{"investigation":{"slug":"htx","entity_name":"HTX","trust_score":28,"severity_base":null,"score_modifier":10,"confidence":0.88,"status":"published","content_type":"investigation","summary":"HTX (formerly Huobi Global) is one of the world's largest cryptocurrency exchanges, rebranded in September 2023 following the de facto acquisition of Huobi by interests linked to Justin Sun in late 2022. The exchange has suffered at least three significant security incidents totaling over $130 million in losses since September 2023, and in May 2026 was sanctioned by the UK government for alleged facilitation of Russian sanctions evasion — the first such crypto-exchange designation under the UK Russia sanctions framework. HTX also faces FCA legal proceedings over illegal financial promotions to UK consumers, has withdrawn its Hong Kong licensing applications twice, and has been publicly criticized for opaque reserve practices.","sections":[{"content":"Huobi Global was acquired by Hong Kong-based About Capital Management in October 2022. Justin Sun, founder of the Tron blockchain, simultaneously joined as a global adviser to the exchange. Sun has consistently denied being the beneficial owner, though he acts as the primary public spokesperson for the platform, makes operational announcements via personal social media, and has pledged personal funds to cover losses from exchange hacks. In September 2023, Huobi rebranded to HTX, a name Sun acknowledged was inspired by Huobi, Tron, and Exchange. Blockchain analytics firm Protos and others have documented that a significant portion of HTX's reported reserves consist of Sun-affiliated tokens and assets, raising concerns about undisclosed conflicts of interest between Sun's role as adviser, the reserves composition, and HTX's obligations to depositors.","heading":"Ownership and Justin Sun Connection","sources":[{"url":"https://en.wikipedia.org/wiki/HTX_(cryptocurrency_exchange)","name":"en.wikipedia.org","type":"other","credibility":3},{"url":"https://www.theblock.co/post/250931/justin-sun-hopes-htx-rebrand-will-help-exchange-keep-pace-with-rivals-global-expansion","name":"theblock.co","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-advised-htx-plays-games-with-its-reserves/","name":"protos.com","type":"other","credibility":3}],"severity":"medium"},{"content":"On May 26, 2026, the UK government sanctioned Huobi Global S.A. (the legal entity behind HTX) as part of an 18-entity package targeting Russian sanctions-evasion networks. This marks the first application of Regulation 17A of the Russia (Sanctions) (EU Exit) Regulations 2019 to a cryptoasset exchange, a correspondent banking-style prohibition that bars UK firms from processing any payments involving the designated entity. UK authorities alleged that HTX provided services to A7 Limited Liability Company — a Kremlin-linked payments network that reportedly moved over $90 billion in 2025, equivalent to roughly half of Russia's annual military expenditure — as well as to Garantex Europe OU, a sanctioned Russian cryptocurrency exchange that had previously rebranded as Grinex. UK investigators alleged HTX channeled over $1.5 billion to Russia through flows from those sanctioned entities and by facilitating cash-outs of a Russian ruble-backed stablecoin. HTX denied the allegations. Major crypto exchanges subsequently increased transfer scrutiny involving HTX.","heading":"UK Government Sanctions — Russia Sanctions Evasion (May 2026)","sources":[{"url":"https://www.elliptic.co/blog/uk-designates-cryptoasset-exchanges-in-sweeping-new-sanctions-package","name":"elliptic.co","type":"other","credibility":3},{"url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/","name":"chainalysis.com","type":"other","credibility":3},{"url":"https://www.bloomberg.com/news/articles/2026-05-26/crypto-firm-htx-sanctioned-by-uk-for-helping-kremlin-move-money","name":"bloomberg.com","type":"other","credibility":3},{"url":"https://crypto.news/htx-denies-uk-sanctions-tied-to-russia/","name":"crypto.news","type":"other","credibility":3},{"url":"https://www.coindesk.com/business/2026/05/27/major-crypto-exchanges-increase-transfer-scrutiny-with-htx-over-uk-sanctions","name":"coindesk.com","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX