{"investigation":{"slug":"huobi","entity_name":"Huobi","trust_score":28,"severity_base":null,"score_modifier":10,"confidence":1,"status":"published","content_type":"investigation","summary":"Huobi, rebranded to HTX in September 2023, is a major centralized cryptocurrency exchange founded in 2013 that came under the de facto control of Tron founder Justin Sun in late 2022. The exchange has suffered three significant security incidents since September 2023, faces extensive regulatory non-compliance across multiple jurisdictions, and its proof-of-reserves methodology has been subject to credible allegations of double-counting and asset manipulation by investigative outlets.","sections":[{"content":"Huobi was founded in 2013 by Leon Li, a former Oracle engineer and Tsinghua University alumnus, alongside co-founder Du Jun. The exchange launched simulation trading in August 2013 and began live Bitcoin trading in September of that year. By December 2013 its trading volume exceeded 30 billion yuan, establishing it as a leading digital asset platform in China. In 2014 it received $10 million in angel and venture capital funding, including from Sequoia Capital. Following China's September 2017 ban on domestic cryptocurrency trading and ICOs, Huobi restructured and expanded internationally, establishing presences in South Korea, Singapore, and Japan. In August 2018 it became a publicly listed Hong Kong company. At its peak Huobi was considered one of the three largest global crypto exchanges by volume. In September 2023, on its tenth anniversary, the exchange rebranded internationally from Huobi Global to HTX, with the letters representing Huobi, Tron, and Exchange respectively.","heading":"Background","sources":[{"url":"https://en.wikipedia.org/wiki/HTX_(cryptocurrency_exchange)","name":"","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":"","type":"other","credibility":3}],"severity":"medium"},{"content":"In late 2022, founder Leon Li sold his controlling stake in Huobi to About Capital Management, an investment firm widely reported to be associated with Justin Sun, the founder of the TRON blockchain. Sun initially described his role as a 'global advisor,' but Bloomberg and other outlets reported that he effectively controls the exchange. Sun formalized his involvement at the TOKEN2049 conference in Singapore on September 13, 2023, where he personally announced the HTX rebrand. The rebranding drew immediate controversy: Bloomberg noted echoes of the FTX brand name, and the 'T' in HTX explicitly standing for TRON embedded Sun's own blockchain project into the exchange's identity. The acquisition linked HTX's fate directly to Sun's broader controversial business empire, which includes the TRON blockchain, the USDD stablecoin, and the BitTorrent platform.","heading":"Justin Sun Acquisition","sources":[{"url":"https://www.bloomberg.com/news/newsletters/2023-09-21/in-justin-sun-s-huobi-rebrand-to-htx-there-are-echoes-of-ftx","name":"","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":"","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-stored-usdd-reserves-at-htx-for-proof-of-reserves/","name":"","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX and its affiliated Heco Chain bridge suffered three major security incidents within a single calendar year. First, on September 24, 2023, HTX's hot wallet was drained of approximately 4,999 ETH valued at roughly $7.9 million. Justin Sun confirmed the breach on September 25, 2023. HTX offered the attacker a 5% white-hat bounty and claimed to have fully covered the losses. Second, in November 2023, the HECO Chain bridge — a cross-chain bridge allowing transfers between the Heco Chain and Ethereum, operated under the same Sun-affiliated umbrella — was exploited via an alleged private key compromise. The attacker used a compromised operator account to withdraw funds from the bridge directly. Total losses from this combined HTX hot-wallet and HECO bridge attack were reported by multiple outlets at approximately $99 million to $115 million, comprising roughly $12.5 million from HTX hot wallets and approximately $86.8 million from the HECO bridge. Stolen assets included USDT, HBTC, SHIB, ETH, USDC, LINK, UNI, and TUSD. Following the November 2023 hack, HTX reported approximately $258 million in net user withdrawals as confidence in the platform eroded. HTX stated it would fully compensate users