{"investigation":{"slug":"exmo-exchange-uk-russia-sanctions-shutdown","entity_name":"EXMO Exchange (UK Russia Sanctions / Shutdown)","trust_score":4,"severity_base":null,"score_modifier":0,"confidence":0.85,"status":"draft","content_type":"investigation","summary":"EXMO Exchange Limited, a cryptocurrency exchange founded in 2014 that built a large user base among Russian-, Ukrainian-, and Kazakh-speaking traders, was designated by the UK Foreign, Commonwealth and Development Office (FCDO) on 26 May 2026 under the Russia sanctions regime, as part of an 18-entity action targeting alleged crypto and banking infrastructure supporting Russia's war economy. Following the designation, EXMO confirmed on 14 July 2026 that group entities had become \"effectively paralyzed,\" halted new registrations and deposits, and began an orderly wind-down in which 29.4% of every client balance — reflecting both a long-standing shortfall from a December 2020 hot-wallet hack and newly frozen custodian assets — was converted into a non-tradable, non-withdrawable IOU token called USDRecover. EXMO disputes the sanctions designation but says it is cooperating with UK authorities while managing the closure.","sections":[{"content":"On 26 May 2026, the UK Foreign, Commonwealth and Development Office added EXMO Exchange Limited (registered at 2 Kingdom Street, London W2 6JP) to its Russia sanctions list under the Russia (Sanctions) (EU Exit) Regulations 2019, as part of a package naming 18 entities and individuals, including HTX (formerly Huobi), Bitpapa, Rapira Group, Aifory Pro, ABCex, Eurasian Savings Bank, and three named individuals. The action targeted what UK officials and blockchain analytics firms described as the 'A7 network,' alleged crypto and banking infrastructure said to move on the order of $90 billion annually in support of Russia's war economy. Measures imposed on EXMO include an asset freeze, trust services sanctions, a director disqualification sanction, internet services sanctions, and correspondent banking sanctions, the last of which bars UK financial institutions from processing payments connected to the entity. According to blockchain analytics firm TRM Labs, EXMO had publicly stated it exited the Russian market after the 2022 invasion of Ukraine by selling its Russia-facing operations to a rebranded entity, EXMO.me, but on-chain analysis allegedly found the two platforms continued to share custodial wallet infrastructure, and that EXMO conducted over $19.5 million in direct transactions with previously sanctioned entities including Garantex, Grinex, and Chatex. These are allegations made in the UK designation and by third-party blockchain analytics firms; EXMO has publicly disputed the sanctions (see below). No court adjudication of the underlying allegations was identified in available sources.","heading":"UK FCDO Sanctions Designation (26 May 2026)","sources":[{"url":"https://www.opensanctions.org/entities/gb-fcdo-rus3602/","name":"OpenSanctions — EXMO Exchange Ltd (UK FCDO listing gb-fcdo-rus3602)","type":"regulatory","credibility":1},{"url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","name":"GOV.UK — List of Russia sanctions designations, 26 May 2026","type":"regulatory","credibility":1},{"url":"https://assets.publishing.service.gov.uk/media/6a1578669819be865f421cf1/Sanctions_Notice_Russia_26_May_2026.pdf","name":"UK Sanctions Notice: Russia, 26 May 2026 (OFSI PDF)","type":"regulatory","credibility":1},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"TRM Labs — UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"Chainalysis — UK Sanctions Crypto Companies With Russia Ties","type":"research","credibility":2},{"url":"https://beosin.com/resources/on-chain-analysis14-crypto-entities-including-htx-and-4-individuals-were-sanctioned-by-the-uk","name":"Beosin — On-Chain Analysis: Why 14 Crypto Entities Including HTX and 4 Individuals Were Sanctioned by the UK","type":"research","credibility":2},{"url":"https://bitcoinfoundation.org/news/crypto-companies-news/uk-sanctions-htx-and-exmo-over-alleged-russia-finance-links/","name":"Bitcoin Foundation — UK Sanctions HTX and EXMO Over Alleged Russia Finance Links","type":"news_article","credibility":2}],"severity":"critical"},{"content":"EXMO confirmed on 14 July 2026 that legal entities within the EXMO group had become 'effectively paralyzed' following the May 2026 UK sanctions, and announced it was beginning an orderly wind-down. The exchange stopped accepting new customer registrations and deposits, and restricted trading to closing existing positions. EXMO stated it could not