HTX Is Rotating Wallets Faster Than Sanction Lists Can Refresh 🌀

HTX has rebuilt its underlying wallet infrastructure in the weeks since the UK sanctioned it, rotating deposit and hot wallets on a rapid cycle across multiple blockchains, according to a Tuesday report from blockchain intelligence firm TRM Labs. TRM described the shift as a "rebuilt its on-chain plumbing" effort in which address-list screening "cannot keep pace" with the exchange's activity. The United Kingdom's Office of Financial Sanctions Implementation (OFSI) designated Huobi Global S.A., the entity behind HTX, on May 26, marking what the British government called the first time the measure had been applied to a crypto exchange of that size.

The sanctions package targeted crypto exchanges and what British authorities identified as the "A7 network," which the UK government said was "used by Russia to evade existing restrictions" and channel funds tied to its invasion of Ukraine. In its announcement, the UK government flagged HTX as a "major global cryptocurrency exchange" suspected of having channeled more than $1.5 billion to the Kremlin. HTX, owned and advised by Justin Sun, was sanctioned for "making available funds, economic resources, goods or technology to individuals and entities in the Russian financial sector." HTX reported over $3 trillion in trading volume last year.

According to TRM, HTX has remained live under the same brand while cycling its wallets across TRON, Ethereum, BNB Smart Chain, and Solana, retiring each hot wallet and funding address within hours and shifting activity to fresh ones. The firm described the result as a "continuous moving target," with any block list built on specific HTX addresses going "stale within hours" and missing most post-designation flows.

TRM compared the approach to the playbook used by Russian exchange Garantex following its own designation. After a March 2025 takedown, Garantex's operators spun up the successor Grinex and migrated liquidity through the ruble-pegged stablecoin A7A5, while HTX kept the same brand and rebuilt at the wallet level, TRM said. The report noted that the U.S. Treasury's OFAC and the European Union have not designated HTX, meaning freeze obligations fall only on UK-regulated firms, and TRM urged other participants to treat the exchange as an "elevated sanctions-evasion risk." An HTX spokesperson told Decrypt that the behavior flagged in the report is benign, adding that "the technical activities referenced in TRM's report reflect" routine infrastructure practices.