Will OKX go public in the US? Can it replicate Circle's miracle?

Mr. Kennedy made his fortune by running a bootlegging operation during Prohibition (the period from 1920 to 1933 when the sale, production, and distribution of alcoholic beverages was banned in the United States) and became the first chairman of the U.S. Securities and Exchange Commission (SEC) after Prohibition ended. It is said that President Roosevelt remarked on this appointment, "Let the thief catch the thief." Kennedy then zealously cleaned up Wall Street, establishing rules that still govern the securities market today.

A similar example in the modern cryptocurrency space is OKX's transformation from a regulatory "orphan" to a potential IPO candidate.

According to a report on Sunday, the Seychelles-based cryptocurrency exchange OKX is considering going public in the United States, just four months after agreeing to pay a $505 million fine to the U.S. government for operating without a license.

In February 2025, this global second-largest centralized exchange (CEX) admitted to processing over $1 trillion in unauthorized trades by U.S. users while deliberately violating anti-money laundering laws and agreed to pay a hefty fine of over $500 million. Now, it wants to invite U.S. investors to purchase shares in its company.

Nothing indicates "we have turned the page" more than voluntarily accepting the quarterly earnings call, disclosures, and filings required by the SEC.

Can a crypto company succeed on Wall Street? Circle has recently proven that it is possible. In the past few weeks, this USDC stablecoin issuer has shown that as long as it follows a compliance path, investors will eagerly throw money at crypto companies.

The stock price of Circle skyrocketed from $31 to nearly $249 within a few weeks, instantly creating billionaires and setting a new template for crypto IPOs. Even Coinbase, the largest crypto exchange in the U.S., which has been public for four years, saw its stock price rise by 40% in nearly 10 days, approaching a four-year high.

Can OKX achieve similar success in the stock market?

Well, Circle had an impeccable regulatory record when it went public. They have attended congressional hearings in suits for years and released transparency reports. In contrast, OKX recently admitted to facilitating $5 billion in suspicious transactions and criminal proceeds and had to solemnly promise not to repeat the mistakes.

Different CEX, Different Stories

To understand the IPO prospects of OKX, let's take a look at Coinbase, which is the only cryptocurrency exchange that has successfully entered the public market. OKX and Coinbase have the same revenue model: they charge fees every time someone trades cryptocurrency.

When the crypto market is crazy, such as during a bull market, they make a fortune. Both platforms offer basic crypto services: spot trading, staking, and custody services. However, their business construction methods are completely different.

Coinbase chose a compliance-first approach. They hired former regulators, built institutional-grade systems, and spent years preparing to go public on Wall Street. This strategy paid off as they went public in April 2021, despite the volatile crypto market, and now have a market cap of over $90 billion.

In 2024, Coinbase's average monthly spot trading volume is $92 billion, primarily from U.S. customers who pay a premium for regulatory certainty. This is the turtle strategy: slow and steady, focusing on doing well in one market.

OKX has chosen the rabbit strategy: act quickly, seize global market share, and consider regulatory issues later. From a business perspective, this approach is very successful.

In 2024, OKX's average monthly spot trading volume was $98.19 billion, 6.7% higher than Coinbase, serving 50 million users across more than 160 countries. Coupled with their dominant position in derivative trading (global market share of 19.4%), the cryptocurrency trading volume handled by OKX far exceeds that of Coinbase.

OKX processes approximately $2 billion in spot trading volume and over $25 billion in derivatives trading volume daily, while Coinbase has $1.86 billion and $3.85 billion respectively.

But speed comes with a cost. Coinbase has established relationships with U.S. regulators, while OKX actively attracts American customers despite being banned from operating in the U.S. Their attitude seems to be "ask for forgiveness, not permission," which was effective even before needing to seek forgiveness from the Department of Justice.

There is a problem: the revenue of cryptocurrency exchanges completely depends on people's continued enthusiastic trading of cryptocurrencies. When the market is hot, exchanges make a fortune. When the market cools down, revenues can drop significantly overnight.

