I use both CEX and DEX platforms. Below, I distinguish between them based on their operating models, as well as the key regulations and security measures applicable to each.
🔵 CEX — Centralized Exchanges
OKX — CEX | Partnership / Affiliate
🇪🇺 MiCA / CASP
OKX Europe Limited holds a Crypto-Asset Service Provider (CASP) authorization issued by the Malta Financial Services Authority (MFSA) under the MiCA framework.
📑 MiFID II
OKX Europe Markets Limited holds an investment firm license issued by the MFSA under MiFID II. This applies to specific investment services, including certain financial instruments and products covered by this regulatory framework. It does not mean that all spot crypto trading on OKX falls under MiFID II.
🔐 Proof of Reserves (PoR)
OKX publishes monthly Proof of Reserves reports, using cryptographic verification methods, including zk-STARKs. OKX states that it maintains reserves of at least 1:1 for customer assets.
🏦 Segregation of Customer Assets
OKX Europe states that customer funds are held in accounts separate from the company's own funds.
🛡️ OKX Shield Program
🔎 KYC / AML
Customer identification and anti-money laundering requirements.
Bybit EU — CEX
🇪🇺 MiCA / MiCAR — CASP
Bybit EU GmbH is an authorized Crypto-Asset Service Provider (CASP) in Austria under the MiCA regulatory framework (MiCAR).
🏦 Safeguarding / Segregation of Assets
Under MiCAR, Bybit EU is subject to requirements concerning the protection and segregation of customer assets.
🔐 Proof of Reserves (PoR)
Bybit publishes Proof of Reserves information and states that it maintains a 1:1 reserve ratio for user assets. However, PoR is a transparency mechanism, not a regulatory license.
🔎 KYC / AML
Compliance obligations arising from applicable regulations and internal compliance procedures.
⚠️ Important: Bybit EU holds a MiCAR authorization for specific services. Not all products and services available on the platform are necessarily covered by this regulatory framework.
🟣 DEX — Decentralized Exchanges
Uniswap — DEX
🔗 Decentralized Exchange / Automated Market Maker (AMM)
Uniswap is a decentralized exchange protocol that uses smart contracts and liquidity pools rather than a traditional centralized order book.
👛 Non-Custodial / Self-Custody
The protocol does not take custody of users' funds in the same way as a traditional centralized exchange. Users interact through their own wallets and retain control of their private keys.
🌐 On-Chain
Transactions are executed directly on the blockchain according to the logic of smart contracts.
❌ No MiCA License Equivalent to That of a Centralized Exchange
As a decentralized protocol, Uniswap should not be presented as holding a MiCA authorization equivalent to those held by entities such as OKX Europe or Bybit EU.
⚖️ Summary Comparison
Platform | Type | MiCA / MiCAR | MiFID II | PoR | Custody |
|---|---|---|---|---|---|
OKX | CEX | ✅ | ✅* | ✅ | ✅ |
Bybit EU | CEX | ✅ | ❌** | ✅ | ✅ |
Uniswap | DEX | ❌ | ❌ | ❌*** | ❌ |
* MiFID II applies to specific investment services offered by OKX Europe Markets, not to all spot crypto trading.
** Bybit EU is regulated under MiCAR as a CASP. It should not be described as holding a general MiFID II license for crypto services.
*** Uniswap provides on-chain transparency, but this is not the same as a traditional centralized exchange's Proof of Reserves mechanism.
Key Definitions
MiCA / MiCAR = The EU regulatory framework for crypto-assets and Crypto-Asset Service Providers (CASPs).
MiFID II = The regulatory framework governing certain investment services and financial instruments.
PoR (Proof of Reserves) = A reserve transparency mechanism, not a regulatory license.
CEX = Centralized exchange.
DEX = Decentralized exchange protocol.
