Audit log

Every state-changing event for EXMO Exchange: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1publishby system:backfill

   2026-10-15 18:15:40Z
   Score: ? → ? (no score change)
   anchoranchored

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   ●mainnet-betaslot 457,334,025

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   4AzGG55zqDub…AsxWdxiycopyexplorer ↗

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   {"actor":"system:backfill","investigation_id":"4421286e-4d9a-4883-9b91-26de80ebbac0","kind":"publish","page_slug":"exmo-exchange","published_at":"2026-10-15T18:15:39.916Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"EXMO Exchange","sections":[{"content":"EXMO Exchange Limited is a UK-incorporated entity (Company No. 11655602, incorporated November 1, 2018) headquartered at 2 Kingdom Street, London W2 6JP. The exchange was founded in 2013 or 2014 — sources differ on the exact year — and grew to become one of the largest crypto exchanges serving Eastern European and post-Soviet markets, supporting ruble, hryvnia, and other regional currency pairs. Its founders included Ivan Petuhovski and Pavel Lerner, with Serhii Zhdanov serving as CEO at the time of the wind-down announcement. Following Russia's February 2022 invasion of Ukraine, EXMO announced it had sold its Russia- and Belarus-facing operations to a Kazakhstan-based buyer, which continued operating under the domain exmo.me; EXMO maintained its international platform at exmo.com.","heading":"Company Overview","severity":"low","sources":[{"credibility":1,"name":"EXMO Exchange — About EXMO.com","type":"official","url":"https://exmo.com/blog/en/about-us"},{"credibility":1,"name":"OpenSanctions — EXMO EXCHANGE LTD entity record","type":"regulatory","url":"https://www.opensanctions.org/entities/NK-M2jseYxfb6a3WuuMTXjMhr/"},{"credibility":2,"name":"Exmo Says It Sold Russian Crypto Business — International Business Times","type":"news_article","url":"https://www.ibtimes.com/exmo-says-it-sold-russian-crypto-business-new-owner-will-continue-use-company-name-3478357"}]},{"content":"On May 26, 2026, the UK Foreign, Commonwealth and Development Office (FCDO) designated EXMO Exchange Limited under the Russia (Sanctions) (EU Exit) Regulations 2019. The designation was part of an 18-entity package targeting what UK authorities described as the 'A7 network' — a Kremlin-linked infrastructure system that the UK government alleged moved more than USD 90 billion in the prior year, approximately half of Russia's reported annual military spending. The A7 network is said to have reconstituted ruble-onramp flows following the March 2025 takedown of Garantex. The designation imposes an asset freeze on EXMO Exchange Limited and bars UK-regulated firms from processing payments or maintaining correspondent banking relationships with the entity. UK Foreign Secretary Yvette Cooper stated the government would leave 'no safe havens' for entities enabling Russia's aggression. EXMO disputed the designation but stated it was cooperating with authorities. Blockchain analytics firm TRM Labs documented over USD 19.5 million in direct transactions between EXMO and sanctioned entities including Garantex, Grinex, and Chatex, and found that EXMO.com and EXMO.me shared custodial wallet infrastructure, suggesting the 2022 Russian business sale did not produce full operational separation. Elliptic had separately identified EXMO.me as one of five exchanges filling Garantex's role in Russian sanctions evasion, prior to EXMO.com's own designation. These are allegations and analytical findings from TRM Labs and Elliptic; no court has adjudicated the underlying conduct.","heading":"UK Sanctions Designation (May 2026)","severity":"critical","sources":[{"credibility":1,"name":"UK Government — List of Russia Sanctions Designations, 26 May 2026","type":"regulatory","url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"credibility":2,"name":"TRM Labs — UK Designates Huobi, Exmo, Bitpapa and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"},{"credibility":2,"name":"The Moscow Times — Britain Imposes New Sanctions on Russian Crypto