suffered three distinct security incidents within a three-month period in 2023. First, on September 24, 2023, a hot wallet breach resulted in the theft of 4,999 ETH (~$7.9 million). HTX issued an on-chain ultimatum to the attacker, offering a 5% white-hat bounty in exchange for return of funds within seven days; the attacker ultimately returned 4,997 ETH and claimed the $400,000 bounty. Second, on November 22, 2023, simultaneous exploits targeted HTX exchange hot wallets and the HECO Chain bridge — a cross-chain infrastructure piece linked to Justin Sun. The HECO Chain bridge operator account was compromised, enabling unauthorized minting and draining of approximately $86.6 million; HTX hot wallets lost an additional $13–30 million (estimates vary by source), bringing combined losses to approximately $100–115 million. Stolen assets included USDT, HBTC, SHIB, UNI, USDC, LINK, ETH, and TUSD. On-chain tracking by The Block later found exploiters laundered over $145 million in ether via Tornado Cash. HECO Chain was formally discontinued in January 2025. These incidents followed closely after Justin Sun-linked exchange Poloniex was also hacked for approximately $126–132 million on November 10, 2023, bringing total losses across Sun-affiliated platforms to approximately $238+ million within a single month.","heading":"Security Incidents — Multiple Hacks (2023)","sources":[{"url":"https://www.coindesk.com/business/2023/09/25/crypto-exchange-htx-lost-8m-of-ether-due-to-a-hack-justin-sun-says","name":"coindesk.com","type":"other","credibility":3},{"url":"https://cryptoslate.com/huobi-hacker-returns-4997-eth-stolen-via-hot-wallet-breach-receives-400k-bounty/","name":"cryptoslate.com","type":"other","credibility":3},{"url":"https://www.cnbc.com/2023/11/23/htx-heco-chain-crypto-hack-115-million-stolen-so-far.html","name":"cnbc.com","type":"other","credibility":3},{"url":"https://www.theblock.co/post/284107/heco-bridge-exploiters-launder-145-million-usd-eth-tornado-cash","name":"theblock.co","type":"other","credibility":3},{"url":"https://hacken.io/insights/heco-bridge-hack-explained/","name":"hacken.io","type":"other","credibility":3},{"url":"https://decrypt.co/205465/justin-sun-owned-crypto-exchange-poloniex-hacked-60m","name":"decrypt.co","type":"other","credibility":3}],"severity":"medium"},{"content":"On March 22, 2023, the U.S. Securities and Exchange Commission filed charges against Justin Sun, the Tron Foundation, the BitTorrent Foundation, and BitTorrent (Rainberry) alleging sale of unregistered securities (TRX and BTT tokens), market manipulation via wash trading, and fraudulent revenue generation of approximately $31 million. The SEC complaint directly raised questions about Huobi (later HTX), given that TRX constituted approximately 18% of Huobi's reported reserves at the time of filing. Bloomberg reported that the case stirred broader questions about Huobi's reserve integrity given the concentration of Sun-issued assets. Sun has denied wrongdoing. The case remained active as of the research date.","heading":"SEC Charges Against Justin Sun and TRX Exposure Risk","sources":[{"url":"https://www.sec.gov/newsroom/press-releases/2023-59","name":"sec.gov","type":"other","credibility":3},{"url":"https://www.coindesk.com/policy/2023/03/22/tron-founder-justin-sun-sued-by-us-sec-on-securities-market-manipulation-charges","name":"coindesk.com","type":"other","credibility":3},{"url":"https://www.bloomberg.com/news/articles/2023-03-23/sec-case-against-crypto-mogul-sun-stirs-questions-over-huobi","name":"bloomberg.com","type":"other","credibility":3}],"severity":"medium"},{"content":"Investigative reporting by Protos (July 2024) found material issues in HTX's published proof-of-reserves. HTX claimed approximately $610 million in USDT reserves, of which roughly $460 million consisted of stUSDT — a Sun-controlled yield product — with over 96% of Ethereum-side