Xu Mingxing's ultimate test: Is OKX going public in the U.S.?

Author: Luke, Mars Finance

Is OKX Going Public in the U.S.?

On June 23, 2025, when Yueqi Yang, a crypto reporter from The Information, revealed that global crypto giant OKX is considering an IPO in the U.S., the nerves of the entire market were instantly ignited. This news struck like a lightning bolt, shattering the calm of the crypto world. The market's reaction was almost instinctive—OKB, the platform token closely tied to the OKX ecosystem, saw its price violently surge over 15% within an hour, breaking through the psychological barrier of $55.

This surge driven by rumors reveals a logic far deeper than the candlestick charts. It clearly indicates that, in the eyes of investors, the valuation of OKX has formed an inseparable symbiotic relationship with the fate of its issued crypto asset OKB, which has a market cap exceeding $3 billion. A company seeking to list on the NYSE or NASDAQ should be valued by traditional Wall Street metrics such as price-to-earnings ratios and revenue growth. However, the market's enthusiasm declares that in this capital drama, the protagonist is not only the company itself but also the token empire it has created.

This is precisely the unique dilemma and greatest gamble facing OKX. When a company attempts to embed itself in the world's most mature and stringent capital market system, its inherent "crypto original sin" gene—will it be a ticket to the future or a shackle that binds it? Especially for OKX, which has just struggled to emerge from a regulatory storm, knocking on Wall Street's door now is not only the ultimate test of its determination to transform but also signifies that the entire crypto industry stands at a crossroads from the "Wild West" to the financial hall.

The Road to Return Under Shadows

Why has OKX chosen this moment to put the IPO on the agenda?

Not long ago, the operating entity of OKX reached a stunning settlement with the U.S. Department of Justice (DOJ). It admitted to "willfully violating anti-money laundering (AML) laws" and "operating an unlicensed money transmission business" for seven years, paying a hefty price of over $500 million. The investigation documents painted a shocking picture: OKX's platform had been used to process massive suspicious transactions, and its employees even openly guided U.S. users to evade the platform's KYC processes.

This costly settlement could have marked the end of OKX's story in the U.S., just like its competitor Binance, which was forced to completely exit the U.S. market after paying an even more staggering fine. However, OKX chose a more difficult path—rebirth through fire. In April 2025, just two months after paying the fine, OKX boldly announced its return to the U.S.

This move is less about commercial expansion and more about a carefully orchestrated "reputation repair campaign." OKX has employed nearly all textbook crisis public relations tactics: appointing former Barclays Bank director Roshan Robert, who has a deep traditional finance background, as CEO of U.S. operations; establishing a new regional headquarters in the heart of Silicon Valley, San Jose; and its management team, including the usually low-profile founder Xu Mingxing, has made unprecedented commitments to compliance, striving to become the "gold standard for global compliance."

From this perspective, OKX's return strategy is interconnected, and its ultimate goal is clear. The IPO is not merely for raising funds but is the final chapter of this "reputation repair campaign." If it can successfully go public, it would mean passing the joint "big test" of the SEC, top investment banks, and public auditors, effectively obtaining an irrefutable "health certificate" from the very system it once scorned.

Precisely Betting on the Future of Regulation

If the internal compliance reforms at OKX are the "internal driving force" for considering an IPO, then the subtle changes in the macro regulatory environment in the U.S. provide a crucial "external pull" for this gamble. OKX's decision to launch its IPO plan in 2025 is not a spur-of-the-moment decision but a precise prediction of policy direction.

The most significant change comes from the political level. In 2025, after the new U.S. government took office, the attitude towards the cryptocurrency industry has noticeably softened, shifting from a previously hardline "enforcement-first" strategy to creating a relatively relaxed external environment for the industry. However, for a complex platform like OKX, which focuses on financial derivatives trading, merely softening the enforcement attitude is not enough; it requires fundamental changes at the legal framework level.

This is precisely the core issue that the "21st Century Financial Innovation and Technology Act" (FIT21) and its updated version—the 2025 "Digital Asset Market Clear Act" (CLARITY Act)—aim to address. The CLARITY Act aims to establish a clear and comprehensive regulatory framework for the chaotic U.S. digital asset market, with the core focus on clearly delineating the jurisdiction of the SEC and the Commodity Futures Trading Commission (CFTC). According to the draft of the act, "digital commodities" will primarily be regulated by the CFTC. This delineation is akin to a timely rain for OKX, which excels in derivatives trading.