return approximately 29.4% of total client obligations, attributing the shortfall to two combined causes: an unrecovered deficit from a December 2020 hot-wallet hack, and new freezes placed on exchange assets by third-party custodians and payment providers in response to the sanctions. To account for the shortfall, EXMO deducted 29.4% from every client balance and issued a replacement token called USDRecover (ticker USDRec), which the company describes as 'a debt claim token representing your right for proportional distribution of assets that might be recovered.' USDRecover is explicitly non-tradable and non-withdrawable; EXMO says holders would be paid proportionally only if frozen funds are released or stolen funds are recovered through its 'ongoing legal efforts.' The company said withdrawal requests are being processed in the order received but that processing now takes several days due to disrupted operations, and warned that withdrawal fees could rise and further restrictions could be introduced as the wind-down progresses. EXMO stated: 'We believe that sanctions are unjustified, but we continue cooperation with the relevant authorities,' disputing the basis for its designation while stating it has engaged external UK legal counsel.","heading":"Shutdown, 29.4% Shortfall, and USDRecover Token","sources":[{"url":"https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account","name":"EXMO Info Hub — EXMO.com is closing, please initiate withdrawal from your account","type":"official","credibility":2},{"url":"https://exmo.com/blog/en/notifications/update-on-recent-uk-sanctions","name":"EXMO Info Hub — Update on recent UK sanctions","type":"official","credibility":2},{"url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/","name":"Finance Magnates — EXMO Pulls the Plug: Sanctioned Crypto Exchange Winds Down, Leaves Users Holding IOU Tokens","type":"news_article","credibility":2},{"url":"https://www.hokanews.com/2026/07/exmo-shuts-down-after-uk-sanctions.html","name":"Hokanews — EXMO Shuts Down After UK Sanctions Freeze Operations and User Funds","type":"news_article","credibility":2},{"url":"https://thecurrencyanalytics.com/digital-wallet/exmo-exchange-shuts-down-after-uk-sanctions-freeze-29-4-of-user-funds-276032","name":"The Currency Analytics — EXMO Exchange Shuts Down After UK Sanctions Freeze 29.4% of User Funds","type":"news_article","credibility":2},{"url":"https://financefeeds.com/exmo-com-to-shut-down-after-uk-russia-sanctions-hit-group/","name":"FinanceFeeds — EXMO.com to Shut Down After UK Russia Sanctions Hit Group","type":"news_article","credibility":2}],"severity":"critical"},{"content":"On 21 December 2020, EXMO detected suspicious withdrawal activity and halted withdrawals after discovering that an attacker had gained access to its hot-wallet infrastructure. The Block reported EXMO lost approximately 5% of total crypto assets held on the platform, an amount its research analyst estimated at roughly $10.5 million, across bitcoin and five other cryptocurrencies including XRP, Zcash, USDT, Ethereum Classic, and Ethereum. EXMO later said some of the stolen funds were traced through Poloniex and Binance, but the funds were never fully recovered. This unrecovered deficit is cited by EXMO itself as one of the two components (alongside 2026 sanctions-related freezes) of the 29.4% shortfall underlying the USDRecover token program.","heading":"December 2020 Hot-Wallet Hack","sources":[{"url":"https://www.theblock.co/post/88692/crypto-exchange-exmo-hacked","name":"The Block — Crypto exchange EXMO hacked, appears to have lost $10.5 million worth of funds","type":"news_article","credibility":2},{"url":"https://siliconangle.com/2020/12/22/uk-cryptocurrency-exchange-exmo-hacked-customer-funds-stolen/","name":"SiliconANGLE — Customer funds stolen in hack of UK cryptocurrency exchange EXMO","type":"news_article","credibility":2},{"url":"https://www.nasdaq.com/articles/uk-crypto-exchange-exmo-says-%244m-of-hacked-funds-was-through-poloniex-2020-12-25","name":"Nasdaq/Bitcoin.com News — UK Crypto Exchange EXMO Says $4M of Hacked Funds Was Through Poloniex","type":"news_article","credibility":2}],"severity":"high"},{"content":"In March 2022, following Russia's full-scale invasion of Ukraine, EXMO sold its business operations in Russia, Belarus, and Kazakhstan, stating it wanted to avoid jeopardizing its global expansion plans amid Western sanctions on Russia. The operations, along with rights to the EXMO.me domain and branding, were transferred to a separate entity, described in reporting as 'EXMO RBC LLP' (ЭКСМО РБК ТОО), reportedly