Infrastructure","type":"news_article","url":"https://www.themoscowtimes.com/2026/05/26/britain-imposes-new-sanctions-on-russian-crypto-infrastructure-a92856"},{"credibility":1,"name":"OpenSanctions — EXMO EXCHANGE LTD. (UK FCDO, EU, Ukraine designations)","type":"regulatory","url":"https://www.opensanctions.org/entities/NK-M2jseYxfb6a3WuuMTXjMhr/"},{"credibility":2,"name":"The Block — Five Crypto Exchanges Are Helping Russia Evade Sanctions, Filling Garantex's Void: Elliptic","type":"research","url":"https://www.theblock.co/post/390709/five-crypto-exchanges-are-helping-russia-evade-sanctions-filling-garantexs-void-elliptic"}]},{"content":"On July 23, 2026, the Council of the European Union adopted its 21st Russia sanctions package, which included EXMO Exchange Limited alongside HTX, Rapira, BitPapa, Aifory Pro, and others. The transaction ban took effect on August 23, 2026, prohibiting EU persons and businesses from conducting transactions, directly or indirectly, with the listed entities. Binance separately announced it would cease processing transactions involving EXMO and 15 other platforms in response to the expanded sanctions. EXMO's inclusion in both the UK and EU Russia sanctions regimes represents a concurrent multi-jurisdictional asset freeze.","heading":"EU Sanctions Designation (August 2026)","severity":"critical","sources":[{"credibility":2,"name":"EU Today — EU transaction bans begin for HTX, EXMO and nine other crypto services","type":"news_article","url":"https://eutoday.net/eu-transaction-bans-begin-for-htx-exmo/"},{"credibility":2,"name":"Crowdfund Insider — EU Includes Crypto Platform HTX In Latest Russia Sanctions Package","type":"news_article","url":"https://www.crowdfundinsider.com/2026/07/293760-eu-includes-crypto-platform-htx-in-latest-russia-sanctions-package-imposing-transaction-ban-from-late-august/"},{"credibility":2,"name":"Latestly — Binance To Cut Off HTX, EXMO and 14 Other Crypto Platforms Over EU, US Sanctions","type":"news_article","url":"https://www.latestly.com/technology/binance-to-cut-off-htx-exmo-and-14-other-crypto-platforms-over-eu-us-sanctions-7561157.html/amp"},{"credibility":1,"name":"OpenSanctions — EXMO EXCHANGE LTD. (EU designation record)","type":"regulatory","url":"https://www.opensanctions.org/entities/NK-M2jseYxfb6a3WuuMTXjMhr/"}]},{"content":"Following the UK sanctions designation, EXMO announced an orderly wind-down, closing new account registrations and halting new deposits. Critically, EXMO disclosed it cannot currently return approximately 29.4% of total user obligations. The company attributes this shortfall to two compounding factors: (1) approximately 5% of total assets stolen in a December 2020 hot-wallet hack that was never fully recovered, and (2) a larger share of assets frozen by third-party custodians, banking partners, and payment providers that suspended services in response to the May 2026 sanctions. The combined shortfall — 29.4% — was applied as a mandatory, proportional deduction to every client's balance without individual user consent, constituting a forced bail-in. Users' existing positions can be closed but no new trades can be opened. Withdrawal fees may increase as operational costs rise. The wind-down was reported to have effectively begun around July 25, 2026.","heading":"Forced Wind-Down and 29.4% User Haircut","severity":"critical","sources":[{"credibility":1,"name":"EXMO — EXMO.com Is Closing (official announcement)","type":"official","url":"https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account"},{"credibility":2,"name":"Finance Magnates — EXMO Pulls the Plug: Sanctioned Crypto Exchange Winds Down, Leaves Users Holding IOU Tokens","type":"news_article","url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/"},{"credibility":2,"name":"The Currency Analytics — EXMO Exchange Shuts Down After UK Sanctions Freeze 29.4% of User Funds","type":"news_article","url":"https://thecurrencyanalytics.com/digital-wallet/exmo-exchange-shuts-down-after-uk-sanctions-freeze-29-4-of-user-funds-276032"},{"credibility":2,"name":"FinanceFeeds — EXMO.com to Shut Down After UK Russia Sanctions Hit Group","type":"news_article","url":"https://financefeeds.com/exmo-com-to-shut-down-after-uk-russia-sanctions-hit-group/"}]},{"content":"To