Mr. Kennedy made his fortune during Prohibition (1920-1933, the period when the sale, production, and distribution of alcoholic beverages were banned in the US) by operating illegal liquor businesses, and after Prohibition ended, he became the first chairman of the US Securities and Exchange Commission (SEC). 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 realm is OKX's transformation from a regulatory 'orphan' to a potential IPO candidate.
According to a report on Sunday, the cryptocurrency exchange OKX, based in Seychelles, is considering going public in the US, just four months after agreeing to pay $505 million in fines to the US government for operating without permission.
In February 2025, this second-largest centralized exchange (CEX) acknowledged handling over $1 trillion in transactions from unlicensed US users while intentionally violating anti-money laundering laws and agreed to pay over $500 million in hefty fines. Now, it wants to invite US investors to buy shares in its company.
Nothing signifies 'we have turned a corner' more than voluntarily accepting the quarterly earnings call, disclosures, and filings required by the US Securities and Exchange Commission.
Can a crypto company succeed on Wall Street? Circle recently proved this is possible. In recent weeks, this USDC stablecoin issuer has shown that as long as they take a compliant route, investors will enthusiastically throw money at crypto companies.
Circle's stock price soared from $31 to nearly $249 in just weeks, creating billionaires in an instant and establishing a new template for crypto IPOs. Even Coinbase, the largest crypto exchange in the US, has seen its stock rise 40% in the past ten days, nearing a four-year high since going public four years ago.
Can OKX achieve similar success in the stock market?
Well, Circle had an impeccable regulatory record when it went public. They have been attending congressional hearings in suits and releasing transparency reports for years. Meanwhile, OKX recently admitted to facilitating $5 billion in suspicious transactions and criminal proceeds and had to solemnly promise not to repeat the mistakes.
01
Different CEX, different stories
To understand OKX's IPO prospects, let's look at Coinbase, the only crypto exchange that has successfully entered the public market. OKX and Coinbase earn profits in the same way: by charging fees every time someone trades cryptocurrencies.
When the crypto market is crazy, like during a bull market, they profit immensely. Both platforms offer foundational crypto services: spot trading, staking, and custody. However, their business construction methods are radically different.
Coinbase chose a compliance-first approach. They hired former regulators, established institutional-grade systems, and spent years preparing for a public listing on Wall Street. This strategy paid off, as they went public in April 2021, despite the volatility in the crypto market, and now have a market cap exceeding $90 billion.
In 2024, Coinbase's average monthly spot trading volume was $92 billion, primarily from US customers who paid a premium for regulatory certainty. This is the turtle strategy: slow and steady, focus on doing well in one market.
OKX adopted a rabbit strategy: act quickly, capture global market share, and consider regulatory issues later. From a business standpoint, this approach has been 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 dominance in derivatives trading (global market share of 19.4%), OKX's crypto trading volume far exceeds that of Coinbase.
OKX handles about $2 billion in spot trading volume and over $25 billion in derivatives trading per day, while Coinbase handles $1.86 billion and $3.85 billion, respectively.
But speed comes with costs. Coinbase builds relationships with US regulators, while OKX actively attracts US customers despite being banned from operating in the US. Their attitude seems to be 'forgive me, not ask for permission,' which works until they need to seek forgiveness from the Department of Justice.
There is one question: the income of crypto exchanges entirely depends on people's continued enthusiasm for trading cryptocurrencies. When the market is hot, exchanges profit immensely. When the market cools, revenue can plummet overnight.
For instance, in June 2024, the exchange's spot and derivatives trading volume collectively fell over 50% from a peak of approximately $9 trillion in March.
@CCData Exchange Commentary
OKX's $500 million settlement agreement has become a mandatory lesson on how the US financial markets operate. They seem to have learned from their expensive mistakes. They hired former Barclays executive Roshan Robert as CEO for the US, opened compliance offices in San Jose, New York, and San Francisco, with 500 employees, and began discussing building a 'category-defining super app,' a corporate language indicating serious reform efforts.
Interestingly, whether investors will believe this redemption story.
02
Valuation game
Based on trading volume, OKX's valuation should theoretically be comparable to or even higher than Coinbase.
Coinbase has a market cap of over $90 billion, with an average monthly trading volume of $92 billion, equivalent to a one-time monthly trading volume. OKX's monthly trading volume is $98.19 billion, 6.7% higher than Coinbase. By the same multiple, OKX's market cap should be $85.4 billion.
But valuation is not just math; it 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 learned in Thailand, where regulators 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 volumes, they might have grounds for a premium valuation.
Realistic range: $70 billion to $90 billion, depending on how much investors value growth versus governance.
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Advantages
OKX’s investment appeal is based on several competitive advantages lacking in Coinbase.
Global scale: Coinbase focuses mainly on the US, while OKX serves markets with surging 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 complex traders. Coinbase recently announced the launch of perpetual futures, meaning OKX will face more competition from established and regulated players.
Volume leader: Despite being a private company with recent regulatory troubles, OKX's spot trading volume still exceeds that of the publicly listed Coinbase.
Coinbase also has advantages—clean regulatory records and relationships with institutional investors who prefer predictable compliance costs over a globally growing story fraught with regulatory complexities.
04
Potential issues
OKX carries significant risks, which differ from typical IPO concerns.
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 cut substantial revenue overnight.
Market cyclicality: Revenue for crypto exchanges fluctuates with trading activity. When the crypto market cools, exchange revenue can collapse.
Reputation risk: Despite reaching a settlement, OKX could still suffer severe reputational damage from a regulatory scandal. Crypto exchanges are inherently risky businesses; a technical failure or security breach could destroy customer confidence overnight.
05
Summary
OKX's potential IPO could be an interesting test to see if the public market will overlook the exchange's problematic background.
Peeling away the regulatory drama, OKX actually has advantages over the only crypto exchange that has successfully gone public, Coinbase. They dominate derivatives trading and have a global customer base.
Whether OKX has learned from its mistakes (expensive lessons tend to stick) may not be important. What matters is whether public market investors are willing to pay growth multiples for a company operating in dozens of unpredictable regulatory environments. Coinbase has built a moat of compliance reputation in the US; OKX has built a global trading empire and is now restructuring around compliance.
Both strategies could work, but they attract entirely different investors. Coinbase is a safe choice for institutions seeking regulated crypto exposure. OKX may attract investors who believe the future of crypto lies in global adoption and complex trading products.
Circle proved that investors will throw money at a clean crypto story. OKX is betting that investors will do the same for them, even with their complicated past.
Whether OKX's reform image can resonate with the public market will tell us a lot about how investors weigh growth versus governance in the crypto space.
