Key facts
- Crypto exchange HTX has rebuilt its on-chain wallet infrastructure after being sanctioned by the UK.
- TRM Labs reported that HTX is rapidly cycling its hot wallets and funding addresses across TRON, Ethereum, BNB Smart Chain, and Solana.
- The UK government sanctioned Huobi Global S.A., the entity behind HTX, on May 26, suspecting it of channeling over $1.5 billion to the Kremlin.
- HTX stated the observed activity is routine and security-driven, rejecting implications of sanctions evasion.
- TRM Labs noted that the U.S. Treasury's OFAC and the EU have not designated HTX.
Crypto exchange HTX has rebuilt its underlying wallet infrastructure in the weeks following UK sanctions, rapidly cycling its deposit and hot wallets across TRON, Ethereum, BNB Smart Chain, and Solana, according to a report by blockchain intelligence firm TRM Labs. The firm stated that this rapid rotation makes it difficult for compliance professionals to keep pace, creating a "continuous moving target."
The UK's Office of Financial Sanctions Implementation (OFSI) designated Huobi Global S.A., the entity behind HTX, on May 26. This marked the first time the UK applied such sanctions to a crypto exchange of that size, flagging HTX as a "major global cryptocurrency exchange" suspected of channeling more than $1.5 billion to the Kremlin to fuel its invasion of Ukraine. The sanctions package also targeted the "A7 network," which British authorities said was used by Russia to evade existing restrictions.
TRM Labs noted that HTX has remained operational under the same brand since the designation. The exchange's strategy of retiring hot wallets and funding addresses within hours and shifting activity to new ones means that block lists become outdated quickly. TRM framed this approach as a pattern observed in well-resourced sanctioned entities that adapt rather than disappear, comparing it to the playbook of Russian exchange Garantex. However, the U.S. Treasury's OFAC and the EU have not designated HTX, meaning freeze obligations currently fall only on UK-regulated firms.
An HTX spokesperson told Decrypt that the activities reported by TRM Labs reflect "routine, security-driven platform operations common across the industry" and categorically rejected any characterization implying otherwise. The exchange has previously contested the UK action, stating that the designated entity is distinct from the online HTX exchange and that user funds remain safe. The UK's Financial Conduct Authority (FCA) had also previously taken enforcement action against HTX over illegal promotions to British customers.
HTX is owned and advised by billionaire crypto entrepreneur Justin Sun, who recently settled a U.S. fraud case with the SEC. The exchange reported over $3 trillion in trading volume in 2025.