Summary
- A recent analysis by TRM Labs indicates that the cryptocurrency exchange HTX has continued to operate under its established brand despite sanctions imposed by the UK, while revamping its on-chain wallet setup.
- HTX has been rotating its wallets across various platforms, including TRON, Ethereum, BNB Smart Chain, and Solana, creating a "constantly shifting target for compliance authorities," according to TRM Labs.
- The exchange asserted to Decrypt that these activities are part of "standard, security-focused operations" and rejected any alternative interpretations.
In the aftermath of being sanctioned by the UK, crypto exchange HTX has revamped its wallet infrastructure, operating on a fast-paced cycle for deposit and hot wallets, as stated by blockchain intelligence firm TRM Labs in a report released on Tuesday.
TRM Labs noted that the exchange has effectively “reconstructed its on-chain framework,” resulting in address-list screening that “cannot keep up” with the rapid changes.
The UK's Office of Financial Sanctions Implementation designated Huobi Global S.A., the parent company of HTX, on May 26, marking the first instance where the UK has applied such measures to a crypto exchange of this magnitude. This set of sanctions targeted various crypto exchanges and the "A7 network," which British officials claimed was utilized by Russia to bypass existing restrictions and fund its military actions in Ukraine. The UK government identified HTX as a "significant global cryptocurrency exchange" alleged to have funneled over $1.5 billion to the Russian government.
A Shifting Target
TRM Labs reported that following the sanctions, HTX continued to operate under its existing brand while implementing a strategy of rapidly changing its wallets across TRON, Ethereum, BNB Smart Chain, and Solana. Each hot wallet and funding address is retired within hours, with activities shifting to new addresses.
This approach results in a “constantly shifting target,” TRM noted. A blacklist based on specific HTX addresses becomes outdated within hours, effectively clearing most of the exchange's activities since the sanctions were enacted, as transactions are funneled through addresses that have not been previously identified. The firm claimed that effective screening can only occur when it monitors the behavior associated with the rotating wallets, recognizing each new address as it becomes active.
TRM characterized this response as a behavior pattern observed in well-resourced sanctioned entities, which typically do not vanish but adapt instead. The firm drew parallels between HTX's wallet rotation strategy and that of the Russian exchange Garantex after its own sanctioning. Following a crackdown in March 2025, Garantex's operators initiated a successor platform, Grinex, and shifted liquidity through the A7A5 stablecoin pegged to the ruble. Unlike Garantex, HTX maintained its brand while overhauling its wallet system, TRM explained.
The report highlighted that neither the U.S. Treasury's OFAC nor the EU has designated HTX, meaning that only UK-regulated entities must adhere to freeze obligations, even as TRM warned others to consider the exchange an “increased risk of sanctions evasion.”
Response from HTX
An HTX representative stated to Decrypt that the activities highlighted in the report are innocuous. "The technical operations mentioned in TRM's report are routine, security-focused actions typical in the industry," the spokesperson asserted. "We categorically reject any implications to the contrary and have no further comments."
HTX has previously contested the UK's actions. Following the designation in May, HTX informed Decrypt that the listed entity, Huobi Global S.A., is "separate from the HTX exchange online," and assured that user funds remain secure and global operations unaffected. However, OFSI has emphasized that HTX is subject to UK financial sanctions due to its ownership by Huobi.
Earlier this year, the UK's financial regulator, the FCA, initiated enforcement actions against HTX for promoting illegal financial services to British customers, leading the exchange to limit new sign-ups from the UK.
HTX is owned by Justin Sun, the billionaire crypto entrepreneur who recently settled a fraud case with the SEC. The exchange reported a trading volume exceeding $3 trillion in 2025.