The OKX peer-to-peer (C2C) trading platform is committed to maintaining a secure, transparent, and trustworthy trading environment for all users. To ensure the integrity of transactions and protect user assets, OKX has established a comprehensive C2C Certified Merchant Risk Rating Management System. This framework enables dynamic, data-driven evaluation of merchant behavior, ensuring fair and consistent risk management across the platform.
This document outlines the principles, evaluation criteria, risk classifications, and enforcement measures that govern how OKX monitors and manages merchant risk levels. Whether you're an active merchant or considering joining the network, understanding this system is essential for compliance and long-term participation.
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Purpose and Scope
Objective and Legal Basis
The primary objective of the OKX C2C Certified Merchant Risk Rating Management Guidelines is to strengthen risk oversight for both certified and diamond-level merchants—collectively referred to as "merchants." By implementing precise, fair, and transparent risk assessment mechanisms, OKX aims to safeguard user rights and enhance platform security.
These guidelines are formulated in accordance with the following foundational documents:
- OKX Platform Certified Merchant Transaction Behavior Standards
- OKX C2C Trading Rules
- Other relevant platform policies and announcements
Together, they form a holistic risk management ecosystem designed to respond dynamically to evolving threats such as money laundering, fraudulent activity, and non-compliant trading practices.
Applicability
These guidelines apply to:
- All users who have applied to become certified merchants on the OKX C2C platform
- Users who have initiated requests to deactivate their merchant status but whose assets remain locked in their platform accounts during review
By applying for merchant status, users explicitly agree to comply with these rules. Non-acceptance of these terms requires immediate notification to OKX to cancel the merchant application.
Enforcement Authority
This policy applies specifically to day-to-day risk management activities conducted by OKX. Once published, it becomes binding on all merchants. If a merchant’s trading behavior violates any provision within this framework, OKX reserves the right to take disciplinary action in accordance with these guidelines—prioritizing them over general platform rules when applicable.
Risk Evaluation Framework
Rating Cycle
Risk assessments are performed on a regular basis. OKX continuously evaluates merchants based on real-time transaction patterns, service performance, and compliance history. The goal is to maintain an up-to-date, accurate reflection of each merchant's risk profile.
Key Risk Indicators
OKX employs a multi-dimensional approach to assess merchant risk, analyzing the following core indicators:
1. Detection of Abnormal Behavior via Internal Monitoring
During the evaluation period, if internal risk detection systems identify suspicious activity—including high-risk transaction patterns or triggers in anti-money laundering (AML) protocols—the following may occur:
- The merchant is flagged by the AML system and required to undergo advanced verification (e.g., video authentication)
- The merchant is asked to re-verify identity or provide additional documentation for AML investigations
- The merchant is confirmed to have participated—directly or indirectly—in money laundering through digital asset transactions
Such findings significantly impact risk scoring and may lead to immediate restrictions.
2. Violations of Published Platform Rules
Merchants found violating OKX’s publicly disclosed policies may face elevated risk ratings. Specific violations include:
- Being investigated by law enforcement due to suspicious trading activities
- Conducting trades off-platform (e.g., via private groups on WhatsApp, Telegram, or WeChat)
- Ignoring warnings about blacklisted withdrawal addresses and transferring funds to high-risk platforms
- Using identical payment accounts across multiple exchanges without proper fund segregation
- Causing other users’ accounts to be frozen due to illicit asset origins
- Repeated or severe breaches of the Certified Merchant Transaction Behavior Standards or C2C Trading Rules
These actions demonstrate disregard for platform safety and increase systemic risk.
3. Additional Risk Considerations (Reference Only)
While not automatically punitive, the following behaviors may serve as red flags during risk assessment:
- Engaging in one-sided arbitrage ("brick moving") across platforms—exclusively buying or selling at scale
- Posting sell orders without counterparty restrictions, leading to unintended freezing of buyer accounts
These patterns suggest potential misuse of the C2P infrastructure and warrant closer scrutiny.
Risk Classification Levels
Based on cumulative risk indicators, merchants are classified into one of four risk tiers:
Low Risk
No abnormal activity detected. The merchant complies fully with all platform rules and shows no signs of involvement in risky transactions. No restrictions are applied.
Medium Risk
The merchant has triggered minor risk alerts that were later resolved upon investigation, or committed isolated violations that did not result in account freezes or legal inquiries. These cases are placed under observation. If no further issues arise, the rating may be downgraded to low risk.
High Risk
The merchant has repeatedly triggered risk alerts or violated platform policies, resulting in user account freezes or initial contact from authorities (e.g., police investigation or temporary detention). Such merchants face significant operational restrictions.
Ultra-High Risk
The merchant exhibits persistent high-risk behavior—including repeated high-risk withdrawals or cross-platform arbitrage—and has been formally linked to money laundering activities by law enforcement. This classification results in immediate termination of merchant status and permanent account suspension.
Risk Management and Adjustment Policies
Risk-Based Enforcement Measures
Depending on the current risk rating, OKX may implement the following actions:
- Low Risk: No restrictions imposed.
- Medium Risk: Account flagged for monitoring; placed under observation period. Rating may be reduced if no new risks emerge.
- High Risk: May face secondary authentication requirements, trade limitations, delayed or restricted withdrawals, partial or full account freeze. OKX may also revoke merchant status or deduct from guarantee assets—requiring replenishment if insufficient.
- Ultra-High Risk: Immediate revocation of merchant status, permanent account disablement, and full deduction of guarantee assets if involved in confirmed money laundering cases.
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Dynamic Rating Adjustments
Risk ratings are not static. OKX reviews performance over rolling periods to reflect behavioral changes:
- A medium-risk merchant showing clean records over 60 days may be downgraded to low risk.
- A previously medium-risk merchant exhibiting new violations within the observation window may be upgraded to high or ultra-high risk.
- A high-risk merchant may be downgraded to medium risk after 30 days of compliant activity and successful restoration of required guarantee assets.
- Conversely, recurrence of any violation listed in Section 5 will result in an immediate upgrade to ultra-high risk status.
This adaptive model encourages rehabilitation while deterring repeat offenses.
Final Provisions
- These guidelines take effect immediately upon publication.
- OKX reserves the right to modify these rules at any time without prior notice.
- All interpretations and final decisions regarding this policy rest solely with OKX.
Frequently Asked Questions (FAQ)
Q: How often are merchants re-evaluated for risk level?
A: Risk assessments occur regularly using real-time data. Major reviews happen on a rolling basis, with updates influenced by recent 30-day activity and historical compliance.
Q: Can I appeal my risk rating if I believe it’s incorrect?
A: While there is no formal appeals process, consistent adherence to platform rules over time can lead to automatic downgrades. Contact support for clarification on specific flags.
Q: What happens if my account is downgraded to high risk?
A: You may face trade limits, withdrawal delays, mandatory re-verification, or partial fund freezes. Immediate corrective action improves chances of future downgrade.
Q: Does using the same bank account on other platforms affect my rating?
A: Yes. Failure to isolate funds across exchanges increases traceability risks and may trigger higher scrutiny under anti-money laundering protocols.
Q: Will I be notified before my risk level changes?
A: Yes. OKX typically sends notifications via email or in-app alerts before implementing major restrictions or status changes.
Q: How can I maintain a low-risk status?
A: Follow all C2C rules strictly, avoid off-platform communication, never ignore blacklist warnings, keep funds segregated, and respond promptly to verification requests.
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