For example, in June 2024, the trading volume of spot and derivatives on the exchange collectively decreased by more than 50% from the peak of about $90 trillion in March.

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The $500 million settlement agreement with OKX has become a mandatory course on the operation of the U.S. financial markets. They seem to have learned from their costly mistakes. They hired former Barclays executive Roshan Robert as the U.S. CEO, opened compliance offices in San Jose, New York, and San Francisco, with 500 employees, and began discussing the creation of a "category-defining super app," a corporate language that indicates serious reform efforts.

Interestingly, whether investors will believe this redemption story.

Valuation Game

Based on trading volume, OKX's valuation should theoretically be comparable to, or even higher than, Coinbase.

Coinbase's market capitalization exceeds $90 billion, with a monthly trading volume averaging $92 billion, equivalent to a single month's trading volume. OKX's monthly trading volume is $98.19 billion, which is 6.7% higher than Coinbase. Calculating by the same multiplier, OKX's market capitalization should be $85.4 billion.

But valuation is not just mathematics; it also involves perception and risk.

OKX's regulatory burden may require a discount. Their international business means profits depend on a rapidly changing regulatory environment, as they have learned in Thailand, where Thai regulators have just banned them and several other exchanges.

Applying a 20% "regulatory risk discount," OKX's valuation could be $68.7 billion. However, considering their global influence, dominance in derivatives, and higher trading volume, they may have reasons to achieve a premium valuation.

Realistic range: $70 billion to $90 billion, depending on investors' emphasis on growth and governance.

Advantages

The investment appeal of OKX is based on several competitive advantages that Coinbase lacks.

• Global Scale: Coinbase primarily focuses on the United States, while OKX serves the markets experiencing a surge in crypto adoption: Asia, Latin America, and parts of Europe with underdeveloped traditional banking systems.
• Derivatives Dominance: OKX controls 19.4% of the global crypto derivatives market, while Coinbase's derivatives offerings are negligible. Derivatives trading generates higher fees and attracts more sophisticated traders. Coinbase recently announced the launch of perpetual futures, which means OKX will face more competition from established and regulated players.
• Leading in trading volume: Despite being a private company with recent regulatory troubles, OKX's spot trading volume still exceeds that of the listed Coinbase.

Coinbase also has advantages - a clean regulatory record and relationships with institutional investors, who prefer predictable compliance costs over a global growth story filled with regulatory complexities.

Possible Issues

The risks of OKX are significant and differ from the typical concerns associated with an IPO.

• Regulatory uncertainty: OKX operates in dozens of jurisdictions, where rules change rapidly. The ban in Thailand is just the latest example. Any major market could see a significant reduction in revenue overnight.
• Market Cyclicality: The revenue of cryptocurrency exchanges fluctuates with trading activity. When the crypto market cools down, exchange revenues may collapse.
• Reputational risk: Despite reaching a settlement, OKX may still suffer severe reputational damage due to a regulatory scandal. Cryptocurrency exchanges are inherently risky businesses, and technical failures or security breaches can destroy customer confidence overnight.

Summary

The potential IPO of OKX could be an interesting test to see if the public market will overlook the exchange's problematic background.

Peeling away the regulatory drama, OKX is actually more advantageous than the only successfully listed cryptocurrency exchange, Coinbase. They dominate derivatives trading and have a global customer base.

Whether OKX learns from its mistakes (expensive lessons are often memorable) may not be important. What matters is whether public market investors are willing to pay a growth multiple for a company operating in dozens of unpredictable regulatory environments. Coinbase has built a moat of compliance reputation in the U.S.; OKX has built a global trading empire and is now undergoing a transformation around compliance.

Both strategies could work, but they attract completely different investors. Coinbase is a safe choice for institutions seeking regulated exposure to crypto. OKX may attract investors who believe that the future of crypto lies in global adoption and complex trading products.

Circle has proven that investors will throw money at clean crypto narratives. OKX is betting that investors will do the same for them, even if they have a complicated past.

Whether OKX's reform image can resonate with the public market will tell us a lot about how investors weigh growth against governance in the crypto space.