Crypto exchange HTX has rotated its on-chain wallet infrastructure across multiple blockchains in the weeks following UK sanctions imposed on May 26, according to a report released Tuesday by blockchain intelligence firm TRM Labs. The UK's Office of Financial Sanctions Implementation designated Huobi Global S.A., the entity behind HTX, marking the first time the UK applied such measures to a crypto exchange of that scale. TRM Labs stated HTX rebuilt its wallet systems on TRON, Ethereum, BNB Smart Chain, and Solana, cycling deposit and hot wallets rapidly to create what the firm described as a 'continuous moving target for compliance professionals.' The UK government alleged HTX channeled more than $1.5 billion to Russia's government to support its invasion of Ukraine, part of a broader sanctions package targeting the 'A7 network' used for sanctions evasion.
TRM Labs stated in its Tuesday report that HTX 'rebuilt its on-chain plumbing' following the UK designation, retiring hot wallets and funding addresses within hours and shifting activity to newly created addresses. The firm documented wallet rotations across TRON, Ethereum, BNB Smart Chain, and Solana networks. According to TRM Labs, address-list screening 'cannot keep pace' with the rotation speed, as block lists built on specific HTX addresses 'go stale within hours.' The firm stated that most activity HTX has conducted since the May 26 designation flows through addresses not captured on existing block lists. TRM Labs argued that effective screening requires tracking the behavior pattern behind rotating wallets rather than relying on static address lists.
The blockchain intelligence firm compared HTX's approach to tactics used by Russian exchange Garantex after its own sanctions designation. TRM Labs noted that after a March 2025 takedown, Garantex operators launched successor platform Grinex and migrated liquidity through ruble-pegged stablecoin A7A5. HTX maintained the same brand while rebuilding wallet infrastructure, according to the report. TRM Labs characterized this response as a pattern observed across well-resourced sanctioned entities, which the firm stated 'rarely disappear and tend to adapt.'
The report noted that the U.S. Treasury's Office of Foreign Assets Control and the European Union have not designated HTX, meaning freeze obligations apply only to UK-regulated firms. TRM Labs stated it considers HTX an 'elevated sanctions-evasion risk' despite the limited geographic scope of the designation.
An HTX spokesperson told Decrypt that the wallet activity described in the TRM Labs report represents standard industry practice. 'The technical activities referenced in TRM's report reflect routine, security-driven platform operations common across the industry,' the spokesperson stated. 'We categorically reject any characterization implying otherwise and have no further comment.'
HTX previously contested the UK sanctions designation. Following the May 26 action, HTX told Decrypt that the listed entity Huobi Global S.A. is 'distinct from the online HTX exchange,' and stated that user funds remained safe and global operations were unaffected. The UK's Office of Financial Sanctions Implementation emphasized that it considers HTX subject to UK financial sanctions due to its ownership by Huobi.
The Office of Financial Sanctions Implementation designated Huobi Global S.A. on May 26 as part of a sanctions package targeting crypto exchanges and the 'A7 network.' British authorities stated the network was 'used by Russia to evade existing restrictions' and channel funds to support Russia's invasion of Ukraine. The UK government announcement flagged HTX as a 'major global cryptocurrency exchange' suspected of channeling more than $1.5 billion to the Kremlin.
The UK's Financial Conduct Authority separately launched enforcement action against HTX earlier this year over illegal promotions to British customers, which prompted the exchange to restrict new UK sign-ups. HTX is owned and advised by Justin Sun, the billionaire crypto entrepreneur whose U.S. fraud case was settled by the Securities and Exchange Commission earlier this year. The exchange reported more than $3 trillion in trading volume in 2025.
What did TRM Labs report about HTX's wallet activity following UK sanctions? TRM Labs reported Tuesday that HTX rotated its on-chain wallet infrastructure across TRON, Ethereum, BNB Smart Chain, and Solana in the weeks following UK sanctions imposed on May 26. The firm stated HTX retired hot wallets and funding addresses within hours and shifted activity to newly created addresses, creating what TRM Labs described as a 'continuous moving target for compliance professionals.' According to the report, address-list screening 'cannot keep pace' with the rotation speed.
How did HTX respond to the TRM Labs report? An HTX spokesperson told Decrypt that the wallet activity reflects 'routine, security-driven platform operations common across the industry.' The spokesperson stated: 'We categorically reject any characterization implying otherwise and have no further comment.' HTX previously stated that the sanctioned entity Huobi Global S.A. is 'distinct from the online HTX exchange' and that user funds remained safe.
Why did the UK sanction HTX on May 26? The UK's Office of Financial Sanctions Implementation designated Huobi Global S.A., the entity behind HTX, on May 26 as part of a sanctions package targeting the 'A7 network.' British authorities alleged the network was used by Russia to evade sanctions and channel funds to support its invasion of Ukraine. The UK government stated HTX was suspected of channeling more than $1.5 billion to the Kremlin.
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