Target Market Determination OKX Card

Target Market Determination OKX Card

Virtual Mastercard 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 OKX Cardholder Agreement or other disclosure documents. When making a decision about this product, customers must refer to the OKX Cardholder Agreement.

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 the OKX Card to consumers who are NOT Australian residents.

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

This TMD is not (nor forms part of) the OKX Cardholder Agreement. It does not take into account any particular person's objectives, financial situation, or needs. Prospective cardholders should read the OKX Cardholder Agreement before deciding to acquire the Card.

This TMD should be read together with the OKX Cardholder Agreement, which sets out the detailed terms of the product and the legal rights and obligations of cardholders.

This document does NOT apply to Australian residents. Australian residents must use the separate Australian PDS and TMD, available at www.okx.com/en-au/help.

This product is not available for acquisition by issue in Australia. It is distributed exclusively to persons outside Australia through the OKX App.

Information in this TMD is current as at the Effective Date but may change. While reasonable care is taken, no representation or warranty is given that it is complete or error-free. The Issuer may amend this TMD and will publish the current version at https://www.okx.com/help/okx-card-global-target-market-determination. Applications are accepted only via the OKX App.

2. Product Description and Key Attributes

2.1 Overview

The OKX Card is a virtual Mastercard non-cash payment (NCP) facility issued by Bano Pty Ltd under AFSL 536984 and distributed by Aux Cayes FinTech Co. Ltd. (trading as OKX). Aux Cayes FinTech Co. Ltd. is not a corporate authorised representative of the Issuer but is permitted to distribute the Card on behalf of the Issuer outside Australia. The Card enables consumers (who are not Australian residents) to make everyday purchases using stablecoins held in their OKX Pay Wallet.

2.2 Key Attributes

3. Target Market

3.1 Eligibility

The OKX Card is designed for and may only be distributed to consumers who satisfy ALL of the following criteria:

• Age: 18 years or older.

• Residency: NOT an Australian resident. Australian residents are excluded from this product and must use the separate Australian product.

• OKX Account: Hold an active, verified OKX account with full AML/KYC verification completed to OKX's satisfaction.

• Wallet: OKX Pay Wallet activated and funded with supported stablecoins.

• Device: Compatible smartphone with Apple Pay or Google Pay capability and reliable internet access.

• Channel: Acquisition via the OKX App only.

• Jurisdiction: Must be in a jurisdiction where the Card is available under OKX's eligibility criteria and Mastercard Rules.

• Compliance: Must ensure use of the Card is lawful in their jurisdiction of residence and use.

3.2 Objectives and Needs

The OKX Card is likely to be consistent with the likely objectives, financial situation and needs of consumers in the target market who want:

• Everyday spending using stablecoins at merchants that accept Mastercard.

• Convenient access to spend stablecoin holdings without first converting to fiat currency.

• Global Mastercard acceptance for online and in-store purchases.

• Cashback rewards in USDG (where available and subject to separate terms).

• A digital-first virtual card experience with app-based controls.

3.3 Financial Situation

Consumers in the target market are likely to:

• Have discretionary funds held in stablecoins that they do not rely on for essential living expenses.

• Understand that stablecoins are not bank deposits and are not covered by any deposit insurance or government guarantee in any jurisdiction.

• Be able to absorb potential losses from de-peg events, exchange rate movements, or spreads without material financial hardship.

3.4 Knowledge and Risk Tolerance

Consumers in the target market are likely to:

• 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 the dual-conversion mechanism (local currency to USD to stablecoins) and that exchange rates and spreads apply to every transaction.

• Appreciate that a bespoke liability framework applies to unauthorised and mistaken transactions and that liability allocation may differ from standard bank cards in the consumer's jurisdiction.

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

• Understand the risks of Dynamic Currency Conversion (DCC) if offered by a merchant.

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

• Understand and accept that use of the Card must comply with the laws of their jurisdiction of residence and use.

• Understand and accept that the Card may not be regulated, approved or licensed by any authority in their jurisdiction of residence and use.

