How to prepare for a larger settlement of observance error: the OKX method

Confidential protocols introduced to deal with news of regulatory failure from one of the top-five crypto exchanges, OKX, suggests that the company has probably expected a settlement with US authorities for some time.

This happened Monday when OKX announced a $ 500 million settlement plus with the US Ministry of Justice after not securing a money transmitter license and allegedly facilitating $ 5 billion in “suspicious transactions and criminal income.”

OKX’s careful planning creates some fascinating reading. The secret crisis management document seen by Coindesk refers to a message “SWAT -Team” that can be mobilized to implement different ways that the company’s top executives can communicate a settlement via social media and when talking to journalists.

Well before Monday’s big fine and forfeiture, OKX had produced specific guidance on running DOJ as well as the US Ministry of Finance’s Office of Foreign Assets (OFAC or sanctions watchdog), for example.

A preferred approach is to point out that the entire crypto industry has largely been under intense control and that OKX is fully cooperating with regulators, the document says. This was repeated in Monday’s press release, which said OKX “values” Doj’s “collaboration”.

Since the administration of President Donald Trump took over last month, the main focus of regulatory agencies in the Crypto Arena has been to reverse their previously aggressive enforcement position, where SEC dropped ongoing litigation and final investigations. But not so in the case of OKX, which, like Kucoin with its recent $ 300 million penalties and Binance back in 2023, has been forced into expensive settlements.

The guidance refers to what is expected of OKX founder Star XU, President Hong Fang and other leaders when it comes to “their social media actions in two scenarios: 1) Leakage before ofac -Running, 2) by OFAC conduct.”

In the question of OFAC, whose managers are asked if OKX has earned sanctioned markets, a proposal is to say: “Customers from sanctioned markets are sliding through as we had immature observance control and systems […] It is a very small and insignificant part of OKCOIN or OKX customer base. “

In fact, Monday’s press release from OKX acknowledged that US customers were able to act on the global exchange.

“The total number of US customers involved – no longer on the platform – made up a small percentage of the company’s worldwide customer population,” the release said.

Fire consciousness

Another priority for OKX is how the company choreographs its big ticket sponsorship schemes with them as Manchester City Football Club, F1 Team McLaren and Tribeca Film Festival. The company estimates that about $ 100 million a year has been spent on these partnerships in the last three years.

The action plan for fire partners involves the OKX marketing manager who gives each partner a phone call “in the last hour before the news breaks down.”

The recommended strategy here is to say that OKX has prepared for a regulatory review in view of the increased control of cryptic companies. If asked why the stock exchange did not share information about this before, the document says that these are pending inquiries and non-public affairs. There is also a bullet point that suggests CMO and OKX’s head of legal “Review clauses in our fire partner contracts again.”

Mention not Okb

Another detail that gets attention in the OKX planning document is Exchange’s original cryptocurrency, OKB. An obvious concern in the wake of FTX is any suggestion that OKB has been used as security or to finance any operation of OKX, as was the case with FTX’s FTT token.

Of course, the Okb Exchange token has not been subject to anything like the misleadings at FTX’s Exchange -Token. However, it was involved in a sudden flash accident in January 2024, after which OKX quickly offered to compensate users who were lost. The token, which has a relatively thin trading volume and liquidity, so that 10 sleeping wallets become active and start shopping just before the crash, according to Marina Khaustova, COO Crystal Intelligence, a blockchain analytic company.

Not long after the OKB crash, OKX leaders Tim Byun, the former CEO of OKCOIN and head of Global Government Relations and head of the product Wei Lan became OKX. A source familiar with the situation said Byun was “sacrificed” after the OKB crash.

It is not surprising that the OKX Comms protocol emphasizes that Execs must “refrain from mentioning OKB and only refer to this if asked.”

Media management

Another part of the puzzle is how the exchange should handle media examinations. Should OKX receive E emails or a phone call from a journalist looking for comments on ongoing investigations, the SWAT team and the PR team must go into action to “buy time by offering leadership plans”

Meanwhile, the plan is “to contact the most important friendly publications for a parallel story to seeds in a free tale for the original story,” the document states.

“1. Push for Delay 2 .. Confirm friendly publications 3.

OKX did not make a comment before pressing time

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