represent the 29.4% shortfall, EXMO issued a proprietary token called USDRecover (ticker: USDRec) to affected users in proportional amounts. The token is explicitly non-withdrawable and non-tradable; it functions as a debt claim instrument entitling holders to a proportional share of any future asset recovery. EXMO's announcement states that if frozen funds are released by sanctioned custodians or stolen funds from the 2020 hack are traced and recovered through ongoing legal efforts, USDRec tokens will be redeemed proportionally. There is no guaranteed timeline for any such recovery, and no indication that recovery of frozen sanctions-related assets is likely in the near term given the active multi-jurisdictional designation. Holders of USDRec tokens therefore face indefinite illiquidity on approximately 29.4% of their balances, with recovery contingent on uncertain legal and regulatory outcomes.","heading":"USDRecover (USDRec) IOU Token","severity":"critical","sources":[{"credibility":1,"name":"EXMO — EXMO.com Is Closing (official announcement)","type":"official","url":"https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account"},{"credibility":2,"name":"Finance Magnates — EXMO Pulls the Plug: Sanctioned Crypto Exchange Winds Down, Leaves Users Holding IOU Tokens","type":"news_article","url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/"}]},{"content":"The platform remained online solely to process withdrawals of the remaining approximately 70.6% of user balances. However, withdrawal requests are being processed sequentially in the order received, and as of the time of reporting, processing times had extended to several days per request due to severely disrupted operations. EXMO warned users that additional fees or restrictions may be introduced as the wind-down progresses, creating urgency for users who have not yet initiated withdrawals. For users in regions where EXMO was the primary on-ramp and off-ramp — particularly across Eastern Europe and the former Soviet Union — the combination of delayed withdrawals, a forced haircut, and an illiquid IOU token represents an ongoing and acute consumer harm with no guaranteed resolution timeline.","heading":"Withdrawal Delays and Active Consumer Harm","severity":"high","sources":[{"credibility":1,"name":"EXMO — EXMO.com Is Closing (official announcement)","type":"official","url":"https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account"},{"credibility":2,"name":"The Currency Analytics — EXMO Exchange Shuts Down After UK Sanctions Freeze 29.4% of User Funds","type":"news_article","url":"https://thecurrencyanalytics.com/digital-wallet/exmo-exchange-shuts-down-after-uk-sanctions-freeze-29-4-of-user-funds-276032"}]},{"content":"On December 21, 2020, EXMO suffered a security breach in which attackers withdrew approximately 5% of the exchange's total assets from its hot wallets. The affected assets included BTC, XRP, ZEC, USDT, ETC, and ETH. Third-party analysts estimated the total theft at approximately USD 10.5 million. EXMO detected the suspicious withdrawals, halted operations, and redeployed its hot wallets. Cold wallet assets were reported to be unaffected. EXMO stated at the time that it would cover all losses incurred by affected users and reported the incident to the London Metropolitan Police Cybercrime team. The stolen funds were traced to exchanges including Poloniex and Binance but were never fully recovered. As of the 2026 wind-down announcement, EXMO disclosed that a portion of the unrecovered 2020 hack proceeds contributes to the current 29.4% shortfall. Note: EXMO was the victim of this hack; the breach is reported here as a contributing factor to the present user loss, not as misconduct by EXMO.","heading":"December 2020 Hot-Wallet Hack","severity":"medium","sources":[{"credibility":1,"name":"CoinDesk — Crypto Exchange EXMO Says Hackers Have Stolen 5% of Total Assets","type":"news_article","url":"https://www.coindesk.com/markets/2020/12/21/crypto-exchange-exmo-says-hackers-have-stolen-5-of-total-assets"},{"credibility":2,"name":"BleepingComputer — EXMO Cryptocurrency Exchange Hacked, Loses 5% of Total