Last week, TRM Labs held a webinar breaking down the UK's sanctions package targeting HTX and the A7 network, with compliance experts covering designation details, immediate obligations, and response strategies. The UK FCDO designated HTX—formerly Huobi, one of the world's five largest crypto exchanges—alongside 17 other entities, marking the first time a major exchange has been sanctioned. HTX is alleged to have moved approximately USD 1.5 billion for Kremlin-aligned entities, while the A7 network absorbed roughly USD 838 million after the Garantex takedown. UK-regulated firms must immediately block transactions, freeze funds, and report to OFSI. Regulators expect look-back exercises segmented by customer exposure, using consistent review frameworks tied to sanctions evasion typologies. OFSI's three-to-five hop guidance is a minimum, with frequency and pattern of indirect risk paths more important than hop count alone. Pre-designation transactions may not require OFSI reporting but could trigger SAR obligations to the NCA if evasion activity is identified.

Key facts

• UK FCDO designated HTX and 17 other entities, first time a major crypto exchange sanctioned
• HTX alleged to have moved ~$1.5B for Kremlin-aligned entities; A7 network absorbed ~$838M post-Garantex
• Firms must block transactions, freeze funds, and report to OFSI immediately
• Regulators expect structured look-back exercises segmented by customer exposure risk
• OFSI's 3-5 hop guidance is minimum; frequency and pattern of indirect paths are critical