for hot-wallet losses but made no equivalent pledge for the HECO bridge losses, which affected bridge users rather than exchange depositors. Elliptic and other researchers noted that proceeds from these hacks were subsequently routed through Tornado Cash, with some attribution to North Korean state-linked actors, though that specific attribution has not been conclusively confirmed.","heading":"Security Incidents","sources":[{"url":"https://www.financemagnates.com/cryptocurrency/huobi-globals-htx-hit-by-79-million-crypto-heist-offers-hacker-white-hat-deal/","name":"","type":"other","credibility":3},{"url":"https://www.coindesk.com/tech/2023/11/22/justin-sun-confirms-htx-heco-chain-exploited-after-100m-in-suspicious-transfers","name":"","type":"other","credibility":3},{"url":"https://hacken.io/insights/heco-bridge-hack-explained/","name":"","type":"other","credibility":3},{"url":"https://www.certik.com/resources/blog/heco-bridge-exploit","name":"","type":"other","credibility":3},{"url":"https://www.pymnts.com/cryptocurrency/2023/crypto-platform-htx-loses-258-million-in-withdrawals-after-hack/","name":"","type":"other","credibility":3},{"url":"https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions","name":"","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX faces a pattern of regulatory non-compliance across multiple jurisdictions. In Hong Kong, the exchange's subsidiary HBGL Hong Kong Ltd withdrew its virtual asset trading platform (VATP) licence application from the Securities and Futures Commission (SFC) twice — first in February 2024 and again in May 2024 — and was required to cease Hong Kong operations by August 2024. The specific reasons for the repeated withdrawals were not publicly disclosed by either HTX or the SFC. In Thailand, Huobi's local license was revoked. Malaysia's Securities Commission placed Huobi on its investor warning list for unlicensed securities activities and ordered Huobi Global to cease local operations for operating without DAX registration. In the Philippines, the Securities and Exchange Commission issued a public advisory warning investors against HTX, citing the absence of registration and regulatory licenses. HTX was also struck off the Seychelles corporate register. HTX's User Agreement prohibits residents of the United States, Mainland China, Cuba, Iran, North Korea, Sudan, Syria, Venezuela, Hong Kong, Singapore, and Myanmar from using its services. Despite having previously been headquartered in Singapore, HTX has not obtained a full regulatory license in that jurisdiction. Legal commentators at Shoosmiths noted HTX faces 'high regulatory pressure' across its operating regions.","heading":"Regulatory Issues","sources":[{"url":"https://www.coindesk.com/business/2024/05/15/huobi-hong-kong-withdraws-license-application-for-the-second-time","name":"","type":"other","credibility":3},{"url":"https://cryptonews.com/news/htx-withdraws-hong-kong-crypto-license-application-again/","name":"","type":"other","credibility":3},{"url":"https://bitpinas.com/regulation/sec-advisory-htx-huobi","name":"","type":"other","credibility":3},{"url":"https://www.shoosmiths.com/insights/comment/regulatory-challenges-in-the-cryptocurrency-world-binance-and-htx-huobi","name":"","type":"other","credibility":3},{"url":"https://www.sec.gov/newsroom/press-releases/2023-59","name":"","type":"other","credibility":3}],"severity":"medium"},{"content":"On March 22, 2023, the U.S. Securities and Exchange Commission charged Justin Sun personally and three of his companies — Tron Foundation Limited, BitTorrent Foundation Ltd., and Rainberry Inc. — with the unregistered offer and sale of TRX and BTT crypto asset securities, fraudulent wash trading of TRX, and orchestrating a celebrity promotional scheme where eight celebrities including Lindsay Lohan, Jake Paul, Soulja Boy, and others were paid to tout TRX and BTT without disclosing their compensation. The SEC alleged Sun directed employees to conduct more than 600,000 wash trades of TRX between accounts he controlled from at least April 2018 through February 2019, with between 4.5 million and 7.4 million TRX artificially traded daily. On March 5, 2026, the SEC ended the case: Rainberry Inc. paid a $10 million civil penalty, and all charges against Sun personally, the Tron Foundation, and BitTorrent Foundation were dismissed with prejudice. Sun and his firms neither admitted nor