“I use Binance” or “my funds are on Kraken” is not legally precise enough. The brand, trading venue, custodian, fiat entity and derivatives counterparty can be different companies in different countries.
What Matters
When a crypto exchange fails, freezes withdrawals, changes jurisdiction, disputes a trade or enters insolvency, the relevant question is not simply which brand you used. It is which legal entity provided the specific service, where that entity is incorporated, which regulator or licensing framework applies, and what dispute forum the contract names.
Large exchanges increasingly operate through multiple entities. One entity may provide spot trading, another custody, another e-money services, and another derivatives. The correct counterparty can also change with residence, registration date, product and migration status.
DN's rule: never infer legal recourse from the exchange logo. Read the entity named in the user's current agreement and product-specific terms.
DN Evidence Block
The mapper records current documented contracting structures. It is not legal advice and does not guarantee that the displayed entity applies to every product or legacy account.
The Signal: One Brand Can Hide Several Counterparties
Traditional exchanges and brokers have long separated trading, clearing, custody and payment functions. Crypto is moving in the same direction.
Binance's current global structure is a clear example. From 5 January 2026, Binance.com transitioned to three ADGM-regulated entities:
- Nest Exchange Limited for exchange activity, including spot and derivatives trading;
- Nest Clearing and Custody Limited for clearing, settlement and custody;
- Nest Trading Limited for off-exchange activities and principal services such as OTC, Convert and Earn.
Coinbase EEA: Crypto and Fiat Sit With Different Entities
Coinbase's EEA agreement states that customers contract with both Coinbase Luxembourg S.A. and Coinbase Ireland Limited, depending on the service.
Coinbase Luxembourg is the MiCA-authorised crypto-asset service provider. Coinbase Ireland provides e-money services under Irish regulation.
That means a dispute over a crypto-asset service and a dispute over an e-money balance can involve different legal entities, regulatory frameworks and governing-law provisions.
Coinbase UK: A Different Contract Again
Coinbase's UK agreement, last updated 16 October 2026, identifies CB Payments Ltd as the contracting entity for UK customers and certain other non-EEA European jurisdictions. It is authorised by the UK Financial Conduct Authority for e-money and additional regulated activities.
This illustrates why a global “Coinbase is regulated by X” statement is incomplete. The correct answer depends on the customer's jurisdiction and service.
Kraken: Residence and Product Both Matter
Kraken's global Terms of Service, last updated 28 October 2026, identifies multiple contracting entities. Examples include:
- Payward Interactive, Inc. for most US users;
- Payward Ltd. for UK users;
- Bit Trade Pty Limited for Australian users;
- Payward Trading Ltd. in the British Virgin Islands for many other global users;
- and separate affiliates for specific derivatives, xStocks, OTC, wallet and other products.
Kraken — Global Terms of Service
The same Kraken account can therefore involve more than one legal counterparty when the user accesses different products.
OKX South Africa: A Local Regulatory Overlay on an Offshore Entity
OKX's South Africa Terms Addendum, published 18 September 2026, states that Aux Cayes FinTech Co. Ltd., incorporated in Seychelles, provides covered services in South Africa as a juristic representative of CurrenC Group (Pty) Ltd, a South African authorised financial services provider with FSP licence 53709.
The addendum explicitly says Aux Cayes does not itself hold an FSCA financial-services-provider licence. Covered services are rendered under CurrenC's mandate and oversight.
OKX — South Africa Terms Addendum
This is exactly the type of structure that a simple “is OKX regulated in South Africa?” question can obscure.
OKX EEA: Malta MiCA Entity
For EU/EEA users, OKX's current EEA terms identify OKX Europe Limited, a Malta company authorised as a crypto-asset service provider under MiCA.
Bybit: Europe Is Segregated From the Global Platform
Bybit launched a dedicated EEA platform operated by Bybit EU GmbH, an Austrian MiCA-authorised crypto-asset service provider. In 2026, Bybit Payments GmbH also received an Austrian electronic-money-institution licence for payment and e-money services on Bybit.eu.
Bybit — Bybit Payments GmbH EMI licence
Current global product terms continue to reference Bybit Technology Limited, while Bybit's 2026 VAT guidance says new Bybit Global users from 19 January 2026 are onboarded under a UAE-incorporated, SCA-regulated entity. Because product and registration cohort matter, DN does not collapse all non-EEA Bybit users into one universal entity without checking account-specific terms.
