On May 26, 2026, the United Kingdom published an updated sanctions list as part of its Russia-related restrictions package. It added 18 new entries – companies, platforms, and individuals. Among them: EXMO, Bitpapa, ABCEX, Aifory, and a number of affiliated entities. But the headline name on the list is Huobi Global S.A. – the legal entity behind the HTX exchange.
This is not a routine addition to the sanctions registry. Direct UK restrictions have now been imposed on one of the world’s largest cryptocurrency exchanges – one processing hundreds of millions of dollars in daily volume and serving tens of millions of users.
To understand the consequences, you need to understand the scale. In 2025, HTX recorded total trading volume of approximately $3.3 trillion – a 39% year-on-year increase – with registered users exceeding 55 million. According to Forbes, HTX ranked 6th globally by spot market share in 2024, with daily trading volume of $4-5 billion.
HTX’s role in the post-Soviet segment is particularly significant. After 2022, when several Western exchanges restricted access for Russian users, HTX continued operating normally. In October 2022, the exchange’s management publicly stated it would not impose restrictions on Russian traders.
HTX’s OTC service served 3.93 million users with transaction volumes of approximately $360 billion across 74 fiat currencies. For hundreds of OTC operators across the CIS, HTX was one of the primary sources of liquidity. These are not abstract figures – this is the infrastructure that underpinned a substantial layer of the regional crypto market.
HTX’s inclusion in the sanctions list triggers a mechanism whose consequences will extend far beyond the exchange itself. To understand why, it’s important to understand how AML systems work.
When a platform is added to a sanctions list, major AML providers update their clusters. But some systems do not limit this to new transactions – they re-label historical data retroactively: transactions that previously passed through HTX addresses may receive a sanctions flag, including those that occurred long before the restrictions were introduced.
This is exactly what happened with Tornado Cash and Garantex. Users who had interacted with those services months or years before the sanctions were imposed found their addresses suddenly turning ‘red’ – with no wrongdoing on their part. A transaction that was clean at the time of execution was retrospectively reclassified as suspicious.
With HTX, the potential scale of this problem is fundamentally different. We are talking about an exchange with tens of millions of users and trillion-dollar trading volumes. A significant portion of legitimate market participants who used HTX as a source of liquidity may find that their transaction history suddenly acquires an unwanted color – not because of anything they did, but simply because they interacted with the platform.
There is an additional risk that often goes overlooked. AML systems do not update instantaneously. After a platform is added to a sanctions list, time passes – sometimes days, sometimes weeks – before all providers synchronize their databases and begin labeling related transactions consistently.
During this transition period, users will receive assets that appear clean in the moment – but may be re-labeled later. Someone conducts a transaction, sees a green risk score, moves the funds further down the chain – and weeks later encounters problems at a receiving exchange involving a completely different transaction. By that point, the source of the problem is non-obvious, and the chain has already grown longer.
The geography of the other entities on the list is telling. Rapira and Arvix – connected to EXMO – are listed as Georgian companies. The document also includes legal entities from Kyrgyzstan, the UAE, and El Salvador. UK regulators are tracking functional ties to Russia’s financial sector regardless of where a company is incorporated.
This principle has already been tested in practice: Garantex relocated, changed domains, and attempted to operate through new legal entities – regulators found the threads each time. The current list includes not just company names but also name variants, associated domains, and affiliated structures. The regulatory machinery has learned to work with restructuring.
The market will visibly ‘turn red’ in the coming weeks. The scale of HTX means that millions of addresses will be affected – and a significant share of them belong to legitimate users who simply traded on one of the world’s largest exchanges.
Some services on the current list will likely attempt to reincorporate or relaunch under a new brand – there are precedents. Pressure on other major exchanges that continue serving users from Russia and the CIS without restrictions will intensify. The HTX case will become a reference point in those conversations.
These events are a reminder that proactive AML compliance is cheaper than reactive damage control. Platforms and users who systematically monitor their transactional connections and screen counterparties in advance are in a fundamentally different position from those who deal with the consequences after the fact.
Match Systems provides a full range of AML compliance services: from address screening and transaction history review to comprehensive regulatory compliance support. For a quick one-off address check, use our bot @MsAmlBot. If you need in-depth analytics or a professional consultation – submit a request on our website and we will get back to you shortly.
