OKX Card Target Market Determination

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 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 the OKX Card to retail clients in Australia.

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

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

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 OKX Australia Pty Ltd (ABN 22 636 269 040). It enables retail clients to make everyday purchases using stablecoins held in their OKX Pay Wallet.

2.2 Key Attributes

3. Target Market

The OKX Card 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:

• Everyday spending: Using stablecoins for everyday purchases (online and in-store) via a familiar card network.

• Convenient access: A simple, app-based way to spend stablecoin holdings without first converting to fiat via a bank transfer.

• Global acceptance: Making purchases wherever Mastercard is accepted, including overseas, funded from a single stablecoin wallet.

• Cashback rewards: Earning cashback (where available) on qualifying purchases, paid in USDG.

• Digital-first experience: Virtual card with instant issuance, in-app controls, and mobile-wallet integration (no physical card needed).

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

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

• 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

The OKX Card 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 exchange rates and a conversion spread apply to every Card transaction.

• 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 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

• 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 the OKX Card to ensure it reaches consumers within the target market ("reasonable steps").

6.1 Approved Distribution Channels

• The Card may only be acquired via the OKX App.

• The Card must not be distributed through cold-call telemarketing or unsolicited door-do-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 Card issuance.

6.3 Pre-Issuance Acknowledgements

Before the Card is issued, 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 a conversion spread (currently 0.10%), and Mastercard and merchant charges may apply to all Card transactions.

• Understand that the Card cannot be used for 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 application before the Card is issued.

• 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 support Apple Pay or Google Pay to use the Card.

• PassKey (biometric) authentication must be configured before Card activation.

6.6 Marketing and Copy Controls

• Promotion of the Card 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 the Card; and

  • acquisition of the Card is completed by the customer through the OKX App.

• The Issuer will have oversight over how the product is promoted and issued. 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 the Card must receive compliance approval before publication.

• Marketing must not overstate benefits or downplay risks (including stablecoin de-peg risk, conversion spread, and non-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 the Card 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 Card issuance, including evidence of identity verification; pre-issuance acknowledgements; and timestamp of PDS acceptance.

• Records must be retained for a minimum of 7 years from the date of Card issuance or last transaction (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 or spread change
  The OKX conversion spread is increased by more than 100% of the prevailing rate (e.g., from 0.10% to above 0.20%), or a new fee is introduced that materially increases the cost of using the Card.

• Regulatory or scheme changes
  Any change to applicable law, ASIC regulatory guidance, or Mastercard scheme rules that materially affects the product's features, risks, or target market (including any restriction on stablecoin-funded cards 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 transaction funding 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 Card transactions in any calendar quarter; or AFCA issues an adverse determination or systemic issue finding relating to the Card.

• Significant restricted-MCC or acceptance issues
  A material increase in complaints or support tickets relating to transactions at restricted merchant categories being incorrectly approved, or Mastercard network restrictions preventing use in previously available jurisdictions.

• 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 Card

• Complaints by classification

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

• Restricted‑MCC declines and insufficient‑funds/limit declines

  Volumes and values.

• Issuances and activations

  Cancellations and closures initiated by OKX (top reasons);

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 Card issuances they represent, and the total value of transactions 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 Card-Specific Examples

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

• A significant number of Cards issued to consumers who immediately and consistently use the Card for restricted MCC transactions that are incorrectly approved.

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 the OKX Card, 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

• The Card provides a straightforward spending facility (virtual Mastercard) funded by stablecoins, meeting the needs of consumers who already hold stablecoins and wish to use them for everyday purchases.

• The dual-conversion mechanism is clearly disclosed in the PDS, including the current conversion spread (0.10%), enabling consumers to make informed cost comparisons.

• 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.

• Restricted MCCs (including gambling) reduce the likelihood of consumer harm from inappropriate use.

• App-based controls (lock, unlock, limit visibility) empower consumers to manage security risks in real time.

9.2 Fee Transparency

• The 0.10% conversion spread is a single, simple fee that applies to all transactions. There are no hidden or complex fee structures.

• All fees are GST-inclusive and clearly stated.

9.3 Acceptance Qualifiers

• Scheme restrictions, country restrictions, and restricted MCCs are disclosed in the PDS and accessible via in-app links, reducing the risk of consumer surprise or frustration.

• DCC cautions are prominently displayed, helping consumers avoid unnecessary merchant-imposed conversion costs.

9.4 Risk Disclosures

• The PDS identifies and explains: stablecoin de-peg risk; exchange rate risk; technology/smart-contract risk; regulatory risk; counterparty risk; settlement timing risk; and security risk.

• Pre-issuance acknowledgements require consumers to affirmatively confirm understanding of key risks before the Card is issued.

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/help/okx-card-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. End-of-Life and Dormancy

• If a cardholder closes their Card (or the Issuer terminates the Card), the Wallet balance remains available for withdrawal to the cardholder's OKX exchange account. See PDS.

• Cards expire 5 years from issuance. The Issuer may issue a replacement before expiry. Upon expiry, the Wallet balance remains available for withdrawal.

• Cards that have had no transaction activity for a period of time may be classified as dormant. The Issuer or OKX Australia may close dormant Cards after giving the cardholder at least 14 days' written notice, or longer if required by law. The Wallet balance remains available for withdrawal following closure.

• Full terms governing closure, expiry, and dormancy are set out in the PDS (Card Suspension, Termination, and Replacement).

• 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).