denied the SEC's claims. The dismissal drew significant criticism. Senator Elizabeth Warren issued a statement noting that Sun had contributed approximately $75–90 million to Trump-affiliated crypto ventures prior to the case being dropped, and multiple House Democrats characterized the outcome as a potential 'pay-to-play scheme.' The charges, though now dismissed, relate directly to Sun's business conduct and overlap with the TRON ecosystem that HTX is now branded to represent.","heading":"Justin Sun SEC Fraud Charges","sources":[{"url":"https://www.sec.gov/newsroom/press-releases/2023-59","name":"","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":"","type":"other","credibility":3},{"url":"https://www.coindesk.com/policy/2026/03/05/sec-justin-sun-reach-settlement-over-tron-lawsuit","name":"","type":"other","credibility":3},{"url":"https://www.bloomberg.com/news/articles/2026-03-05/sec-ends-case-against-crypto-billionaire-justin-sun","name":"","type":"other","credibility":3},{"url":"https://www.banking.senate.gov/newsroom/minority/warren-statement-on-the-sec-dropping-its-case-against-justin-sun","name":"","type":"other","credibility":3},{"url":"https://www.cryptotimes.io/2026/03/06/justin-sun-gave-trump-75m-now-his-sec-fraud-case-has-been-dismissed/","name":"","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX began publishing Merkle Tree-based proof-of-reserves (PoR) reports and later introduced a zero-knowledge proof (ZK) PoR system. Published reserve ratios for major assets have consistently shown 100% or above collateralization. However, investigative outlet Protos published multiple reports beginning January 2024 raising serious methodological concerns. Protos identified a Tron address (TZ1SsapyhKNWaVLca6P2qgVzkHTdk6nkXa) that was simultaneously counted as an HTX reserve asset and as collateral for the USDD stablecoin managed by the TRON DAO Reserve, suggesting alleged double-counting. Protos also reported that approximately 92% of HTX's USDT reserves were deployed into Aave lending protocols rather than held in reserve, that approximately $402 million of USDT holdings were composed of stUSDT (a yield-bearing derivative), and that HTX's reserve figures included approximately $125 million in TRX tokens — a Sun-controlled asset — counted both as exchange reserves and as USDD collateral. A separate Protos investigation found that Justin Sun's HTX allegedly redeemed $500 million in WBTC that it was not supposed to hold according to the exchange's own disclosures. HTX suspended its TUSD proof-of-reserves reporting in 2024 after TUSD lost its dollar peg. No independent Big Four accounting firm has audited HTX's reserves. In January 2023, amid post-FTX market anxiety, Sun confirmed layoffs of approximately 20% of Huobi's then-roughly 1,600 staff and dismissed insolvency rumors as 'pure FUD,' while reports surfaced that employees were being paid in USDT rather than fiat currency.","heading":"Proof of Reserves","sources":[{"url":"https://protos.com/justin-sun-stored-usdd-reserves-at-htx-for-proof-of-reserves/","name":"","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-advised-htx-plays-games-with-its-reserves/","name":"","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-defends-htx-while-it-lends-92-percent-of-its-usdt-on-aave-1/","name":"","type":"other","credibility":3},{"url":"https://protos.com/justin-suns-htx-redeems-500m-in-wbtc-it-wasnt-supposed-to-have/","name":"","type":"other","credibility":3},{"url":"https://www.cnbc.com/2023/01/06/crypto-exchange-huobi-to-lay-off-20percent-of-workforce.html","name":"","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-confirms-20-staff-cuts-at-huobi-amid-insolvency-rumors/","name":"","type":"other","credibility":3}],"severity":"medium"},{"content":"HTX presents a materially elevated risk profile for users. The exchange has suffered three confirmed security breaches within a single year (September 2023 hot-wallet hack, November 2023 HECO bridge exploit, November 2023 HTX hot-wallet compromise), resulting in combined losses estimated at over $107 million. Ownership and control by Justin Sun creates a concentrated counterparty risk given Sun's history of alleged market manipulation, the SEC's original fraud charges (settled in 2026), and the entanglement of HTX's balance sheet with Sun-controlled assets such as TRX and USDD. Credible investigative reporting by Protos