stUSDT held in an address blockchain explorers label as belonging to Justin Sun personally. Of 25,735 BTC reported in reserves, more than half (14,108 BTC) consisted of Wrapped Bitcoin from Poloniex with no disclosed backing documentation. Of 92,630 ETH reported, only 3,484 were traditional ether; the remainder were staked or bridged assets. Approximately $125 million in TRX was alleged to be counted simultaneously as HTX reserve assets and as collateral for the USDD stablecoin. In a separate Protos investigation, large USDT movements — sometimes as much as $1 billion — were observed cycling rapidly through Aave lending protocol wallets in patterns that appeared to affect on-chain rates. HTX has disputed characterizations of its reserves as manipulated and states its reserve ratio has remained above 100% across 26 published Merkle-tree attestations.","heading":"Reserve Opacity and Alleged Double-Counting","sources":[{"url":"https://protos.com/justin-sun-advised-htx-plays-games-with-its-reserves/","name":"protos.com","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-stored-usdd-reserves-at-htx-for-proof-of-reserves/","name":"protos.com","type":"other","credibility":3},{"url":"https://protos.com/someone-is-taking-advantage-of-htxs-reserves/","name":"protos.com","type":"other","credibility":3}],"severity":"medium"},{"content":"The UK Financial Conduct Authority placed HTX on its Warning List on October 8, 2023, on the day the UK's crypto financial promotions regime took effect, citing illegal marketing to UK consumers. After repeated written warnings were ignored, the FCA initiated legal proceedings against HTX on February 10, 2026 — the first enforcement action of its kind against a crypto firm for illegal UK marketing. The FCA found that HTX continued publishing financial promotions on TikTok, X, Facebook, Instagram, and YouTube after the regime came into force, and that HTX failed to respond to a letter before claim sent in August 2025. As of proceedings, existing UK users could still log in and access allegedly unlawful promotions. HTX is not authorised or registered by the FCA. Consumers dealing with HTX do not have access to the Financial Ombudsman Service.","heading":"UK FCA Legal Action — Illegal Financial Promotions","sources":[{"url":"https://www.fca.org.uk/news/press-releases/fca-action-against-htx-illegal-financial-promotions","name":"fca.org.uk","type":"other","credibility":3},{"url":"https://www.fca.org.uk/news/warnings/huobicom-htxcom-htx-and-or-huobi-global-and-or-huobi","name":"fca.org.uk","type":"other","credibility":3},{"url":"https://cryptobriefing.com/fca-legal-action-against-htx/","name":"cryptobriefing.com","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX's Hong Kong subsidiary, Huobi Global (HGBL) Hong Kong Limited, submitted an application to the Securities and Futures Commission (SFC) for a virtual asset trading platform (VATP) license, then withdrew it within three days. The subsidiary resubmitted on February 26, 2024, and withdrew again on May 14, 2024. Following the second withdrawal, the SFC required HTX to shut down its Huobi HK operations by August 2024. Analysts noted the withdrawals reflected HTX's inability or unwillingness to meet SFC requirements, particularly restrictions on serving mainland Chinese users.","heading":"Hong Kong Licensing Withdrawals","sources":[{"url":"https://www.coindesk.com/policy/2024/02/27/htx-withdraws-hong-kong-crypto-exchange-application","name":"coindesk.com","type":"other","credibility":3},{"url":"https://cryptonews.com/news/htx-withdraws-hong-kong-crypto-license-application-again/","name":"cryptonews.com","type":"other","credibility":3}],"severity":"medium"},{"content":"On January 19–20, 2024, HTX was targeted by a distributed denial-of-service (DDoS) attack affecting exchange services for approximately 15 minutes. Justin Sun announced the incident via personal social media and stated user funds were unaffected. The incident occurred against a backdrop of multiple prior security events, prompting users and analysts to question the exchange's