Dex Aggregator and Intent conflict of interest policies

Gepubliceerd op 30 apr 2026

Published on 30 April 2026

This OKX Web3 DEX Aggregator and Intent Conflict of Interest Policy (this "Policy") is published by OKX Technology Inc. ("we", "us", "our" or "OKX") to disclose how we identify, manage, and mitigate potential conflicts of interest arising from the operation of the OKX Web3 DEX Aggregator (the "Aggregator") and OKX Intent (collectively, the "Services"), including conflicts of interest associated with default transaction parameters. This Policy supplements the OKX Web3 Ecosystem Terms of Service and the OKX Web3 DEX Interface User Agreement. All capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Service.

By using the Services, you confirm that you have read, understood, and accepted this Policy. If you do not agree to be bound by this Policy, please do not access or use the Services.

1. Overview

1.1 OKX recognizes that potential conflicts of interest may arise in the design of routing algorithms, the configuration of default transaction parameters, the presentation of providers in the User Interface, and the operation of solver networks. This Policy sets out the principles, procedures, and controls we have implemented to identify, manage, and mitigate such conflicts.

1.2 This Policy applies to:

  • The OKX Web3 DEX Aggregator, which sources liquidity across multiple DEXs and computes transaction routes for swap orders;

  • OKX Intent, which operates a parallel batch auction mechanism through which allowlisted Solvers compete to provide execution for User-signed intent orders; and

  • Any associated default transaction parameters and slippage settings, including any conflicts of interest or risks arising from such parameters.

2. Routing and Provider Display: Conflict of Interest Disclosures

2.1 Routing Neutrality (within the OKX Aggregator). When the OKX Web3 DEX Aggregator computes its own transaction route, the routing algorithm is designed for the sole purpose of identifying the most competitive execution outcome based on objective, quantifiable on-chain data. The algorithm evaluates available liquidity sources solely on the basis of price, liquidity depth, gas cost, slippage impact, and execution reliability.

2.2 No Preferential Routing within the Aggregator's Algorithm. Within the OKX Aggregator's routing algorithm, OKX does not preferentially route Users' orders to:

  • Any liquidity source, smart contract, or protocol owned, operated, or controlled by OKX or any of its affiliates;

  • Any project, protocol, or token in which OKX Ventures or any other affiliated investment vehicle of OKX holds an investment, equity, or token interest;

  • Any liquidity source, bridge, or protocol deployed on, or affiliated with, X Layer or any other blockchain network operated by OKX or its affiliates; or

  • Any third-party liquidity source on the basis of any commercial relationship, marketing arrangement, or revenue-sharing agreement.

2.3 Equal Treatment of Liquidity Sources within the Aggregator. All liquidity sources integrated into the OKX Aggregator, whether operated by OKX-affiliated entities or by independent third parties, are subject to the same objective evaluation criteria within the routing algorithm.

2.4 User Interface Display: Disclosure of Potential Conflict and Sorting Tools. The OKX Web3 DEX Interface displays both the route generated by the OKX Aggregator and alternative transaction routes generated by integrated third-party DEX aggregators. Users acknowledge and accept that the OKX Aggregator's route may be presented as the default selection or may be visually emphasized in the User Interface, including in cases where the OKX Aggregator's quoted received amount is not the highest among the available providers. This presentation reflects OKX's role as the operator of the OKX Web3 DEX Interface and constitutes a potential conflict of interest, which OKX expressly discloses through this Policy. Such presentation does not constitute a representation that the OKX Aggregator's route is, in any specific transaction, the most favourable available option.

To enable Users to evaluate all available options on an objective basis, the OKX Web3 DEX Interface displays all available execution routes ranked by estimated received value after deduction of network fees, using a consistent methodology across all providers. Users retain the unrestricted right to review all displayed alternatives and select any third-party aggregator route before signing a transaction. The default presentation order does not reflect any endorsement or ranking by OKX. OKX does not apply any label, badge, or other commentary to any execution route characterizing it as the best, most reliable, or otherwise superior option.

