OKX Pay Financial Services Guide

Published on 8 Jun 2026
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Non-Cash Payment Facility – Peer-to-Peer Stablecoin Transfer

Issuer: Bano Pty Ltd (ABN 93 643 260 431)

AFSL 536984

Distributor: OKX Australia Pty Ltd (ABN 22 636 269 040)

Corporate Authorised Representative (CAR No. 1318306) of Bano Pty Ltd

Version: 1.0

Date: 9 June 2026

The distribution of this Financial Services Guide by OKX Australia Pty Ltd has been authorised by Bano Pty Ltd (AFSL 536984).

About this Financial Services Guide

This Financial Services Guide (FSG) is designed to help you decide whether to use the financial services we offer. It provides important information about:

  • who we are and how to contact us;

  • the financial services we are authorised to provide;

  • how we (and others) are paid;

  • any relevant associations or conflicts of interest;

  • our complaints handling procedures; and

  • how we protect your privacy.

This FSG should be read together with the OKX Pay Product Disclosure Statement (PDS), which includes the Terms and Conditions (Section B). The PDS contains detailed information about OKX Pay, including its features, risks, fees and charges. You should read the PDS before making a decision about whether to acquire Pay.

A paper copy of this FSG is available free of charge on request. Contact us using the details in Section 2 below.

We will provide this FSG as soon as practicable and, in any event, before we provide a financial service to you. We deliver disclosure electronically and you may request a free paper copy at any time. We keep records of the disclosures provided to you (including timestamps and the version of the PDS and FSG shown at acceptance).

Who we are and how to contact us

Issuer

Entity

Bano Pty Ltd

ABN

93 643 260 431

AFSL

536984

Role

Issuer of OKX Pay (non-cash payment facility)

Address

Level 13, 2 Bulletin Place, Sydney NSW 2000

Email

contact@banosuperapp.com

Distributor

Entity

OKX Australia Pty Ltd

ABN

22 636 269 040

Role

Corporate Authorised Representative (CAR No. 1318306) of Bano Pty Ltd (AFSL 536984). Distributes OKX Pay, facilitates P2P transfers and provides general advice.

Address

C/O William Buck (NSW) Pty Ltd, Level 29, 66 Goulburn Street, Sydney NSW 2000

Email

Contact us via the OKX App. Complaints can be left at: AUComplaints@okx.com

Phone

+61 2 8880 0709 (leave a voicemail if prompted)

Website

www.okx.com/en-au/pay

Key documents

The following documents are available on the OKX website:

How to deal with us

OKX Pay is only available via the OKX App for Australian residents. We may promote OKX Pay across other channels (digital, in-person events, sponsorship and ambassador or KOL activations, and existing-customer communications). We do not engage in unsolicited outbound contact. You can give us instructions about your OKX Pay Wallet (including freezing assets in your Wallet, or disputing transactions) through the OKX App support function, by email to AUComplaints@okx.com (for complaints) or contact@banosuperapp.com (for matters to the Issuer), or by phone on +61 2 8880 0709. You can transfer your stablecoins back to your Simple Portfolio at any time using your Pay Passkey. A restriction requested through OKX may take some time to take effect, and your Pay Wallet (as an on-chain smart contract) cannot be closed but can be left dormant.

1. Our financial services and products

We provide the following financial services in relation to OKX Pay:

  • Bano Pty Ltd (Issuer):

    Deals in OKX Pay by issuing a non-cash payment facility (peer-to-peer stablecoin transfer facility) under which P2P transfers are funded by supported stablecoins (USDC, USDT, USDG) held in your Pay Wallet.

  • OKX Australia Pty Ltd (Distributor):

    Arranges for the issue of OKX Pay, facilitates P2P transfers, and provides general financial product advice in connection with Pay.

Important limitations:

  • We provide general advice only. We do not provide personal financial product advice (see Section 5).

  • OKX Pay is available to Australian residents only.