operational resilience.","heading":"DDoS Attack and Operational Incidents (2024)","sources":[{"url":"https://www.coindesk.com/business/2024/01/19/htx-services-restored-after-exchange-hit-by-ddos-attack-justin-sun","name":"coindesk.com","type":"other","credibility":3},{"url":"https://dailyhodl.com/2024/01/20/crypto-exchange-giant-htx-hit-with-ddos-attack-justin-sun-says-user-funds-are-safe/","name":"dailyhodl.com","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX has denied wrongdoing across all major allegations. Following the November 2023 hacks, Justin Sun pledged full reimbursement for affected users and announced an 'epic airdrop' for HTX and Poloniex users. HTX states it has maintained a proof-of-reserves ratio above 100% across 26 published attestations, reports total assets exceeding $4 billion and over 47 million registered users. The exchange formally discontinued HECO Chain in January 2025. Following the May 2026 UK sanctions, HTX stated the designation was unwarranted and denied ties to Russian sanctions-evasion networks. The exchange continues to operate globally while facing exclusion from UK markets, heightened counterparty scrutiny from other major exchanges, and ongoing FCA legal proceedings.","heading":"HTX Response and Current Status","sources":[{"url":"https://www.coindesk.com/business/2023/12/13/htx-poloniex-assets-are-100-safe-says-justin-sun-after-200m-hack","name":"coindesk.com","type":"other","credibility":3},{"url":"https://crypto.news/htx-denies-uk-sanctions-tied-to-russia/","name":"crypto.news","type":"other","credibility":3},{"url":"https://protos.com/htx-misrepresents-huobi-global-s-a-after-uk-sanctions/","name":"protos.com","type":"other","credibility":3}],"severity":"medium"}],"timeline":[{"date":"2022-10","event":"Huobi Global acquired by About Capital Management; Justin Sun joins as global adviser.","source":"","date_original":"2022-10-01"},{"date":"2023-03-22","event":"SEC files charges against Justin Sun, Tron Foundation, and BitTorrent for unregistered securities and market manipulation involving TRX and BTT; Huobi/HTX reserves flagged as holding ~18% TRX.","source":""},{"date":"2023-09-14","event":"Huobi Global officially rebrands to HTX.","source":""},{"date":"2023-09-24","event":"HTX hot wallet breached; 4,999 ETH (~$7.9 million) stolen via private key compromise.","source":""},{"date":"2023-10-08","event":"UK FCA places HTX on its Warning List on the day the UK crypto financial promotions regime takes effect.","source":""},{"date":"2023-11-10","event":"Justin Sun-linked Poloniex exchange hacked for approximately $126–132 million.","source":""},{"date":"2023-11-22","event":"HTX hot wallets and HECO Chain bridge simultaneously exploited; combined losses estimated at $100–115 million.","source":""},{"date":"2024-01-19","event":"HTX services disrupted for ~15 minutes by a DDoS attack; Justin Sun confirms user funds safe.","source":""},{"date":"2024-01-25","event":"HECO Chain formally discontinued.","source":""},{"date":"2024-02-26","event":"HTX resubmits Hong Kong SFC virtual asset trading platform license application.","source":""},{"date":"2024-05-14","event":"HTX withdraws Hong Kong SFC application a second time; SFC orders Huobi HK operations to cease by August 2024.","source":""},{"date":"2024-07-08","event":"Protos publishes investigation alleging HTX reserves include double-counted TRX and substantial Sun-controlled synthetic assets.","source":""},{"date":"2026-02-10","event":"UK FCA initiates legal proceedings against HTX for illegal financial promotions — first such action against a crypto exchange in the UK.","source":""},{"date":"2026-05-26","event":"UK government sanctions Huobi Global S.A. (HTX) under the Russia sanctions framework for alleged facilitation of Russian sanctions evasion via A7 network and Garantex. First crypto exchange designated under Regulation 17A.","source":""},{"date":"2026-05-27","event":"Major crypto exchanges increase transfer scrutiny involving HTX following UK sanctions; HTX denies all 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