2.5 Mitigation: User's Right to Compare and Select. To mitigate the potential conflict disclosed in Clause 2.4, all available providers and aggregators are made visible to the User, together with the estimated received value to the User after deduction of network fees for each option. The estimated received value displayed for each provider is calculated using the same methodology, enabling Users to make a direct, like-for-like comparison. The User has the unrestricted right, at the User's sole discretion, to:

  • review the estimated received value of each available provider before signing any transaction;

  • select any third-party provider in preference to the OKX Aggregator, regardless of which option is presented as the default; and

  • decline to transact through any provider.

OKX does not suppress, hide, downrank, or otherwise restrict access to competing third-party routes.

2.6 Liquidity Source Selection Menu. Where the OKX Web3 DEX Interface presents Users with a selectable menu of integrated liquidity sources (DEXs) for the purpose of customizing their transaction route, such liquidity sources are listed in alphabetical order. The ordering of liquidity sources within this menu does not reflect any preference, endorsement, ranking, or commercial arrangement on the part of OKX, and all integrated liquidity sources are presented on an equal footing.

3. Default Transaction Parameters: Conflicts of Interest and Risks

3.1 Determination of Parameters. Default transaction parameters, including but not limited to slippage tolerance, transaction deadline, gas estimation, and MEV protection settings, are determined based on prevailing on-chain market conditions, observed price volatility, historical execution data, and industry-standard practices. These parameters are calibrated to optimize the likelihood of successful settlement at a fair price, and are not set with the purpose of advantaging OKX, any OKX affiliate, or any specific liquidity source.

3.2 Dynamic Slippage Adjustment and MEV Protection. Default slippage tolerance is dynamically adjusted based on market conditions, including the volatility of the relevant token pair, the depth of available liquidity, and recent price movements. Tokens exhibiting higher volatility or lower liquidity may be assigned a higher default slippage tolerance to improve execution success rates, while tokens with deep, stable liquidity may be assigned a lower default. The default slippage tolerance presented to the User reflects an estimate intended to balance execution reliability against price protection, and does not reflect any commercial preference of OKX.MEV protection is enabled by default for all transactions processed through the Services. This protection is designed to reduce the risk of value extraction by third parties through front-running, sandwich attacks, or similar on-chain exploitation techniques. Users may modify MEV protection settings at their sole discretion; however, OKX recommends retaining the default setting, particularly for transactions involving tokens with higher slippage tolerance.

3.3 No Conflict-Driven Parameter Setting. OKX does not configure default transaction parameters in a manner intended to:

  • direct order flow towards any OKX-affiliated liquidity source;

  • enlarge any spread, fee, or surplus accruing to OKX or its affiliates; or

  • disadvantage any third-party provider relative to the OKX Aggregator.

3.4 User Override. Users may, at their sole discretion, modify default transaction parameters before signing and submitting a transaction. The User remains solely responsible for any parameter modifications and the resulting execution outcome.

3.5 Parameter Risks. Users acknowledge that default transaction parameters carry inherent risks, including but not limited to: (a) the risk that high slippage tolerance may permit execution at a less favourable price than the displayed quote; (b) the risk that low slippage tolerance may cause transactions to fail and gas fees to be lost; and (c) the risk that market conditions may change between quote generation and on-chain execution. OKX does not guarantee that default parameters will produce optimal results in all circumstances.

4. OKX Intent Solver Network: Conflict of Interest Controls

4.1 Anti-Manipulation Controls. OKX has implemented the following controls to prevent Solver-side conflicts of interest and market manipulation:

  • Non-Winner Settlement Restriction: Only the auction-winning Solver is permitted to submit on-chain settlement. Any non-winner Solver submitting on-chain settlement is subject to indefinite disablement pending satisfactory explanation in accordance with the Solver Disablement and Appeal Mechanism below.