4. Negative Target Market and Ineligible Consumers

The OKX Card is NOT suitable for- and must not be distributed to - consumers 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 the 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 exchange rates and a conversion spread apply to every Card transaction.

• Clients who do not understand that a bespoke liability framework applies and that liability allocation differs from standard bank cards.

4.3 Purpose

• Clients who require ATM cash withdrawals or cash-out functionality.

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

• Clients seeking a credit facility (the Card is not a credit card and does not offer credit).

• Clients who intend to use the Card for gambling, betting, or other restricted MCC activities.

4.4 Jurisdiction

• Australian residents (they must use the separate Australian product with the Australian PDS and TMD) if they wish to use the Card.

• Persons in jurisdictions where the Card is not available under OKX eligibility criteria or Mastercard Rules.

• Persons who cannot satisfy AML/KYC requirements to OKX's satisfaction.

• Persons who cannot lawfully use the Card in their jurisdiction of residence or use.

5. Product Attributes and Consumer Objectives/Needs

The following demonstrates how the key attributes of the OKX Card are consistent with the likely objectives, financial situation and needs of the target market, and how the product design mitigates or manages key risks:

5.1 Everyday Stablecoin Spending

Consumer Need: Convenient ability to spend stablecoin holdings at merchants globally.

Product Feature: Virtual Mastercard accepted wherever Mastercard is accepted; dual-conversion mechanism automatically converts stablecoins to local currency via USD.

Cardholder Agreement Reference: Section 5 (About the Card), Section 6 (Use of the Card).

5.2 Fee Transparency

Consumer Need: Clear understanding of all costs involved in using the Card.

Product Feature: Single 0.10% conversion spread, no issuance/replacement/refund fees; Mastercard rate publicly available; OKX rate visible in-app.

Cardholder Agreement Reference: Section 7 (Fees, exchange rates and charges).

5.3 Security and Control

Consumer Need: Ability to protect the Card and respond quickly to security issues.

Product Feature: In-app lock/unlock, biometric Pay Passkey, PIN, 3D Secure, push notifications for high-value transactions.

Cardholder Agreement Reference: Section 11 (Keeping your Card safe).

5.4 Liability Protection

Consumer Need: Fair allocation of liability for unauthorised transactions.

Product Feature: Bespoke framework limiting liability where cardholder has not contributed to loss; caps at USD 150/actual loss/Wallet balance.

Cardholder Agreement Reference: Section 12 (Unauthorised or incorrectly executed transactions).

5.5 Cashback Rewards

Consumer Need: Rewards for everyday spending.

Product Feature: Cashback in USDG on qualifying purchases (where available, subject to separate terms).

Cardholder Agreement Reference: Section 9 (Cashback).

5.6 Digital-First Experience

Consumer Need: Modern, app-based card management.

Product Feature: Virtual card with Apple Pay/Google Pay integration; real-time transaction history; instant card lock; push notifications.

Cardholder Agreement Reference: Section 5.1 (Description), Section 6.1 (How to authorise a payment).

Note: Section references to the OKX Cardholder Agreement in this TMD are based on the version current at the Effective Date. If the Cardholder Agreement is restructured or renumbered, references in this TMD will be updated at the next periodic review.

6. Distribution Conditions and Restrictions

6.1 Approved Distribution Channels

• The OKX Card may only be distributed through the OKX App (digital-only distribution).

• No cold-call telemarketing, unsolicited door-to-door sales, or unsolicited direct solicitation.

• No distribution through intermediaries or third-party platforms unless pre-approved by the Issuer and subject to equivalent eligibility gating requirements, and pre-issuance acknowledgement requirements.

6.2 Geographic and Identity Controls

• Distribution restricted to persons who are NOT Australian residents.

• If an applicant is identified as an Australian resident during KYC, issuance must be refused and the applicant directed to the separate Australian product (www.okx.com/en-au/pay).

• If a cardholder subsequently becomes an Australian resident, OKX must be notified and the Card may need to be surrendered or transitioned to the Australian product.

• Full AML/KYC verification must be completed before Card issuance.

• Eligible jurisdictions are determined by OKX and Mastercard Rules and may change from time to time.

