OKX operator pleaded guilty to unlicensed U.S. money transmission

Aux Cayes FinTech Co. Ltd., the Seychelles-based operator doing business as OKX and formerly as OKEx, pleaded guilty on February 24, 2025 to one count of operating an unlicensed money-transmitting business. U.S. District Judge Katherine Polk Failla presided over the plea and sentencing in the Southern District of New York.

The company agreed to criminally forfeit approximately $420.3 million and pay a criminal fine of approximately $84.4 million, bringing the monetary consequences above $504 million. The action mattered beyond the size of the payment: it applied U.S. registration and anti-money-laundering obligations to an offshore exchange whose formal policy prohibited U.S. customers but whose admitted conduct reached deeply into the American market.

What the guilty plea established

The criminal information covered conduct from approximately 2018 through at least early 2024. It said U.S. retail and institutional customers conducted more than $1 trillion in transactions through OKX while the operator remained unregistered with the Treasury Department’s Financial Crimes Enforcement Network as a money-services business.

Registration would have brought related Bank Secrecy Act duties, including an effective anti-money-laundering program, customer-identification procedures, recordkeeping and suspicious-activity reporting. The information distinguished Aux Cayes FinTech and OKX from the affiliated U.S. exchange OKCoin USA, which was registered with FinCEN. The plea concerned the unregistered operator, not every company using the OKX or OKCoin brands.

OKX maintained an official restriction against U.S. customers and blocked U.S.-located internet addresses. According to the company’s admissions and court records, however, it knew customers could evade that restriction with virtual private networks. Until approximately November 2022, retail users could open accounts, transfer funds and trade without completing a know-your-customer process; certain older accounts continued trading without completed checks into early 2023.

The information also described trading through “non-disclosure brokers,” which could place orders without identifying the underlying customers, until approximately early 2024. It alleged that employees sometimes advised prospective U.S. customers to submit inaccurate nationality or identification information after customer checks became mandatory.

U.S. institutional activity was especially significant to the case. One institutional customer conducted approximately $1.2 trillion in spot and derivatives transactions between approximately 2019 and 2023 and ranked among the platform’s four largest customers during those years. This figure overlaps with, rather than adds to, the broader transaction totals described in the record.

Compliance failures became a market-structure issue

The Justice Department said OKX did not adequately or consistently use commercially available transaction-monitoring software until approximately May 2023 and lacked adequate controls for identifying parties potentially subject to U.S. sanctions. Based on a review of third-party transaction data, prosecutors attributed more than $5 billion in suspicious transactions and illicit proceeds to activity conducted through the platform.

That $5 billion figure did not mean every transaction was separately adjudicated as money laundering, nor did the single conviction charge customers with crimes. The offense admitted by Aux Cayes FinTech was operating an unlicensed money-transmitting business. The suspicious-activity estimate supplied context for the compliance consequences but was not an audited measure published with transaction-level records.

The case nevertheless demonstrated how customer location, institutional liquidity and access controls could bring a nominally offshore exchange within the U.S. enforcement perimeter. A website restriction was not sufficient when the operator knew U.S. customers were trading, derived substantial revenue from them and failed to register.

What remained unresolved on February 24

OKX received cooperation credit and a 25% reduction from the bottom of the otherwise applicable recommended fine range. It also agreed to retain, at its own expense through February 2027, an external compliance consultant first engaged in early 2024 and to continue cooperating with federal prosecutors.

The event-day record did not quantify affected customer balances, identify the institutional customers, allege customer losses or establish a direct effect on cryptocurrency prices. It therefore supported a firm conclusion about criminal liability and compliance obligations, but not a claim that the plea caused a particular market movement or resolved every jurisdictional question facing offshore exchanges.