owned by a Russia-based software vendor that had previously done engineering work for EXMO. In July 2025, Ukraine separately sanctioned EXMO RBC LTD, the Kazakhstan-registered operator of the EXMO.me exchange, as part of a broader package targeting dozens of Russian-linked crypto and financial firms alleged to help Russia evade international restrictions; that Ukrainian action predates and is formally distinct from the May 2026 UK designation of EXMO Exchange Limited. According to blockchain analytics firm TRM Labs, on-chain evidence indicates the two nominally separated entities — EXMO Exchange Limited (UK) and EXMO.me (Kazakhstan) — continued to share custodial wallet infrastructure after the 2022 sale, undercutting EXMO's public position that it had exited the Russian market. These are allegations from a private analytics firm and a foreign government sanctions action; they have not been independently adjudicated in court in sources reviewed.","heading":"Prior Russia-Linked Restructuring and Separate Ukraine Sanctions","sources":[{"url":"https://news.bitcoin.com/leading-eastern-european-exchange-exmo-sells-business-in-russia-belarus/","name":"Bitcoin.com News — Leading Eastern European Exchange Exmo Sells Business in Russia, Belarus","type":"news_article","credibility":2},{"url":"https://www.pravda.com.ua/eng/news/2025/07/06/7520425/","name":"Ukrainska Pravda — Ukraine sanctions 60 Russian crypto firms for helping evade restrictions","type":"news_article","credibility":2},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"TRM Labs — UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","credibility":2}],"severity":"high"},{"content":"EXMO was founded in 2014 (some secondary sources place incorporation in 2013) and grew into a large exchange platform particularly popular with Russian-, Ukrainian-, and Kazakh-speaking traders, in part because of its support for ruble payments, before later expanding to a broader international customer base. In December 2017, EXMO's managing director, Pavel Lerner, was abducted in Kiev, Ukraine, by unidentified individuals; EXMO confirmed the incident at the time and stated that Lerner's role did not grant him access to user funds or personal data, and that the exchange continued operating normally. This history is provided as background and is not itself evidence of wrongdoing by the company, but it illustrates the volatile operating environment EXMO's user base and leadership have faced over the exchange's history.","heading":"Corporate History and Founder Incident","sources":[{"url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html","name":"The Hacker News — CEO of Major UK-Based Cryptocurrency Exchange Kidnapped in Ukraine","type":"news_article","credibility":2},{"url":"https://exmo.com/blog/en/about-us","name":"EXMO Info Hub — About EXMO.com crypto exchange","type":"official","credibility":2}],"severity":"low"},{"content":"Independent of the 2026 sanctions and wind-down, EXMO carried a mixed reputation among users on review platforms such as Trustpilot and Reviews.io prior to its closure. Recurring complaints in user reviews included delayed fiat withdrawals (including a reported disabling of USD withdrawals for stated technical reasons), slow or unresponsive customer support, and account-verification friction. Some users alleged EXMO displayed prices above other exchanges to attract arbitrage trading and then restricted withdrawal of resulting balances; EXMO's own representatives have suggested some complaints stem from fraudulent schemes impersonating the exchange rather than the platform itself. These complaints are sourced primarily from user review aggregators and should be treated as low-confidence, Tier 3 evidence; they were not independently verified against company records and predate the 2026 sanctions-driven shutdown.","heading":"Customer Complaints and Reputation (Pre-Existing)","sources":[{"url":"https://www.trustpilot.com/review/exmo.com","name":"Trustpilot — EXMO.com Reviews","type":"community_report","credibility":3},{"url":"https://www.reviews.io/company-reviews/store/exmo.com","name":"Reviews.io — EXMO.com Company Reviews","type":"community_report","credibility":3}],"severity":"medium"}],"timeline":[{"date":"2014","event":"EXMO cryptocurrency exchange founded; grows a large user base among Russian-, Ukrainian-, and Kazakh-speaking traders.","source":"EXMO Info Hub — About EXMO.com","source_url":"https://exmo.com/blog/en/about-us"},{"date":"2017-12","event":"EXMO managing director Pavel Lerner is abducted in Kiev, Ukraine, by unidentified individuals; EXMO says