raises unresolved questions about the integrity of HTX's proof-of-reserves disclosures, including potential double-counting of assets and the deployment of ostensible reserve funds into DeFi yield protocols. Regulatory standing is weak: the exchange has failed to obtain or retain licenses in Hong Kong, Thailand, Malaysia, Singapore, and the Philippines, and is explicitly prohibited from serving users in the United States, China, and other major markets. User sentiment on Trustpilot reflects a pattern of reported withdrawal delays, account freezes, and inadequate customer support, with the exchange holding a 1.4/5 rating. The Trustpilot reviews alone constitute Tier 3 evidence and should be weighted accordingly. Taken together, the combination of repeated hacks, contested reserves methodology, regulatory exclusions, and ownership by a figure facing prior fraud allegations warrants a high severity classification and a low trust score.","heading":"Risk Assessment","sources":[{"url":"https://www.coindesk.com/tech/2023/11/22/justin-sun-confirms-htx-heco-chain-exploited-after-100m-in-suspicious-transfers","name":"","type":"other","credibility":3},{"url":"https://protos.com/justin-sun-stored-usdd-reserves-at-htx-for-proof-of-reserves/","name":"","type":"other","credibility":3},{"url":"https://www.trustpilot.com/review/htx.com","name":"","type":"other","credibility":3},{"url":"https://cryptonews.com/news/htx-withdraws-hong-kong-crypto-license-application-again/","name":"","type":"other","credibility":3}],"severity":"medium"}],"timeline":[{"date":"2013-09","event":"Huobi founded by Leon Li and Du Jun; begins live Bitcoin trading","source":"","date_original":"2013-09-01"},{"date":"2014","event":"Huobi raises $10 million from angel investors and Sequoia Capital","source":"","date_original":"2014-01-01"},{"date":"2017-09","event":"China bans domestic crypto trading and ICOs; Huobi begins international expansion","source":"","date_original":"2017-09-01"},{"date":"2018-08","event":"Huobi becomes a publicly listed Hong Kong company","source":"","date_original":"2018-08-01"},{"date":"2022-10","event":"Leon Li sells controlling stake to About Capital Management, associated with Justin Sun","source":"","date_original":"2022-10-01"},{"date":"2023-01-06","event":"Huobi confirms 20% staff layoffs (~320 employees); insolvency rumors circulate; Sun dismisses concerns as 'pure FUD'","source":""},{"date":"2023-03-22","event":"U.S. SEC charges Justin Sun, Tron Foundation, BitTorrent Foundation, and Rainberry with fraud, wash trading, and unregistered securities sales","source":""},{"date":"2023-09-13","event":"Huobi rebrands to HTX at TOKEN2049 Singapore; Justin Sun announces rebrand personally","source":""},{"date":"2023-09-24","event":"HTX hot wallet drained of approximately 4,999 ETH (~$7.9 million); Sun offers white-hat bounty","source":""},{"date":"2023-11-22","event":"HECO Chain bridge and HTX hot wallets exploited via alleged private key compromise; combined losses estimated at $99–115 million; $258 million in subsequent user withdrawals reported","source":""},{"date":"2024-01-11","event":"Protos publishes investigation alleging HTX double-counted USDD collateral in its proof-of-reserves and deployed 92% of USDT reserves into DeFi lending","source":""},{"date":"2024-02-27","event":"HTX's Hong Kong subsidiary withdraws VATP license application from the SFC for the first time","source":""},{"date":"2024-05-14","event":"HTX's Hong Kong subsidiary withdraws VATP license application for the second and final time; ordered to cease HK operations by August 2024","source":""},{"date":"2026-03-05","event":"SEC dismisses charges against Justin Sun and Tron/BitTorrent Foundations; Rainberry pays $10 million civil penalty; critics allege outcome linked to Sun's $75–90 million in Trump-affiliated crypto