  • Malicious Quoting Detection: Solvers providing quotes that consistently fail to execute are subject to indefinite disablement and manual review pending satisfactory explanation in accordance with the Solver Disablement and Appeal Mechanism below.

  • EBBO (External Best Bid and Offer) Compliance: Solver execution prices are continuously benchmarked against an OKX-maintained baseline solver, which sources reference prices from major automated market makers ("AMMs"). Solvers whose execution falls below baseline must compensate Users for the price difference, if they fail to do so, they will be disabled for 24 hours.

  • Anti-Overbidding Controls: Solvers submitting inflated solution scores that do not match actual on-chain settlement outcomes are subject to disablement based on a 100-settlement evaluation window.

  • Score Inflation Prohibition: Solvers found to inflate scores via fake tokens, wash trading, or similar manipulation are removed from the allowlist, unless the Solver provides evidence demonstrating that the relevant conduct was not attributable to it.

  • Fairness Constraint on Multi-Pair Solutions: The Winner Selection mechanism filters out "unfair" solutions in which any token pair within a multi-pair solution performs worse than the best available single-pair baseline, preventing Solvers from sacrificing one User's outcome to inflate the overall solution score.

  • Solver Disablement and Appeal Mechanism. OKX applies two categories of enforcement action: indefinite disablement and removal from the allowlist. Indefinite disablement applies to Non-Winner Settlement Restriction violations and Malicious Quoting Detection violations. A disablement will remain in place until the affected Solver provides a satisfactory explanation to OKX. Where OKX determines that the conduct was caused by a technical bug or other non-malicious reason and was not intended to interfere with the auction process, the disablement will be lifted. Removal from the allowlist applies to Score Inflation violations, subject to the Solver's right to provide evidence demonstrating that the relevant conduct was not attributable to it. OKX will provide written notification of the basis for any enforcement action within 10 business days, or as otherwise required by OKX's legal and compliance obligations.

4.2 Baseline Solver Independence. The EBBO baseline solver is operated and maintained by OKX solely for the purpose of providing an objective reference price. The baseline solver does not compete for auction wins, does not receive Solver fees, and is not eligible to settle Users' orders.

4.3 Winner Selection Neutrality. The selection of winning solutions within each OKX Intent auction round is conducted in strict accordance with the Winner Selection and Fairness Rules, which apply uniformly to all Solvers without favouritism. The mechanism operates as follows:

  • (a) Score Computation. Each solution submitted by a Solver is scored using a uniform formula, where the Solution Score (USD) equals the sum of all order scores within the solution, with each Order Score calculated as the sum of surplus, platform fee, commission fee, and parent commission fee, converted to USD.

  • (b) Baseline Scores. For each DirectedTokenPair (i.e., a specific fromToken → toToken direction), a Baseline Score is computed as the highest score among all single-pair solutions submitted for that pair. This baseline serves as an objective fairness benchmark.

  • (c) Fairness Filtering. Multi-pair solutions are subject to a fairness check whereby each token pair within the solution must score no less than that pair's Baseline Score. Any multi-pair solution failing this check is marked as "Unfair" and filtered out, regardless of which Solver submitted it.

  • (d) Winner Selection. Winners are selected from the pool of fair solutions through a deterministic greedy algorithm that iterates candidates in descending order of total Solution Score, subject to a token-pair non-conflict rule.

4.4 Disclosure of OKX-Affiliated Solver Participation. OKX expressly discloses that one or more Solvers operated by, or affiliated with, OKX or its affiliates participate in the OKX Intent auction system as competing Solvers (each, an "Affiliated Solver"). This participation constitutes a potential conflict of interest, which OKX manages through the controls set out in this Clause 4. Specifically:

  • (a) Same Rules Apply. Each Affiliated Solver is subject to the identical onboarding requirements, performance standards, anti-manipulation controls, fairness rules, and disablement procedures as every other Solver. Affiliated Solvers receive no preferential treatment in the scoring of solutions, the application of Baseline Scores, the fairness filtering process, or the winner selection algorithm.