Assets","type":"news_article","url":"https://www.bleepingcomputer.com/news/security/exmo-cryptocurrency-exchange-hacked-loses-5-percent-of-total-assets/"},{"credibility":1,"name":"EXMO — The 2020 EXMO Security Incident: Resolved","type":"official","url":"https://exmo.com/blog/en/notifications/the-2020-exmo-security-incident-resolved"}]},{"content":"On December 26, 2017, Pavel Lerner, then a managing director of EXMO and a recognized blockchain specialist, was abducted in Kyiv, Ukraine, as he left his office. Kidnappers transported Lerner in a vehicle and released him approximately two days later after receiving a reported ransom of over USD 1 million in Bitcoin, according to an adviser to the Ukrainian Interior Ministry. EXMO confirmed Lerner's release and stated he was safe but under significant stress. The incident was widely reported as an example of targeted physical threats against crypto executives during the 2017 Bitcoin bull market. The event does not reflect misconduct by EXMO but is included here as part of the entity's documented history.","heading":"2017 Executive Kidnapping","severity":"low","sources":[{"credibility":2,"name":"The Hacker News — CEO of Major UK-Based Cryptocurrency Exchange Kidnapped in Ukraine","type":"news_article","url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html"},{"credibility":2,"name":"CoinTelegraph — Director of UK-Based Crypto Exchange Kidnapped in Kiev","type":"news_article","url":"https://cointelegraph.com/news/director-of-uk-based-crypto-exchange-kidnapped-in-kiev"}]}],"sources_used":[{"credibility":1,"name":"UK Government — List of Russia Sanctions Designations, 26 May 2026","type":"regulatory","url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"credibility":1,"name":"OpenSanctions — EXMO EXCHANGE LTD.","type":"regulatory","url":"https://www.opensanctions.org/entities/NK-M2jseYxfb6a3WuuMTXjMhr/"},{"credibility":1,"name":"EXMO — EXMO.com Is Closing (official announcement)","type":"official","url":"https://exmo.com/blog/en/notifications/exmo-com-is-closing-please-initiate-withdrawal-from-your-account"},{"credibility":2,"name":"Finance Magnates — EXMO Pulls the Plug: Sanctioned Crypto Exchange Winds Down, Leaves Users Holding IOU Tokens","type":"news_article","url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/"},{"credibility":2,"name":"The Currency Analytics — EXMO Exchange Shuts Down After UK Sanctions Freeze 29.4% of User Funds","type":"news_article","url":"https://thecurrencyanalytics.com/digital-wallet/exmo-exchange-shuts-down-after-uk-sanctions-freeze-29-4-of-user-funds-276032"},{"credibility":2,"name":"FinanceFeeds — EXMO.com to Shut Down After UK Russia Sanctions Hit Group","type":"news_article","url":"https://financefeeds.com/exmo-com-to-shut-down-after-uk-russia-sanctions-hit-group/"},{"credibility":2,"name":"TRM Labs — UK Designates Huobi, Exmo, Bitpapa and 11 Other Entities for Russian Crypto Sanctions Evasion","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"},{"credibility":2,"name":"The Block — Five Crypto Exchanges Are Helping Russia Evade Sanctions, Filling Garantex's Void: Elliptic","type":"research","url":"https://www.theblock.co/post/390709/five-crypto-exchanges-are-helping-russia-evade-sanctions-filling-garantexs-void-elliptic"},{"credibility":1,"name":"CoinDesk — Crypto Exchange EXMO Says Hackers Have Stolen 5% of Total Assets","type":"news_article","url":"https://www.coindesk.com/markets/2020/12/21/crypto-exchange-exmo-says-hackers-have-stolen-5-of-total-assets"},{"credibility":2,"name":"BleepingComputer — EXMO Cryptocurrency Exchange Hacked, Loses 5% of Total Assets","type":"news_article","url":"https://www.bleepingcomputer.com/news/security/exmo-cryptocurrency-exchange-hacked-loses-5-percent-of-total-assets/"},{"credibility":1,"name":"EXMO — The 2020 EXMO Security Incident: Resolved","type":"official","url":"https://exmo.com/blog/en/notifications/the-2020-exmo-security-incident-resolved"},{"credibility":2,"name":"The Moscow Times — Britain Imposes New Sanctions on Russian Crypto Infrastructure","type":"news_article","url":"https://www.themoscowtimes.com/2026/05/26/britain-imposes-new-sanctions-on-russian-crypto-infrastructure-a92856"},{"credibility":2,"name":"Crowdfund Insider — EU Includes Crypto