the incident does not affect user funds.","source":"The Hacker News","source_url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html"},{"date":"2020-12-21","event":"EXMO detects and halts a hot-wallet hack; roughly 5% of platform assets (an estimated $10.5 million) are stolen and never fully recovered.","source":"The Block","source_url":"https://www.theblock.co/post/88692/crypto-exchange-exmo-hacked","date_evidence":"\"the hacker has withdrawn about 5% of EXMO's assets from its 'hot' wallets, the exchange said Monday\" — published December 21, 2020"},{"date":"2022-03","event":"EXMO sells its Russia, Belarus, and Kazakhstan operations to a separate entity (later branded EXMO.me), citing a desire to protect its global expansion amid Russia-related Western sanctions.","source":"Bitcoin.com News","source_url":"https://news.bitcoin.com/leading-eastern-european-exchange-exmo-sells-business-in-russia-belarus/"},{"date":"2025-07","event":"Ukraine sanctions EXMO RBC LTD, the Kazakhstan-registered operator of EXMO.me, as part of a package targeting dozens of Russia-linked crypto firms.","source":"Ukrainska Pravda","source_url":"https://www.pravda.com.ua/eng/news/2025/07/06/7520425/"},{"date":"2026-05-26","event":"UK FCDO designates EXMO Exchange Limited under the Russia (Sanctions) (EU Exit) Regulations 2019, alongside 17 other entities and individuals including HTX/Huobi and Bitpapa, alleging links to Russian sanctions-evasion infrastructure.","source":"GOV.UK","source_url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","date_evidence":"\"List of Russia sanctions designations, 26 May 2026\" — official UK government publication title"},{"date":"2026-07-14","event":"EXMO confirms its group is 'effectively paralyzed' by the sanctions, halts new registrations and deposits, and restricts trading to position closure ahead of a wind-down.","source":"Hokanews","source_url":"https://www.hokanews.com/2026/07/exmo-shuts-down-after-uk-sanctions.html","date_evidence":"\"The exchange confirmed on July 14, 2026, that legal entities within the EXMO Group had become effectively paralyzed following sanctions imposed by the United Kingdom earlier this year.\""},{"date":"2026-07","event":"EXMO publicly announces an orderly wind-down, discloses a 29.4% shortfall in client obligations, and issues the non-tradable, non-withdrawable USDRecover (USDRec) token to affected accounts.","source":"Finance Magnates","source_url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/"}],"sources_used":[{"url":"https://www.opensanctions.org/entities/gb-fcdo-rus3602/","name":"OpenSanctions — EXMO Exchange Ltd (UK FCDO listing gb-fcdo-rus3602)","type":"regulatory","archive_url":"https://web.archive.org/web/20260918234610/https://www.opensanctions.org/entities/NK-M2jseYxfb6a3WuuMTXjMhr/","credibility":1,"archive_timestamp":"2026-09-18T23:46:10+00:00"},{"url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","name":"GOV.UK — List of Russia sanctions designations, 26 May 2026","type":"regulatory","archive_url":"http://web.archive.org/web/20260902173411/https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026","credibility":1,"archive_timestamp":"2026-09-02T17:34:11+00:00"},{"url":"https://assets.publishing.service.gov.uk/media/6a1578669819be865f421cf1/Sanctions_Notice_Russia_26_May_2026.pdf","name":"UK Sanctions Notice: Russia, 26 May 2026 (OFSI PDF)","type":"regulatory","archive_url":"http://web.archive.org/web/20260602182022/https://assets.publishing.service.gov.uk/media/6a1578669819be865f421cf1/Sanctions_Notice_Russia_26_May_2026.pdf","credibility":1,"archive_timestamp":"2026-06-02T18:20:22+00:00"},{"url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","name":"TRM Labs — UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","archive_url":"http://web.archive.org/web/20260618051113/https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion","credibility":2,"archive_timestamp":"2026-06-18T05:11:13+00:00"},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"Chainalysis — UK Sanctions Crypto Companies With Russia Ties","type":"research","archive_url":"http://web.archive.org/web/20260909164957/https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","credibility":2,"archive_timestamp":"2026-09-09T16:49:57+00:00"},{"url":"https://beosin.com/resources/on-chain-analysis14-crypto-entities-including-htx-and-4-individuals-were-sanctioned-by-the-uk","name":"Beosin — On-Chain Analysis: Why 14 Crypto Entities Including HTX and 4 Individuals Were Sanctioned by the