Bitget: Global Terms Name BTG Technology Holdings Limited
Bitget's current Terms of Use, last updated 20 October 2026, identify BTG Technology Holdings Limited as the operator of the platform and the party to the agreement.
That is the documented global baseline, but regional product restrictions and local regulatory arrangements should still be checked separately.
Gemini: Even the US Can Be State-Specific
Gemini's current user-agreement landing page shows that US residents can be assigned to different entities based on state. Certain states use Gemini Trust Company, LLC, while many others use Gemini Moonbase, LLC.
That is a reminder that entity mapping is not only an international problem. A user's domestic residence can change the contracting company.
DN Exchange Legal Entity Mapper
Exchange Legal Entity Mapper
Select an exchange and region to view the current documented entity structure DN could verify. Always confirm the entity shown in your own account agreement before relying on this result.
Registration date, residence, product and account migration can change the answer.
DN Global Mapper Table
| Exchange / region | Documented entity or entities | Jurisdiction / framework | What DN would verify next |
|---|---|---|---|
| Binance Global | Nest Exchange Ltd; Nest Clearing and Custody Ltd; Nest Trading Ltd | ADGM / FSRA | Which product maps to which entity |
| Coinbase EEA | Coinbase Luxembourg S.A.; Coinbase Ireland Ltd | Luxembourg MiCA + Irish e-money | Crypto vs fiat service |
| Coinbase UK | CB Payments Ltd | UK FCA | Specific regulated service |
| Kraken US | Payward Interactive, Inc. + product-specific affiliates | US; product-specific terms apply | Margin/derivatives/OTC annex |
| Kraken UK | Payward Ltd. + service-specific affiliates | United Kingdom | E-money and product annexes |
| Kraken Global / other | Often Payward Trading Ltd (BVI), subject to exclusions and product annexes | British Virgin Islands / product-specific | Residence + product |
| OKX South Africa | Aux Cayes FinTech Co. Ltd under CurrenC Group (Pty) Ltd oversight for covered services | Seychelles entity + South African FAIS juristic-representative arrangement | Whether the user's product is a Covered Service |
| OKX EEA | OKX Europe Limited | Malta / MiCA | Product scope |
| Bybit EEA | Bybit EU GmbH; Bybit Payments GmbH for e-money/payment services | Austria / MiCA + EMI | Crypto vs payments |
| Bybit Global | Bybit Technology Limited appears in current product terms; new-user entity depends on cohort/jurisdiction | Current global onboarding includes UAE-regulated structure | Account-specific Terms of Service |
| Bitget Global | BTG Technology Holdings Limited | Global terms baseline | Regional restrictions / local arrangements |
| Gemini US | Gemini Trust Company, LLC or Gemini Moonbase, LLC depending on state | US state-specific | State of residence |
DN Entity Complexity Score
DN scores exchange legal-entity complexity separately from safety. More entities can mean stronger segregation of duties, but it can also make recourse harder to understand.
A higher score means the user should spend more time confirming which entity applies. It does not mean the exchange is less safe.
The Four Questions Every User Should Answer
1. Who is my contractual counterparty?
Find the exact company name in the current account or user agreement.
2. Who holds my assets?
The trading entity and custodian may be different companies.
3. Which law and forum apply?
Check governing law, arbitration, courts, complaints and ombudsman provisions.
4. Does this product use another entity?
Derivatives, staking, OTC, payments and custody frequently have separate terms.
Why This Matters in an Insolvency
If an exchange group fails, the relevant creditor relationship can depend on which entity owes the user money or holds the assets. Corporate-group branding does not automatically make every affiliate jointly liable.
Coinbase's EEA agreement is explicit that Coinbase Ireland and Coinbase Luxembourg have several, not joint, liability for their respective obligations. That is a useful reminder that users should not assume one affiliate guarantees another.
Why This Matters for Complaints and Ombudsmen
OKX's South Africa addendum provides a good example. Complaints about covered financial services can move from Aux Cayes to CurrenC and then to the FAIS Ombud. That route exists because of the specific juristic-representative structure.
A user who only knows “I trade on OKX” can miss the actual escalation path.