6.3 Information and Disclosure Controls

• The OKX Cardholder Agreement and this TMD must be published on the OKX website at all times.

• A copy of the OKX Cardholder Agreement must be made available to the applicant before issuance.

• Key terms (fees, liability framework, stablecoin risks) must be clearly presented in the application flow.

6.4 Device and Security Controls

• OKX will maintain reasonable device and security controls.

6.5 Marketing and Copy Controls

• All marketing must clearly disclose:

(a) the Card is not a bank account or deposit;

(b) stablecoins are not government-guaranteed; and

(c) fees and spreads apply.

• Marketing must not overstate the benefits of the Card or understate the risks.

• Marketing must not be directed at Australian residents and must be limited to passive website applications only.

• There can be no proactive marketing (including search engine optimisation and equivalents) directed to any particular territory.

• No personal financial advice may be given or implied.

6.6 Accessibility

The OKX App and all disclosure documents are available in English. Key terms are presented in clear, plain English to support informed decision-making.

6.7 Personal Advice Exclusion

Neither OKX nor the Issuer provides personal financial advice in connection with the Card. No personal recommendation is made as part of the issuance process.

6.8 Record-Keeping

• OKX must maintain records of each Card issuance, including KYC verification records, pre-issuance acknowledgements, and agreement acceptance.

• Records must be retained for a minimum of 7 years.

• Records must be available to the Issuer on request.

7. Review Triggers and Frequency

7.1 Periodic Review

The Issuer will review this TMD at least every 12 months from the Effective Date.

7.2 Out-of-Cycle Review Triggers

The Issuer will also review this TMD if any of the following events occur:

• A material stablecoin de-peg event or liquidity event affecting any supported stablecoin (e.g. loss of peg exceeding 2% for more than 24 hours).

• A materially adverse change to the fee or spread structure.

• A regulatory or scheme change that materially affects the Card's availability, terms, or risk profile in any jurisdiction material to the Card's availability.

• A smart-contract vulnerability, network incident, or X Layer outage materially affecting Wallet availability or transaction processing.

• Complaint incidence exceeds 100 basis points of active cardholders in any rolling 90-day period.

• Significant restricted-MCC transactions are incorrectly approved due to a system or scheme error.

• A material spike in complaints or disputes relating to unauthorised transactions, fees, or exchange rates.

• Jurisdictional restriction - Mastercard or a regulator restricts or prohibits Card use in a jurisdiction with a material cardholder population.

• ASIC or another regulator makes a product intervention order or issues guidance materially relevant to the Card.

7.3 Distributor Reporting

OKX must report to the Issuer as follows:

• Quarterly reports (within 10 business days of quarter-end):

  • Number of Cards issued and closed during the quarter.

  • Number of complaints received and complaint-to-cardholder ratio.

  • Breakdown of complaints by category (unauthorised transactions, fees/charges, operational, other).

  • Any instances of Card issuance to Australian residents (breach of distribution condition).

  • Any instances of Card issuance in jurisdictions not within OKX's approved list.

  • Transaction volumes and values (aggregate).

• Event-based reports (within 10 business days of becoming aware):

  • Any event constituting a review trigger under section 7.2.

  • Any issuance to an ineligible consumer (including Australian residents).

  • Any material system failure, security breach, or operational incident.

  • Any regulatory inquiry, enforcement action, or AFCA determination relating to the Card.

• Reporting standards: Reports must be in writing, provided to the Issuer's nominated contact, and in a format agreed between the parties. OKX must retain copies of all reports for a minimum of 7 years.

8. Significant Dealing Assessment

A dealing in the OKX Card is taken to be a significant dealing that is not consistent with this TMD if it involves any of the following:

Scale

• A material number of Cards are issued to consumers outside the target market (e.g. Australian residents due to a system error in geographic controls).

• A material number of Cards are issued in jurisdictions where the Card is not permitted under OKX's approved jurisdiction list.

Harm

• One or more consumers suffer material financial loss as a direct result of product features or distribution failures inconsistent with this TMD.