  • (b) No Information Advantage. Affiliated Solvers do not have access to non-public auction data, competing Solvers' submitted solutions, or any other information that is not equally available to all participating Solvers through the published API specification.

  • (c) Same Disablement Exposure. Affiliated Solvers are subject to the same disablement, removal, and compensation obligations described in Clause 4.1, and may be disabled or removed from the allowlist on the same terms as any other Solver.

4.5 Competition Transparency: Public Auction Data. To enable independent verification of the equal-treatment principle disclosed in Clause 4.4, OKX publishes auction-level competition data through a public API: competition-info details: https://web3.okx.com/onchainos/dev-docs/trade/dex-api-introduction

The endpoint allows any User or third party to retrieve, for any settled auction round, the following information:

  • the auction identifier, the auction's bidding window (start and deadline blocks), and the on-chain settlement transaction hash;

  • the reference prices of the tokens involved in the auction;

  • the full list of Solvers that submitted solutions, identified by their on-chain addresses;

  • for each submitted solution, its Solution Score and ranking, which together determine Winner Selection;

  • for each solution, the clearing prices and order-level execution amounts (fromTokenAmount and toTokenAmount) it would have produced;

  • which solution was ultimately selected as the winner; and

  • whether any solution was filtered out under the Fairness Rules.

This auction data, including data relating to Affiliated Solvers, is made available on equal terms to all users and observers, enabling the public to independently audit the application of the Winner Selection and Fairness Rules.

4.6 Equal Application to All Solvers. The Winner Selection and Fairness Rules described in Clause 4.3 apply uniformly and identically to all Solvers, including any Affiliated Solver. OKX does not grant preferential treatment, weighting adjustment, or any form of advantage to any Solver in:

  • the scoring of solutions;

  • the computation or assignment of Baseline Scores;

  • the application of fairness filtering;

  • the selection of winners; or

  • the order of evaluation within the selection algorithm.

The selection outcome is determined solely by the objective performance of each Solver's submitted solution against the published rules. Solvers compete on equal footing, and no Solver receives any inherent advantage by virtue of its relationship with OKX.

5. Governance and Review

5.1 Periodic Review. This Policy and the underlying controls are reviewed at least annually, or more frequently in response to material changes in market structure, regulatory developments, or the introduction of new Services or product features.

5.2 Identification of New Conflicts. Where new potential conflicts of interest are identified, OKX will assess them, implement appropriate mitigation measures, and update this Policy accordingly. Material updates will be communicated to Users by posting the revised Policy and updating the "Last Updated" date.

5.3 User Concerns. Users who believe a conflict of interest may have affected their use of the Services may submit a complaint through our Support Center. All complaints are reviewed by OKX and addressed in accordance with OKX's internal complaint handling procedures.

6. Limitations and Acknowledgements

6.1 OKX provides the Services on an "as is" and "as available" basis. While OKX has implemented the controls described in this Policy in good faith, OKX cannot guarantee that all conflicts of interest can be eliminated, particularly given the decentralized nature of blockchain-based liquidity. Users acknowledge that residual risks may exist and should exercise their own judgment when using the Services.

6.2 This Policy does not modify or override the disclaimers, limitations of liability, or other provisions set forth in the OKX Web3 Ecosystem Terms of Service or the OKX Web3 DEX Interface User Agreement. In the event of any conflict between this Policy and the foregoing agreements, this Policy shall govern solely with respect to the identification, disclosure, and management of conflicts of interest as described herein, and shall not affect any limitation of liability, disclaimer of warranty, or indemnification provision in the applicable agreement.

6.3 OKX reserves the right to amend this Policy at any time at its sole discretion. The English version of this Policy shall prevail in the event of any discrepancy with translated versions.