Connecting these clues, a clear picture emerges. OKX's IPO plan is not a passive response to the existing legal environment but a forward-looking strategic layout. It bets that the CLARITY Act, a law crucial to the industry, will ultimately be passed. Considering the lengthy and complex IPO process, OKX has chosen to start preparations now to ensure that at the moment legislation is completed, it can be among the first compliant exchanges to cross the finish line.

Standing on the Shoulders of Giants

Of course, OKX is not the first crypto company attempting to knock on Wall Street's door. Before it, the IPO journeys of Coinbase and Circle have already provided rich experiences and profound lessons for later entrants.

As an industry pioneer, Coinbase's direct listing in 2021 exposed numerous issues: the dual-class share structure raised concerns about corporate governance, the heavy reliance on retail trading fees created a single business model, and the stock price's severe volatility tied to the crypto market all became constraints on its valuation ceiling.

In contrast, the traditional IPO of Circle, the issuer of the stablecoin USDC, in June 2025 can be considered a model. Circle's success hinged on its clear compliance narrative—positioning itself as the issuer of a "regulated digital dollar." Strong on-chain data intuitively demonstrated the immense utility and market demand for its products, providing solid support for a high valuation. As pointed out in Bybit's analysis report, traditional investment banks "seriously underestimated Circle's valuation," indicating that Wall Street's traditional valuation models have begun to falter in understanding crypto-native enterprises.

Placing OKX between these two, its uniqueness becomes apparent. Its business model is more diversified than Coinbase's, especially in the high-margin derivatives sector; however, its regulatory history is far more complex than that of Coinbase and Circle. The most core difference lies in the inseparable deep binding relationship with its native token OKB, which will be the ultimate "big test" it faces on Wall Street.

The Trade-off of Value and the Ultimate Test

Overall, OKX's path to IPO is a difficult balancing act across three dimensions: compliance, token economics, and the founder's history.

First, its core advantage lies in its strong global market position and product depth. As one of the top giants in global trading volume, OKX boasts over 50 million users and high market liquidity. Its true moat lies in the derivatives market—offering futures contracts with leverage up to 100 times and complex trading tools, making it the preferred platform for professional traders, which also brings more stable revenue sources. Estimates suggest that OKX's annual revenue ranges between $1 billion and $10 billion.

However, its greatest advantage—the deeply integrated OKB token ecosystem—also poses its biggest challenge. OKB is not just a platform token; it has permeated every corner of the OKX ecosystem, used for fee discounts, governance, and staking. More importantly, OKX has committed to using 30% of its spot trading fee revenue to regularly repurchase and destroy OKB from the secondary market, creating deflation to enhance token value.

This creates an unprecedented valuation dilemma in the context of the IPO. How can a listed company explain to its shareholders that its business model is so deeply tied to an independent, highly speculative crypto asset? When the company uses income that could be distributed as dividends to support the price of a token in the public market, how should this expenditure be accounted for? This creates potential conflicts of interest between shareholders of the listed company and holders of the OKB token. According to SEC guidance, OKX's "repurchase and destruction" plan may likely lead to its token being classified as a security.

Finally, no matter how hard OKX tries to repair its image, its indelible history will remain a Damocles sword hanging over its head. That $500 million settlement agreement, along with the controversies surrounding founder Xu Mingxing, will be scrutinized repeatedly in the prospectus and due diligence, becoming a significant detractor for a public market seeking to clear the leadership background.

When Crypto Giants Embrace Wall Street

From being fined exorbitantly for serious violations to now considering a listing on Wall Street, OKX's journey is a microcosm of the entire crypto industry's development trajectory. It marks the end of an era of wild growth and the beginning of another seeking order.

This IPO will be the ultimate test of OKX's self-renewal. If successful, OKX will not only achieve its redemption but also provide a compliance path for other global exchanges to follow. If it fails, it will serve as a harsh warning to the entire industry: the bridge from the freedom and unruliness of the crypto world to the stringent rules of Wall Street is still being painstakingly constructed.

Regardless of the outcome, OKX's charge towards Wall Street sends a clear signal: the era of the crypto exchange's wild growth in the "Wild West" is coming to an end. The future holds only two paths: either proactively enter the regulatory framework like OKX, exchanging transparency for survival space; or face the risk of being marginalized or even expelled, as seen with its competitors in the U.S. market. OKX's "big test" on Wall Street is destined to become a memorable moment in the history of cryptocurrency development.