• A significant number of Cards are used for restricted MCC transactions that are incorrectly approved due to a system or scheme error.

Duration

• The dealing involves a systemic or ongoing failure (rather than an isolated incident) that is not corrected within a reasonable period.

Card-specific examples of potentially significant dealings:

• Issuance of Cards to Australian residents due to a failure in geographic/identity controls.

• Issuance in jurisdictions where the Card is not available under OKX eligibility criteria or Mastercard Rules.

• Significant number of Cards incorrectly approved for restricted MCC transactions (gambling, betting, lottery, casino).

Notification: The Issuer will assess whether notification to ASIC under s 994H of the Corporations Act is required in respect of any significant dealing identified under this section. If the Issuer determines that s 994H applies, notification will be given to ASIC as soon as practicable and in any event within 10 business days of the determination being made.

9. Appropriateness Assessment

The Issuer is satisfied that:

(a) if the Card were issued to a consumer in accordance with the distribution conditions in section 6, it would be likely that the consumer is within the target market described in section 3 (s 994B(8)(a)); and

(b) if the Card were issued to a consumer in the target market described in section 3, it would likely be consistent with the likely objectives, financial situation and needs of that consumer (s 994B(8)(b)).

The Issuer has determined that the product is likely to be appropriate for the target market for the following reasons:

9.1 Product Design

• The Card is a simple, non-leveraged payment product that converts existing stablecoin holdings to merchant payments.

• No credit or borrowing is involved; all spending is limited to the cardholder's own stablecoin balance.

• Virtual-only issuance reduces loss/theft risks associated with physical cards.

• App-based controls give cardholders real-time visibility and control over their Card.

9.2 Fee Transparency

• A single, simple fee structure (0.10% conversion spread) is clearly disclosed before issuance and in the OKX Cardholder Agreement.

• No hidden fees, no issuance/replacement/refund fees.

• Mastercard exchange rate publicly available; OKX rate visible in-app.

9.3 Acceptance Qualifiers

• Restricted MCCs prevent use for gambling, betting and other high-risk activities.

• Transaction limits and in-app verification for high-value transactions.

• DCC caution clearly disclosed.

9.4 Risk Disclosures

• The OKX Cardholder Agreement clearly discloses: stablecoin risks, dual-conversion mechanism, bespoke liability framework, technology dependencies, and no deposit insurance.

• Pre-issuance acknowledgements require active consent to key risk statements.

• TMD published and accessible at all times.

9.5 Distribution Conditions

• Digital-only distribution via the OKX App ensures all applicants complete KYC and acknowledgement flows.

• Australian-resident exclusion prevents off-target distribution to consumers who should use the domestic product.

• Jurisdictional controls (OKX eligibility criteria, Mastercard Rules) prevent distribution to consumers in jurisdictions where the Card cannot lawfully operate.

• No cold-calling or unsolicited solicitation.

10. Record-Keeping and Availability

• This TMD is published on the OKX website and available free of charge upon request via OKX Help Centre.

• This TMD is published on a publicly accessible webpage that does not require account login or registration to access, in compliance with s 994B(9) of the Corporations Act.

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

• OKX retains issuance records, KYC records, acknowledgement records, and quarterly/event reports for a minimum of 7 years.

• The Issuer will maintain records of all decisions relating to this TMD, including the data and reasoning underlying the appropriateness assessment, review trigger calibration, and any amendments, for a minimum of 7 years from the date of the relevant decision.

11. End-of-Life and Dormancy

If the OKX Card is discontinued or a cardholder's Card reaches end-of-life:

• Any remaining stablecoin balance in the Wallet remains available for withdrawal to the cardholder's OKX exchange account.

• The Card expires 5 years from issuance. A replacement Card may be issued digitally at no cost before expiry.

• If a Card is dormant (no transactions for a continuous period of 12 months or more), OKX may contact the cardholder to confirm continued need. If no response is received after a further 30 days, the Issuer may close the Card with 14 days' written notice. The Wallet balance remains available for withdrawal.

• If the product is fully discontinued, the Issuer will provide at least 30 days' notice to all affected cardholders.