Crypto Asset Transfer Procedure
Last Update: 27 June 2025
CRYPTO ASSET TRANSFER PROCEDURE
1. GENERAL
OKX TR Kripto Varlık Alım Satım Platformu Anonim Şirketi (the “Company” or “OKX TR”) provides services related to buying, selling, swapping and transferring of crypto-assets. This document outlines the procedures for the transfer services provided by the Company in respect of crypto-assets (“Procedures”) in accordance with Article 24/2 (d) and 46/1 (ğ) of III-35/B.1. Communiqué on the Establishment and Operational Principles of Crypto Asset Service Providers (“Operational Principles Communiqué”).
This Procedure outlines the services related to the buying and selling of crypto assets, as well as the execution of such transactions. It also establishes the principles governing crypto-to-crypto swaps. Finally, the Procedure delineates the fundamental aspects of crypto transfers.
2. CLIENT DISCLOSURES
The Company shall implement robust security measures to protect client data and all information in relation to the transfer services.
The Company shall provide its clients with appropriate information in connection with the transfer services, in good time, prior to the execution of the terms of service with the Company (the “Framework Agreement”).
The Company shall ensure that the Framework Agreement and information provided to clients in connection with the Transfer Services are both: (i) easily understandable, clear and comprehensible; and (ii) accessible at any time during the client relationship. Each client shall be informed of relevant changes to the transfer services in a reasonable time before such changes are implemented by the Company.
3. PRINCIPLES RELATED TO BUYING AND SELLING CRYPTO ASSETS
The buying and selling of crypto assets refer to the exchange of crypto assets for fiat currency and vice versa. Currently, clients may purchase crypto assets solely using Turkish Lira (“TRY”). Other fiat currencies, such as USD and EUR, may be permitted, provided such transactions are not prohibited under applicable laws or by the decisions of relevant authorities.
Customer/Client Identification: Clients must fulfil identification requirements in order to engage in any transactions.
Prices Are Determined Freely: Prices are determined based on market conditions and OKX TR’s markup rate and the Company takes necessary precautions to prevent market manipulation.
4. SWAP TRANSACTIONS
Clients can perform swap transactions between the listed crypto asset pairs allowed by the platform. OKX TR provides services like convert, enabling the exchange of one crypto asset for another.
When performing swap transactions, OKX TR may set a minimum limit, and swaps of crypto assets below this limit may not be possible.
Swap prices are determined based on market conditions and OKX TR’s markup rate. Swap transactions are executed instantly and are non-reversible.
5. THE TRANSFER SERVICES BY THE COMPANY
Transfer services refer to the transfer of crypto assets in wallets to other wallets via distributed ledger technology (“Transfer Services”). The Transfer Services rely on blockchain technology, which provides a secure, transparent and decentralised ledger to record and verify transactions. Essentially, the Transfer Services include the following principal steps:
Initiating the Transfer: The sender generates a transfer request by specifying the blockchain,the recipient’s wallet address and the amount of crypto-assets to be transferred. Sender has to provide a digital signature for authorisation of this transfer.
Broadcasting the Transaction: The transaction is broadcasted to the network of nodes that validate and process transactions on the blockchain.
Transaction Validation: Nodes on the network validate the transaction by checking the sender’s wallet balance and verifying the digital signature. Consensus mechanisms (e.g., Proof of Work, Proof of Stake) are employed to agree on the validity of transactions and the order in which they are added to the blockchain.
Transaction Finalisation: The recipient’s wallet address is credited with the crypto-assets. Both the sender and recipient can verify the transaction details .
Additional Approval Requirement: As of the moment the transfer order is transmitted, transfer requests exceeding TRY 1,000,000 are subject to additional approval procedures.
6. INFORMATION ON TRANSFERS OF CRYPTO-ASSETS: TRAVEL RULE
The Company shall ensure that after receipt of an instruction to transfer crypto-assets, but before the execution of the transfer of crypto-assets, a client is provided with:
a standardised warning as to whether and when the crypto-asset transfer will be irreversible or sufficiently irreversible in case of probabilistic settlement;
any charges, commissions and taxes payable by the client and, if applicable, a breakdown of the amounts of such charges.
The initiation and execution of the crypto asset transfer shall not take place before ensuring compliance with the requirements of Applicable Law, including travel rule. The Company shall ensure that the following has been available in respect of the Transfer Services:
Information Requirements for Transfers ≥ 15,000 TRY: For crypto asset transfers of 15,000 TRY or more facilitated by crypto asset service providers, transfer messages must include the following sender information:
Full name (for individuals); trade name (for registered legal entities); or full name (for other entities);
Wallet address, or a transaction reference number if the wallet address is unavailable;
At least one identifier: address, place/date of birth, client number, citizenship number, passport number, or tax identification number.
All information pertaining to the sender must be verified. In contrast, for the recipient, only the name and wallet information are required, and no verification is necessary.
Information Requirements for Transfers < 15,000 TRY: For transfers below 15,000 TRY, messages must include sender and recipient:
Full name or trade name;
Wallet address or transaction reference number.
Verification is not required for transfers below 15,000 TRY.
Incomplete Transfer Messages
If a transfer message lacks required information, OKX TR will request missing data from the sending provider.
If missing info is not completed, the transfer will be returned.
If this issue occurs repeatedly and information is not provided when requested, the OKX TR may:
Reject further transfers;
Restrict transactions; or
Terminate the business relationship.
Message Chain Responsibility
All intermediary crypto asset service providers must include and preserve sender information throughout the transfer chain.
Special attention must be paid to transmitting the required details at every stage.
Secure and Synchronized Data Transmission
Sender and recipient data must be sent securely and simultaneously with the transfer.