investments","source":""}],"sources_used":[{"url":"https://en.wikipedia.org/wiki/HTX_(cryptocurrency_exchange)","name":"","type":"other","archive_url":"http://web.archive.org/web/20260807091414/https://en.wikipedia.org/wiki/HTX_(cryptocurrency_exchange)","credibility":3,"archive_timestamp":"2026-08-07T09:14:14+00:00"},{"url":"https://www.theblock.co/post/250931/justin-sun-hopes-htx-rebrand-will-help-exchange-keep-pace-with-rivals-global-expansion","name":"","type":"other","archive_url":"http://web.archive.org/web/20260725011510/https://www.theblock.co/post/250931/justin-sun-hopes-htx-rebrand-will-help-exchange-keep-pace-with-rivals-global-expansion","credibility":3,"archive_timestamp":"2026-07-25T01:15:10+00:00"},{"url":"https://www.bloomberg.com/news/newsletters/2023-09-21/in-justin-sun-s-huobi-rebrand-to-htx-there-are-echoes-of-ftx","name":"","type":"other","archive_url":"http://web.archive.org/web/20250224203630/https://www.bloomberg.com/news/newsletters/2023-09-21/in-justin-sun-s-huobi-rebrand-to-htx-there-are-echoes-of-ftx","credibility":3,"archive_timestamp":"2025-02-24T20:36:30+00:00"},{"url":"https://protos.com/justin-sun-stored-usdd-reserves-at-htx-for-proof-of-reserves/","name":"","type":"other","archive_url":"http://web.archive.org/web/20260612045555/https://protos.com/justin-sun-stored-usdd-reserves-at-htx-for-proof-of-reserves/","credibility":3,"archive_timestamp":"2026-06-12T04:55:55+00:00"},{"url":"https://www.financemagnates.com/cryptocurrency/huobi-globals-htx-hit-by-79-million-crypto-heist-offers-hacker-white-hat-deal/","name":"","type":"other","archive_url":"https://web.archive.org/web/20260830050130/https://www.financemagnates.com/cryptocurrency/huobi-globals-htx-hit-by-79-million-crypto-heist-offers-hacker-white-hat-deal/","credibility":3,"archive_timestamp":"2026-08-30T05:01:30+00:00"},{"url":"https://www.coindesk.com/tech/2023/11/22/justin-sun-confirms-htx-heco-chain-exploited-after-100m-in-suspicious-transfers","name":"","type":"other","archive_url":"http://web.archive.org/web/20260725211244/https://www.coindesk.com/tech/2023/11/22/justin-sun-confirms-htx-heco-chain-exploited-after-100m-in-suspicious-transfers","credibility":3,"archive_timestamp":"2026-07-25T21:12:44+00:00"},{"url":"https://hacken.io/insights/heco-bridge-hack-explained/","name":"","type":"other","archive_url":"http://web.archive.org/web/20260520141729/https://hacken.io/insights/heco-bridge-hack-explained/","credibility":3,"archive_timestamp":"2026-05-20T14:17:29+00:00"},{"url":"https://www.certik.com/resources/blog/heco-bridge-exploit","name":"","type":"other","archive_url":"http://web.archive.org/web/20251207052708/https://www.certik.com/resources/blog/heco-bridge-exploit","credibility":3,"archive_timestamp":"2025-12-07T05:27:08+00:00"},{"url":"https://www.pymnts.com/cryptocurrency/2023/crypto-platform-htx-loses-258-million-in-withdrawals-after-hack/","name":"","type":"other","archive_url":"http://web.archive.org/web/20251217003821/https://www.pymnts.com/cryptocurrency/2023/crypto-platform-htx-loses-258-million-in-withdrawals-after-hack/","credibility":3,"archive_timestamp":"2025-12-17T00:38:21+00:00"},{"url":"https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions","name":"","type":"other","archive_url":"http://web.archive.org/web/20260519161533/https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions","credibility":3,"archive_timestamp":"2026-05-19T16:15:33+00:00"},{"url":"https://www.coindesk.com/business/2024/05/15/huobi-hong-kong-withdraws-license-application-for-the-second-time","name":"","type":"other","archive_url":null,"credibility":3,"archive_timestamp":null},{"url":"https://cryptonews.com/news/htx-withdraws-hong-kong-crypto-license-application-again/","name":"","type":"other","archive_url":null,"credibility":3,"archive_error":"error:no-request","archive_status":"unarchivable","archive_timestamp":null},{"url":"https://bitpinas.com/regulation/sec-advisory-htx-huobi","name":"","type":"other","archive_url":"http://web.archive.org/web/20260607193937/https://bitpinas.com/regulation/sec-advisory-htx-huobi","credibility":3,"archive_timestamp":"2026-06-07T19:39:37+00:00"},{"url":"https://www.shoosmiths.com/insights/comment/regulatory-challenges-in-the-cryptocurrency-world-binance-and-htx-huobi","name":"","type":"other","archive_url":null,"credibility":3,"archive_error":"error:not-found","archive_status":"unarchivable","archive_timestamp":null},{"url":"https://www.sec.gov/newsroom/press-releases/2023-59","name":"","type":"other","archive_url":"http://web.archive.org/web/20260818023810/https://www.sec.gov/newsroom/press-releases/2023-59","credibility":3,"archive_timestamp":"2026-08-18T02:38:10+00:00"},{"url":"https://www.coindesk.com/policy/2023/03/22/tron-founder-justin-sun-sued-by-us-sec-on-securities-market-manipulation-charges","name":"","type":"other","archive_url":"http://web.archive.org/web/20260724181441/https://www.coindesk.com/policy/2023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