Why This Matters for Derivatives
Derivatives often sit behind different entities from spot trading. Kraken's current global terms include separate Bermuda and BVI entities for certain derivatives, options, xStocks and OTC products. Binance's new ADGM structure similarly separates exchange, clearing/custody and principal/off-exchange services.
This is especially important for traders who assume their spot account and derivative account have identical legal protections.
South Africa: A Useful Test Case
South African crypto users should check three separate things:
- whether the exchange itself is locally licensed, a juristic representative, or simply serving the user from an offshore entity;
- which products fall inside any South African regulatory arrangement;
- and whether complaint/ombudsman rights apply to the specific service.
DN will not label an exchange “FSCA regulated” merely because one affiliate or representative relationship exists. The exact entity and product scope must be stated.
DN Entity Verification Checklist
Exact company nameCompany numberRegistered jurisdictionRegulator / licenceProduct scopeCustody entityGoverning lawDispute forumMigration dateLast verified
DN Exchange Legal Entity Dataset
exchange_brand customer_region registration_cohort product contracting_entity entity_company_number entity_jurisdiction regulator license_or_registration custody_entity fiat_entity derivatives_entity governing_law dispute_forum complaints_route effective_date source_url last_verified_at status methodology_version
Falsification Test
The DN thesis weakens if exchange users can reliably determine their legal counterparty from the brand alone and product/jurisdiction splits disappear over time.
It also weakens if legal-entity complexity has no practical relationship with custody, complaints, insolvency claims, governing law or product access.
If that happens, the mapper should be simplified rather than maintained as complexity for its own sake.
Frequently Asked Questions
Is the exchange brand the same as the legal entity?
Not necessarily. Large crypto exchanges often operate through multiple companies for trading, custody, payments, derivatives and regional licensing.
How do I know which exchange entity I use?
Check the current user agreement inside your account, including product-specific terms and any migration notice. Residence and registration date can change the answer.
Does being regulated mean all exchange products are regulated?
No. A licence or local arrangement can cover only specific services or entities.
Why does the custody entity matter?
Because the company holding assets may be different from the company operating the trading venue, which can matter for insolvency and legal claims.
Can an exchange change my contracting entity?
Yes, subject to its terms and applicable law. Binance and Coinbase have both documented large entity migrations, and users may receive novation or updated-agreement notices.
Is this legal advice?
No. The mapper is a research tool based on public terms and regulatory disclosures. Users should review their own agreement and seek professional advice where necessary.
DN Alpha Thesis
Exchange legal architecture is becoming a competitive product feature.
As crypto matures, the best exchanges will increasingly resemble financial-market infrastructure: separate trading, custody, clearing and payment functions; clear product-level licensing; and transparent recourse routes.
Final Verdict
The question “which exchange do you use?” is no longer enough.
The legally meaningful version is:
That is the unit the DN Exchange Legal Entity Mapper is designed to track.
Continue the DN Trading Infrastructure Stack
Exchange Account Security 2027 Crypto Withdrawal Holds Guide Passkey Wallet Security BenchmarkPrimary Source Ledger
- Binance — Transition to ADGM: three-entity global operating structure effective 5 January 2026.
- Coinbase — EEA User Agreement: Coinbase Luxembourg and Coinbase Ireland service split.
- Coinbase — UK User Agreement: CB Payments Ltd.
- Kraken — Global Terms: region- and product-specific Payward entities.
- OKX — South Africa Terms Addendum: Aux Cayes / CurrenC juristic-representative structure.
- OKX — EEA Terms: OKX Europe Limited, Malta.
- Bybit — Bybit EU GmbH.
- Bitget — Terms of Use: BTG Technology Holdings Limited.
- Gemini — User Agreement: state-specific US entity structure.
Change Log
| Date | Version | Change |
|---|---|---|
| 2 Nov 2026 | DN-ELM v1.0 | Initial entity mapper covering Binance, Coinbase, Kraken, OKX, Bybit, Bitget and Gemini, plus South Africa focus and legal-entity dataset schema. |
Legal and methodology disclosure: Exchange legal structures change. Public terms may differ from the agreement shown to a particular account because of residence, registration date, customer type, product or migration status. This article is general research, not legal advice. Always confirm the exact entity named in your current account and product terms.
