UK Government sanctions cryptocurrency exchange Huobi Global S.A

OTC’s award-winning Crypto Team and leading Sanctions Team comment on the ramifications of the new sanctions against cryptocurrency exchange HTX (Huobi Global S.A.)

On 26 May 2026, the UK Government designated Huobi Global SA (identified as a Panama company, Folio No 155737650), under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regs”). This well-known cryptocurrency exchange, also commonly known as HTX (formerly known as Huobi) or HTX Exchange (hereafter “HTX”), was one of 18 cryptocurrency exchanges, payment providers and individuals sanctioned for their role in Russia’s use of digital assets to bypass sanctions.

Why was HTX sanctioned?

The UK Government’s Statement of Reasons explains that there are reasonable grounds to suspect that HTX is, or has been involved in, obtaining a benefit from or supporting the Government of Russia by providing financial services, or making available funds, economic resources, goods or technology, to A7 Limited Liability Company and Garantex Europe OU, both of which are carrying on businesses in a sector of strategic significance to the Government of Russia.

The expansion of sanctions against Virtual Asset Service Providers (“VASPs”) – businesses which facilitate activities involving digital assets – is likely to be seen by many as long overdue. It has been well-documented by blockchain analysis firms such as Elliptic and Chainalysis that Russia has evaded sanctions on a huge scale by using digital assets. Chainalysis reports that HTX alone is suspected of channelling over US$1.5 billion to Russia through flows from previously sanctioned entities. It was widely considered that this move against VASPs was inevitable, to ensure the efficacy of the UK’s sanctions regime. Even broader moves to sanction the digital asset sector have been taken by the EU and more VASPs are likely to be sanctioned by the UK Government in the future.

How do these sanctions affect HTX?

There are two main prohibitions which now apply to HTX:

1. Asset-freeze (Chapter 1 of the Russia Regs): This prohibits any UK citizen or business from: (i) dealing with funds or economic resources that are owned, held, or controlled by a designated person (“DP”); (ii) making funds or economic resources available directly or indirectly to a DP; and (iii) making economic resources available to any person for the benefit of a DP.
2. Banking System Ousting (Regulation 17A of the Russia Regs): UK credit or financial institutions are prohibited from establishing or continuing a correspondent banking relationship with a designated person. Most critically, Regulation 17A(2) prohibits UK firms from processing a payment to, from, or via a DP.

What is the impact on customers of HTX?

Third parties who do not directly interact with HTX may, nevertheless, find their assets frozen because of indirect interaction. It is anticipated that financial institutions subject to Regulation 17A will deploy specialist tracing software which can identify assets emanating from HTX. If third parties have received those funds further down the transaction chain, there is a real risk that those assets will be impacted.

What steps can customers and other impacted third parties take to access their assets?

Breaches of financial sanctions will result in criminal offences being committed unless an exception or licence applies. Those affected by HTX’s designation would be well advised to seek prompt legal advice. It maybe that a party affected can seek a specific licence from OFSI to authorise behaviour which would otherwise constitute a breach of UK sanctions. It should be noted that OFSI licenses only apply to the UK, and that the party may need to consider whether it will also need to apply for a license from the competent authority in another jurisdiction as well (e.g. OFAC).

Civil claims for delivery up of cryptoassets or for damages for losses are also possible where funds are frozen by excessively cautious third-party exchanges or financial institutions. Similarly, issues may arise where a counterparty transfers cryptoassets which are then frozen by the recipient institution.

Outer Temple Chambers’ Legal Expertise

Members of Outer Temple Chambers are uniquely placed in London and globally to advise on the cross-section of sanctions and digital assets.

Members of Outer Temple Chambers’ Sanctions Team are leaders in this area, having appeared in the most significant UK sanctions cases. Cases of note include: Synesis v Secretary of State for FCDO [2023] EWHC 541 (Admin); Phillips v Secretary of State for FCDO [2024] EWHC 32 (Admin); advising a well-known audit, tax and advisory firm on various sanctions issues pertaining to an £800m bankruptcy; and acting as an overseas expert on the Russia Regulations 2019 in a $125m arbitration in Russia.

In addition, Oliver Powell KC is editor-in-chief on the sanctions chapter in OUP’s Millington and Sutherland Williams on the Proceeds of Crime; and Sophie O’Sullivan edits a chapter on Economic Sanctions in OUP’s Smith, Owen, and Bodnar on Asset Recovery, and is an editor-in-chief of OUP’s UK Sanctions Law and Practice.

Outer Temples’ Fintech Team won Legal 500’s Technology, Data & Crypto Set of the Year in 2023, and is ranked as a Band 1 set in Cryptoassets in Chambers & Partners and Legal 500, with Band 1 individual rankings. Significant cases include: Wang v Darby [2025] EWCA Civ 67, Daburn v Persons Unknown [2025] EWHC 356 (Comm); Payward Inc v Chechetkin [2023] EWHC 1780 (Comm); and the leading UAE case of Gate Mena DMCC and Huobi Mena FZE v Tabarak DIFC CA-002-2023. Various members have also been instructed in the Lantian Gerui (“Blue Sky”) case, dubbed the Chinese ‘crypto queen’ case in the media.

Andrew Spink KC, Helen Pugh, Justina Stewart and Henry Reid authored the chapter on ‘Digital Assets in Bribery and Corruption’ in Lissack and Horlick on International Bribery and Corruption. Helen Pugh’s academic publications have been cited by the English Law Commission in its seminar report on Digital Assets and in the leading case of D’Aloia v Persons Unknown [2024] EWHC 2342 (Ch). Members of chambers also advise overseas governments on legislative reforms in this area.

Members work with leading law firms and experts in sanctions and blockchain tracing. Many members also accept direct access instructions where appropriate. To find out more, contact Lexie Johnson on + 44 (0) 207 427 0801 or Andy Hunter on +44 (0)20 7427 4905 for a confidential discussion.

This article was written by Oliver Powell KC and Helen Pugh.

Legal Blogs, News 15 Jun, 2026