OKX TR may use below technology to transmit transfer message:
Distributed Ledger Technology (DLT);
Independent messaging platforms;
Application interfaces (APIs);
Other technological tools that enable secure communication.
Transfers Involving Unregistered Wallet Addresses
For transfers to/from wallet addresses not registered with a crypto asset service provider (non-custodial wallets):
OKX TR collects a declaration from the client (transfer party) regarding the unregistered wallet holder’s:
Full name (for individuals) or trade name (for legal entities),
Plus at least one of the following: address, place/date of birth, client number, citizenship number, passport number, or tax identification number.
Transfers with Foreign-Based Providers Not Subject to Disclosure Obligations
If the transfer is to/from a foreign crypto asset service provider or financial institution that is not required to share sender/recipient information under its local law, OKX TR will obtain a declaration from the client regarding:
The name or title of the foreign party;
And at least one identifier: address, place/date of birth, client number, citizenship number, passport number, or tax identification number.
Risk-Based Enhanced Due Diligence
When applying rules regarding unregistered wallets and transfers with foreign-based providers, OKX TR may request additional information and documentation based on a risk-based approach. If sufficient data cannot be obtained, OKX TR may:
Refuse to complete the transfer;
Limit transactions with the relevant institution; or
Terminate the business relationship.
7. THE REJECTION OR SUSPENSION OF AN INSTRUCTION TO TRANSFER CRYPTO-ASSETS OR RETURN OF CRYPTO-ASSET TRANSFERRED
The Company may reject or suspend an instruction to transfer crypto-assets, or return any crypto-assets transferred to the Company, in any one or more of the following scenarios:
incorrect or insufficient information;
insufficient funds;
suspicion of unauthorised instructions;
high-risk transactions;
suspicion of fraud, money laundering, counter terrorist financing or other illicit or illegal activity at the discretion of the Company;
suspicion of any violation, or attempted violation, of Applicable Law;
technical errors or system failures;
incorrect wallet address;
request from administrative or judicial authorities to not execute the transfer;
detecting unauthorized using of client’s account;
detecting manipulative transactions.
Without prejudice to any other applicable requirements under a pplicable l aw, where a transfer of crypto-assets is rejected, returned or suspended, the Company shall provide the client with the following information:
the reason for the rejection, return or suspension;
if applicable, how to remedy the rejection, return or suspension;
the amount of any charges or fees incurred by the client; and
if reimbursement to the client is possible;
8. EXECUTION TIMES AND CUT-OFF TIMES
The Company's platform is in operation 24x7 (24 hours a day, 7 days a week), other than during maintenance periods or unscheduled outages in the unlikely event of system/infrastructure faults so cut-off times for transfer services are deemed not applicable.
Transfer requests are processed in real time as soon as they are received in OKX TR's wallet infrastructure. Sometimes, due to internal wallet balances on OKX TR and the balancing process between hot and cold wallets, delays may occur. In such cases, withdrawal transactions cannot be triggered until the balance adjustment is completed. Once processing is completed, the signed transaction for the transfer request will be broadcasted to the blockchain. Execution time on the blockchain and the number of block confirmations needed for the transfer of crypto-assets to be deemed irreversible depends on the blockchain and is beyond the Company's control.
Price Priority: Priority is given to the best available ask or bid offers.
Time Precedence: An order entered into the system earlier must be fully executed before any subsequent order at the same price is processed, based on the timestamp of each order’s placement in the order book.
OKX TR utilizes a pre-funded trading model, meaning that no orders will be accepted from a client unless sufficient funds (whether fiat or crypto assets) are available in the client’s trading account. Upon placing an order, the corresponding amount of fiat or crypto assets (including applicable fees) will be held in the client's account until the order is filled, expires, or is canceled.
Orders may be partially filled or executed through multiple matching orders from different users. Any unfilled portion of an order will remain on hold until it is completed, expires, or is canceled.
9. LIABILITY OF THE COMPANY IN RELATION TO TRANSFER SERVICES
OKX TR shall not be liable for any unauthorised or incorrectly initiated or executed transfers of crypto assets unless the loss or damage occurred due to the gross negligence, wilful misconduct, or deliberate default of or by the Company. Furthermore, the Company shall not be liable to the client if the loss or damage occurred due to a force majeure event or due to the actions or failures of third-party service providers.
The clients of the Company shall notify the Company of any unauthorised transfer as soon as possible and, in any case, within three (3) calendar days from the date the unauthorised transfer occurred. The failure to notify within this period may limit or exclude the liability of the Company. Upon receiving a notification of an unauthorised transfer, the Company will promptly investigate the claim and inform the client of the outcome within a reasonable timeframe.
10. COMPLIANCE
The risk management personnel shall, on a regular basis, review the Transfer Services in accordance with the compliance monitoring programme established by the Company under the Applicable Law.
The responsible unit and personnel shall notify the senior management of any breaches to these Procedure.
11. REGULAR REVIEW AND APPROVAL
This Procedure will be reviewed annually, or more frequently if necessary, by the Document Owner or the Document Author to ensure it remains up-to-date with regulatory changes and business practices. If deemed necessary (e.g., for the purpose of aligning with current industry practices or complying with new legislative requirements), it will be updated accordingly.
The Document Approver's approval is required at least once every year or when major and significant revisions are made, whichever precedes. Minor and limited revisions may be approved by the Document Owner, unless the Document Owner is also the Author.
This Procedure shall enter into force on 18 June 2025 and will be published on the Company’s website.
This Procedure shall be construed in accordance with the laws of Türkiye.
12. RECORD KEEPING
A copy of this Procedure will be retained for a minimum of ten (10) years or longer, in accordance with applicable legislation.