  • Distribution is online only, via the OKX App.

  • Pay is a peer-to-peer stablecoin transfer facility. It can only be used to send and receive supported stablecoins (USDT, USDG and USDC) to and from other OKX users. It

    cannot

    be used for merchant payments, ATM withdrawals, cash advances, or purchases of goods and services.

  • There are no transaction fees, gas fees, or network fees for P2P transfers within Payor when transferring stablecoins between your Simple Portfolio and your Pay Wallet (see PDS for details).

  • Pay is not subject to the ePayments Code. A bespoke liability framework applies to unauthorised transactions (see PDS).

We provide general financial product advice only. We do not consider your objectives, financial situation or needs. You should consider the PDS and whether Pay is appropriate for you before deciding.

2. Documents we will give you

Before you acquire OKX Pay, we will provide you with:

  • Product Disclosure Statement (PDS): This includes the Terms and Conditions (Section B) and describes Pay’s features, benefits, risks, fees and charges.

  • This Financial Services Guide (FSG): The document you are reading now.

You can also access the following at any time:

  • Transfer limits: There are no transfer limits. Current limits, if any, are displayed in the OKX App and may change for security or regulatory reasons

  • Electronic delivery: We provide documents electronically via the OKX website and App. By applying for Pay, you consent to receiving these documents electronically. A paper copy of any document is available free of charge on request - contact us using the details in Section 2.

You consent to receive disclosure electronically. You may request a free paper copy of any document at any time.

3. How we are paid

Fees and charges

There is no upfront acquisition fee charged to you by Bano or OKX Australia for activating Pay. OKX Pay has a simple fee structure:

  • P2P transfers within Pay are free of charge. There are no transaction fees, gas fees, or network fees for sending or receiving stablecoins to and from other OKX users.

  • No account activation fees, maintenance fees, or closure fees apply at the date of this FSG.

Full fee details are set out in the PDS.

Distributor remuneration

OKX Australia will not receive any distributor fees from Bano. No adviser commissions or trail payments are received by OKX Australia in connection with Pay.

OKX Australia pays Bano for its issuing services under a commercial agreement. The value of these payments is not reasonably ascertainable at the time you receive this FSG.

OKX staff do not receive sales-based commissions in relation to Pay.

We may pay referral fees to third parties for introducing customers; details relevant to you are available on request.

Staff remuneration

OKX Australia staff are salaried employees. They may receive performance bonuses, but these are not linked to the volume or value of Pay activations or transfers.

4. Associations and conflicts of interest

You should be aware of the following associations and relationships:

  • Issuer and Distributor relationship: Bano Pty Ltd issues OKX Pay. OKX Australia Pty Ltd distributes Pay and facilitates P2P transfers as a Corporate Authorised Representative of Bano.

  • OKX Group: OKX Australia is related to broader OKX group entities. OKX Australia also provides exchange and technology services within the OKX ecosystem.

  • No third-party ownership: No third-party product issuer has an ownership interest in Bano Pty Ltd.

How we manage conflicts:

  • Governance arrangements between Bano and OKX Australia (including a Corporate Authorised Representative Agreement with step-in rights);

  • Clear disclosure in the PDS and this FSG of our relationships and remuneration;

  • Product controls, including distribution conditions aligned with the Target Market Determination for Pay as a financial product;

  • All marketing and public communications about Pay require Licensee pre-approval; and

  • Conflicts of interest are monitored by Bano’s compliance function.

Bano is the issuer of Pay. OKX Australia distributes Pay and facilitates PRP transfers on Bano’s behalf. P2P transfers are processed on the X Layer blockchain network. We manage conflicts through governance, approval of all marketing and customer communications by Bano, and staff conduct policies.

5. The kind of advice we provide

General advice only

We provide general financial product advice only. This means any information or advice we give you does not take into account your personal objectives, financial situation or needs.

