UK Sanctions HTX Under First Crypto Exchange 17A Designation

The UK government designated Huobi Global S.A., the entity behind exchange HTX, on May 26 under Regulation 17A – the first time that power has been applied to a cryptoasset exchange. The move freezes any assets held by UK persons or entities on HTX and prohibits dealings with the exchange.

The designation targets HTX’s alleged provision of financial services to A7 Limited Liability Company, a sanctioned Russian payments network, and cites links to Garantex Europe OU, which has been in regulators’ crosshairs for facilitating illicit Russian financial flows. The broader package includes 18 new designations; EXMO Exchange and Bitpapa were also targeted alongside various entities linked to Russian sanctions circumvention.

HTX reported $3.3 trillion in trading volume for 2025, a 39% increase year-over-year. Spot trading exceeded $1.9 trillion USDT, while futures reached $1.4 trillion. The exchange is currently registered in Panama. It was originally founded in China in 2013 under the name Huobi and rebranded to HTX with advisory influence from crypto entrepreneur Justin Sun.

What the UK Actually Applied

Regulation 17A is a civil sanctions power. It does not require a criminal conviction. The UK Treasury’s Office of Financial Sanctions Implementation (OFSI) can freeze assets and impose financial restrictions on any entity it reasonably suspects of facilitating sanctioned activities. Applying it to a crypto exchange of HTX’s size sets a precedent: regulators are willing to target major platforms, not just fringe players.

The Alleged Connections

The UK government’s statement alleges HTX provided financial services to A7 Limited Liability Company, a sanctioned Russian payments network used to move money for entities linked to the Russian defense sector. Separately, HTX’s ties to Garantex Europe OU – an Estonian-registered entity under EU and US sanctions since 2022 – are cited as evidence of a pattern of facilitating illicit Russian financial flows.

These are not new allegations. The US Treasury’s OFAC sanctioned Garantex in 2022. Several exchanges have previously restricted Russian users. The UK’s move, however, is the first direct sanctioning of a major crypto exchange by a Western government using this specific regulatory tool.

Who Is Exposed and How

Any UK person or entity holding assets on HTX or conducting business with Huobi Global S.A. is now subject to an asset freeze. “UK person” includes individuals resident in the UK, entities incorporated in the UK, and any person acting on behalf of a UK entity regardless of location. UK nationals living abroad could also be covered.

Frozen assets include crypto deposits, spot balances, futures positions, and any other financial assets held on the platform. UK users cannot withdraw, trade, or transfer assets without a specific license from OFSI. The freeze is immediate and does not require a court order.

Practical Risk for Holders

• Liquidity risk: UK users attempting to withdraw assets before the freeze takes effect may find delays or denials. Similar situations at other sanctioned exchanges (e.g., Garantex) saw withdrawals suspended for days or weeks.
• Counterparty risk: Non-UK users who trade with UK-connected accounts on HTX may see counterparties restricted, potentially affecting order matching and settlement.
• Exchange-wide contagion: The designation could prompt other jurisdictions (EU, US, Japan) to follow suit, increasing the risk of a broader freeze or withdrawal ban on HTX globally.

Timeline and Escalation Points

Immediate Effects

• UK users cannot access HTX accounts. Withdrawals are blocked unless OFSI issues a specific license.
• HTX must freeze any UK-linked accounts and report to OFSI within 14 days.
• The exchange may voluntarily restrict all UK users to simplify compliance.

Potential Escalation

• EU and US alignment: The EU has already sanctioned Garantex. The UK’s move increases pressure on the US to formally designate HTX under its own sanctions framework. That would freeze any assets held by US persons and could lead to criminal charges against the exchange’s operators.
• Justin Sun’s designation: If Sun is personally added to the sanctions list, his other projects – including the TRON blockchain and BitTorrent – could face secondary sanctions, affecting tokens like TRX and BTT.

Second-Order Effects on Crypto Markets

Stablecoin Exposure

HTX reports substantial volumes in USDT and USDC pairs. If the sanction leads to a broader freeze, stablecoin issuers may face redemption pressure if large holders attempt to exit. Tether and Circle have historically maintained compliance procedures to avoid sanctioned counterparties. The speed of a freeze could still disrupt liquidity.

Impact on Bitcoin and Ethereum

Bitcoin and Ethereum are the most traded assets on HTX. A freeze on UK accounts could temporarily reduce spot order book depth, increasing spreads. The global crypto market is deep enough to absorb the shock unless other jurisdictions follow suit immediately. The more significant risk is a confidence shock that pushes traders to self-custody solutions, increasing demand for hardware wallets and decentralized exchanges.

Institutional Confidence

Sanctioning a top-tier exchange by volume is a structural signal: regulators are willing to go after the largest platforms. Institutional investors may re-evaluate counterparty risk across all exchanges, particularly those with unclear registration or jurisdictional gaps.

What Would Reduce or Worsen the Risk

Factors That Could Reduce the Risk

• If HTX applies for an OFSI license to allow UK users to wind down positions, the freeze could be temporary and orderly.
• If the UK government clarifies that the sanction targets only the corporate entity and not individual users who unknowingly held assets, some relief could follow.
• If other major jurisdictions do not replicate the sanction, the impact remains contained to UK residents.

Factors That Could Worsen the Risk

• If the EU or US OFAC adds HTX to their own sanctions lists, the freeze becomes global and effectively shuts the exchange out of the Western financial system.
• If Justin Sun is designated, it would freeze assets held by TRON-affiliated entities and could trigger forced liquidations of TRX, BTT, and related tokens.
• If HTX fails to cooperate with UK investigators, OFSI could impose secondary sanctions on any entity that does business with the exchange.

For traders, the immediate action is straightforward: anyone subject to UK jurisdiction should move assets off HTX immediately, assuming the freeze is already in effect. Non-UK traders should watch for signs of liquidity strain on the exchange, particularly in USDT pairs. The broader lesson is regulatory: large exchanges with opaque ownership and jurisdiction-hopping structures are increasingly in the crosshairs, and the cost of that exposure can come suddenly. The UK’s use of Regulation 17A against a major crypto exchange is a precedent that will be cited by regulators globally.

For related coverage, see AlphaScala’s analysis of crypto market structure and regulatory risk, the Bitcoin (BTC) profile for macro exposure, and the UK Sanctions Huobi, USDKG Issuer in Russia Crypto Crackdown for full context on the broader sanctions package.