UK","type":"research","archive_url":"https://web.archive.org/web/20260919004850/https://beosin.com/resources/on-chain-analysis14-crypto-entities-including-htx-and-4-individuals-were-sanctioned-by-the-uk","credibility":2,"archive_timestamp":"2026-09-19T00:48:50+00:00"},{"url":"https://bitcoinfoundation.org/news/crypto-companies-news/uk-sanctions-htx-and-exmo-over-alleged-russia-finance-links/","name":"Bitcoin Foundation — UK Sanctions HTX and EXMO Over Alleged Russia Finance Links","type":"news_article","archive_url":"https://web.archive.org/web/20260918234448/https://bitcoinfoundation.org/news/crypto-companies-news/uk-sanctions-htx-and-exmo-over-alleged-russia-finance-links/","credibility":2,"archive_timestamp":"2026-09-18T23:44:48+00:00"},{"url":"https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account","name":"EXMO Info Hub — EXMO.com is closing, please initiate withdrawal from your account","type":"official","archive_url":"https://web.archive.org/web/20260918234501/https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account","credibility":2,"archive_timestamp":"2026-09-18T23:45:01+00:00"},{"url":"https://exmo.com/blog/en/notifications/update-on-recent-uk-sanctions","name":"EXMO Info Hub — Update on recent UK sanctions","type":"official","archive_url":"https://web.archive.org/web/20260919005059/https://exmo.com/blog/en/notifications/update-on-recent-uk-sanctions","credibility":2,"archive_timestamp":"2026-09-19T00:50:59+00:00"},{"url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/","name":"Finance Magnates — EXMO Pulls the Plug: Sanctioned Crypto Exchange Winds Down, Leaves Users Holding IOU Tokens","type":"news_article","archive_url":"https://web.archive.org/web/20260919004236/https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/","credibility":2,"archive_timestamp":"2026-09-19T00:42:36+00:00"},{"url":"https://www.hokanews.com/2026/07/exmo-shuts-down-after-uk-sanctions.html","name":"Hokanews — EXMO Shuts Down After UK Sanctions Freeze Operations and User Funds","type":"news_article","archive_url":"https://web.archive.org/web/20260919005724/https://www.hokanews.com/2026/07/exmo-shuts-down-after-uk-sanctions.html","credibility":2,"archive_timestamp":"2026-09-19T00:57:24+00:00"},{"url":"https://thecurrencyanalytics.com/digital-wallet/exmo-exchange-shuts-down-after-uk-sanctions-freeze-29-4-of-user-funds-276032","name":"The Currency Analytics — EXMO Exchange Shuts Down After UK Sanctions Freeze 29.4% of User Funds","type":"news_article","archive_url":"http://web.archive.org/web/20260918235529/https://thecurrencyanalytics.com/digital-wallet/exmo-exchange-shuts-down-after-uk-sanctions-freeze-29-4-of-user-funds-276032","credibility":2,"archive_timestamp":"2026-09-18T23:55:29+00:00"},{"url":"https://financefeeds.com/exmo-com-to-shut-down-after-uk-russia-sanctions-hit-group/","name":"FinanceFeeds — EXMO.com to Shut Down After UK Russia Sanctions Hit Group","type":"news_article","archive_url":"http://web.archive.org/web/20260919005118/https://financefeeds.com/exmo-com-to-shut-down-after-uk-russia-sanctions-hit-group/","credibility":2,"archive_timestamp":"2026-09-19T00:51:18+00:00"},{"url":"https://www.theblock.co/post/88692/crypto-exchange-exmo-hacked","name":"The Block — Crypto exchange EXMO hacked, appears to have lost $10.5 million worth of funds","type":"news_article","archive_url":"http://web.archive.org/web/20260125013836/https://www.theblock.co/post/88692/crypto-exchange-exmo-hacked","credibility":2,"archive_timestamp":"2026-01-25T01:38:36+00:00"},{"url":"https://siliconangle.com/2020/12/22/uk-cryptocurrency-exchange-exmo-hacked-customer-funds-stolen/","name":"SiliconANGLE — Customer funds stolen in hack of UK cryptocurrency exchange EXMO","type":"news_article","archive_url":"http://web.archive.org/web/20260901042245/https://siliconangle.com/2020/12/22/uk-cryptocurrency-exchange-exmo-hacked-customer-funds-stolen/","credibility":2,"archive_timestamp":"2026-09-01T04:22:45+00:00"},{"url":"https://www.nasdaq.com/articles/uk-crypto-exchange-exmo-says-%244m-of-hacked-funds-was-through-poloniex-2020-12-25","name":"Nasdaq/Bitcoin.com News — UK Crypto Exchange EXMO Says $4M of Hacked Funds Was Through Poloniex","type":"news_article","archive_url":"https://web.archive.org/web/20260918235923/https://www.nasdaq.com/articles/uk-crypto-exchange-exmo-says-%244m-of-hacked-funds-was-through-poloniex-2020-12-25","credibility":2,"archive_timestamp":"2026-09-18T23:59:23+00:00"},{"url":"https://news.bitcoin.com/leading-eastern-european-exchange-exmo-sells-business-in-russia-belarus/","name":"Bitcoin.com News — Leading Eastern European Exchange Exmo Sells Business in Russia, 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