Before making a decision about whether to acquire OKX Pay, you should:

  • read the PDS (including the Terms and Conditions in Section B);

  • consider whether the product is appropriate for your circumstances;

  • consider the risks described in the PDS (including stablecoin de-peg risk, exchange rate risk, technology risk, counterparty risk and the non-ePayments Code liability framework); and

  • if in doubt, seek independent financial advice.

We do not provide personal advice.

If you need advice that considers your personal circumstances, you should consult a licensed financial adviser.

Because we provide only general financial product advice, we will not provide you with a Statement of Advice. An SOA is a document that records personal advice given to a retail client, which we do not provide in connection with OKX Pay.

6. Your information and privacy

We collect, use and disclose your personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

Key points:

  • We collect personal information necessary to provide financial services, verify your identity (KYC) and comply with AML/CTF laws.

  • Your information may be disclosed to service providers, regulatory bodies, and related entities as set out in our Privacy Policy and the PDS.

  • Some personal information may be disclosed to overseas recipients (including entities within the OKX group) as described in the PDS and Privacy Policy.

  • You have the right to request access to your personal information and to request corrections.

Privacy Policy: Our full Privacy Policy is available at https://www.okx.com/en-au/help/privacy-policy-statement and at https://www.banosuperapp.com/privacy and in the OKX App.

To request a copy of your information or to make a correction request, contact us using the details in Section 2.

7. Complaints and dispute resolution

We are committed to resolving complaints fairly and promptly, in accordance with ASIC Regulatory Guide RG 271.

Step 1: Contact us (Internal Dispute Resolution)

If you have a complaint about OKX Pay or our services, you can contact OKX by:

  • In-App: Submit a complaint via the OKX App support function

  • Email: AUComplaints@okx.com or Issuer via contact@banosuperapp.com

  • Phone: +61 2 8880 0709 (leave a voicemail if prompted)

What happens next:

  • OKX will acknowledge your complaint promptly.

  • OKX aim to resolve most complaints within 30 calendar days. If we need more time, we will explain why and keep you informed.

  • You will receive a written IDR response setting out our decision, the reasons for it, and your right to escalate to AFCA if you are not satisfied. You can also raise your concerns with the Issuer. Our IDR process is free of charge.

Step 2: External Dispute Resolution (AFCA)

If you are not satisfied with our response (or if we have not responded within the applicable timeframe), you may escalate your complaint to the Australian Financial Complaints Authority (AFCA):

Organisation

Australian Financial Complaints Authority (AFCA)

Website

www.afca.org.au

Email

info@afca.org.au

Phone

1800 931 678 (free call)

Mail

GPO Box 3, Melbourne VIC 3001

AFCA provides a free, independent dispute resolution service. Time limits may apply to complaints to AFCA, so you should act promptly.

8. Compensation arrangements

Bano Pty Ltd maintains professional indemnity (PI) insurance that satisfies the requirements of section 912B of the Corporations Act and ASIC Regulatory Guide RG 126.

This insurance covers claims relating to the conduct of Bano and its representatives (including OKX Australia as a Corporate Authorised Representative) in providing financial services, including where a representative has ceased to act for Bano.

We believe this insurance is adequate to compensate retail clients for loss or damage suffered as a result of breaches of the financial services laws by Bano or its representatives.

9. Keeping your records and getting a copy

We maintain records of all financial services provided to you in connection with OKX Pay, in accordance with our legal obligations.

You may request a copy of any document we have provided to you, or any record relating to the financial services we have provided. To make a request, contact us using the details in Section 2.

We will provide the requested information within a reasonable time, subject to applicable law.

10. Changes to this FSG

We may update this FSG from time to time to reflect changes in our business, products, fees or the law. The current version is always available:

If we make a material change, we will notify you in writing (which may include electronic notification via the App or email).

Any information we provide is general in nature and does not take account of your objectives, financial situation or needs.

Quick Reference

Key documents and links: