/digital asset regulations that materially affects the product's features, risks, or target market (including any restriction on stablecoin transfers or NCP facilities).

• Smart-contract or network incidents
  The X Layer network or OKX Pay Wallet smart contracts experience failures, outages, or exploits that materially delay or prevent P2P transfer processing on 3 or more days in any 30-day period.

• Unauthorised/scam claim incidence or AFCA adverse trends
  Unauthorised transaction or scam-related claims exceed 100 basis points of total Pay transfers in any calendar quarter; or AFCA issues an adverse determination or systemic issue finding relating to Pay.

• Significant transfer restriction or acceptance issues
  A material increase in complaints or support tickets relating to transfers being declined, blocked, or delayed due to AML/CTF screening or other restrictions.

• Material complaint spikes by classification
  A material increase (e.g., >50% quarter-on-quarter) in complaints classified under any single category (fees/FX, unauthorised transactions, declines/blocks, scams), suggesting a systemic product or distribution issue.

7.3 Distributor reporting requirements

7.3.1 Quarterly reports (within one month of quarter‑end) related to Pay

• Complaints by classification

  Number and nature of complaints categorised by fees, unauthorised transactions, declines/blocks, scams, service/access, privacy, other.

Where no data exists for a category in a period, OKX will submit a nil return for that category. Reports should highlight any metrics that meet or exceed the review triggers in Section 7.2 for the period.

7.3.2 Event‑based reports (within 5 business days)

Where a dealing is, or is likely to be, a significant dealing outside this TMD, OKX Australia must flag it as such in the report and provide the information required for the issuer’s notification to ASIC

7.3.3 Report content (event‑based)

Each event‑based report must include: dates; scale (customers/transactions/values); cohort (demographics/geography/channel); root cause (known at time); and remediation steps.

7.3.4 Reporting standards and method

OKX Australia (as sole distributor) will lodge reports to the Issuer via portal, using templates agreed with the Issuer. Where practicable, reports should adopt the FSC DDO data standards (Version 1.x) and classifications for complaints and significant‑dealing reporting. Significant‑dealing notifications must be made as soon as practicable and within 10 business days of becoming aware, with the data fields in Section 7.3.3.

OKX Australia will retain underlying source records and working data supporting each report for at least seven years and make them available to the issuer on request.

8. Significant Dealing Assessment and Notification

8.1 Criteria for Significant Dealing

A dealing is significant and inconsistent with this TMD if, having regard to the following factors, it indicates that the product is being distributed to consumers outside the target market in a manner that is more than trivial:

• Scale:

  The number of consumers affected, the proportion of total Pay activations they represent, and the total value of transfers involved.

• Harm:

  The actual or potential financial harm to consumers (e.g., losses from de-peg exposure, excessive fees, or unauthorised transactions for consumers who did not understand the liability framework).

• Duration:

  The period over which the off-target distribution occurred before detection and remediation.

8.2 Pay-Specific Examples

• Activation of Pay for a cohort of consumers who demonstrably did not meet KYC requirements or Australian residency criteria due to a system error.

• A significant number of Pay activations for consumers who immediately and consistently use Pay to send transfers that are declined or blocked due to AML/CTF screening, suggesting the product was distributed to consumers outside the target market.

8.3 Notification to ASIC

If the Issuer determines that a significant dealing has occurred, the Issuer must notify ASIC as soon as practicable and in any case within 10 business days of making the determination, in accordance with s 994H of the Corporations Act.

9. Appropriateness Assessment

The Issuer is satisfied that OKX Pay, together with its distribution conditions, is likely to deliver appropriate outcomes for consumers within the target market for the following reasons:

9.1 Product Design

• Pay provides a straightforward P2P stablecoin transfer facility, meeting the needs of consumers who already hold stablecoins and wish to send them to other OKX users at no cost.

• The zero-fee structure for P2P transfers is clearly disclosed in the PDS, with potential network costs for Simple Portfolio transfers also disclosed, enabling consumers to make informed decisions.

• The non-ePayments Code status and bespoke liability framework are prominently disclosed in the PDS, ensuring consumers understand the allocation of liability for unauthorised transactions before acquisition.

• Transfer restrictions (including AML/CTF screening) and the prohibition on illegal use reduce the likelihood of consumer harm from inappropriate use.

• App-based visibility (transfer history) empower consumers to manage security risks in real time.

9.2 Fee Transparency

• There are no fees for P2P transfers within Pay. There are no hidden or complex fee structures.

9.3 Scope and Restrictions

• The P2P-only scope and transfer restrictions are disclosed in the PDS, reducing the risk of consumer confusion about what Pay can and cannot do.

• Transfer irreversibility and the 2-day claim window are prominently disclosed, helping consumers understand the finality of authorised transfers.

9.4 Risk Disclosures

• The PDS identifies and explains: stablecoin de-peg risk; exchange rate risk; technology/smart-contract risk; regulatory risk; counterparty risk; transfer irreversibility; cyber risk; operational risk; and security risk.

• Pre-activation acknowledgements require consumers to affirmatively confirm understanding of key risks before Pay is activated.

9.5 Distribution Conditions

• Digital-only distribution through OKX's own App ensures a controlled environment where mandatory disclosures can be enforced.

• Australian residency verification at OKX onboarding prevents distribution to non-residents.

10. Record-Keeping and Availability

• This TMD is available free of charge on the OKX Australia website at (https://www.okx.com/en-au/help/okx-pay-target-market-determination) and in the OKX App.

• A paper copy is available free of charge on request by contacting OKX Australia at AUComplaints@okx.com or +61 2 8880 0709.

• The Issuer retains records of all TMD versions, review outcomes, distributor reports, significant dealing assessments, and related correspondence for a minimum of 7 years.

• Audit records (including evidence of distribution condition compliance, pre-issuance acknowledgements, and marketing approvals) are retained by OKX Australia and made available to the Issuer on request.

11. Stopping use of Pay and Dormancy

• If a user stops using their Pay Wallet (or the Issuer or OKX restricts access to Pay), the remaining stablecoin balance remains available for withdrawal to the user’s OKX exchange account (Simple Portfolio). See PDS.

• Users may stop using their Pay Wallet at any time by withdrawing their stablecoins to their Simple Portfolio. The Pay Wallet is an on-chain smart contract and cannot be closed, but it can be left dormant. Users may also contact OKX to request that we restrict further use of their Pay Wallet.

• Full terms governing ceasing use and dormancy are set out in the PDS.

• Unclaimed property: Any unclaimed balances will be dealt with in accordance with applicable Australian legislation (including state/territory unclaimed money legislation, to the extent applicable).