Platform HTX In Latest Russia Sanctions Package","type":"news_article","url":"https://www.crowdfundinsider.com/2026/07/293760-eu-includes-crypto-platform-htx-in-latest-russia-sanctions-package-imposing-transaction-ban-from-late-august/"},{"credibility":2,"name":"EU Today — EU Transaction Bans Begin for HTX, EXMO and Nine Other Crypto Services","type":"news_article","url":"https://eutoday.net/eu-transaction-bans-begin-for-htx-exmo/"},{"credibility":2,"name":"Latestly — Binance To Cut Off HTX, EXMO and 14 Other Crypto Platforms Over EU, US Sanctions","type":"news_article","url":"https://www.latestly.com/technology/binance-to-cut-off-htx-exmo-and-14-other-crypto-platforms-over-eu-us-sanctions-7561157.html/amp"},{"credibility":2,"name":"The Hacker News — CEO of Major UK-Based Cryptocurrency Exchange Kidnapped in Ukraine","type":"news_article","url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html"},{"credibility":2,"name":"CoinTelegraph — Director of UK-Based Crypto Exchange Kidnapped in Kiev","type":"news_article","url":"https://cointelegraph.com/news/director-of-uk-based-crypto-exchange-kidnapped-in-kiev"},{"credibility":2,"name":"Nasdaq — EXMO Exits Russia, Sells User Base There to Unnamed Buyer","type":"news_article","url":"https://www.nasdaq.com/articles/exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"}],"summary":"EXMO Exchange (EXMO Exchange Limited, registered in the UK) was a cryptocurrency exchange founded in 2013–2014, historically popular with Russian-, Ukrainian-, and Kazakh-speaking traders. On May 26, 2026, the UK Foreign, Commonwealth and Development Office designated EXMO under the Russia (Sanctions) (EU Exit) Regulations 2019, citing alleged involvement in supporting Russia's financial sector and the A7 sanctions-evasion network. Following the designation, EXMO announced an involuntary wind-down of its platform, during which users face a mandatory 29.4% haircut on their balances — the shortfall replaced with a non-withdrawable, non-tradable IOU instrument called USDRecover — while withdrawal processing has suffered multi-day delays.","timeline":[{"date":"2013-01-01","event":"EXMO Exchange founded (approximate year; some sources cite 2014).","source":"EXMO About Us page","source_url":"https://exmo.com/blog/en/about-us"},{"date":"2017-12-26","event":"EXMO managing director Pavel Lerner kidnapped in Kyiv, Ukraine; released after reported USD 1 million Bitcoin ransom.","source":"The Hacker News","source_url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html"},{"date":"2020-12-21","event":"EXMO hot wallets compromised; approximately 5% of total assets (estimated USD 10.5 million) stolen. Cold wallets unaffected.","source":"CoinDesk","source_url":"https://www.coindesk.com/markets/2020/12/21/crypto-exchange-exmo-says-hackers-have-stolen-5-of-total-assets"},{"date":"2022-03-01","event":"EXMO announces exit from Russia and Belarus following invasion of Ukraine; sells Russia-facing operations to unnamed buyer, which continues as exmo.me.","source":"Nasdaq / EXMO announcement","source_url":"https://www.nasdaq.com/articles/exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"},{"date":"2026-05-26","event":"UK FCDO designates EXMO Exchange Limited under Russia (Sanctions) (EU Exit) Regulations 2019, as part of 18-entity A7 network package. Asset freeze and correspondent banking prohibition imposed.","source":"UK Government — List of Russia Sanctions Designations, 26 May 2026","source_url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"date":"2026-07-23","event":"EU adopts 21st Russia sanctions package, designating EXMO Exchange Limited; transaction ban scheduled to take effect August 23, 2026.","source":"Crowdfund Insider","source_url":"https://www.crowdfundinsider.com/2026/07/293760-eu-includes-crypto-platform-htx-in-latest-russia-sanctions-package-imposing-transaction-ban-from-late-august/"},{"date":"2026-07-25","event":"EXMO announces involuntary wind-down of exmo.com platform; new registrations and deposits halted; 29.4% user haircut disclosed; USDRecover token issued to cover shortfall.","source":"Finance Magnates","source_url":"https://www.financemagnates.com/cryptocurrency/exmo-pulls-the-plug-sanctioned-crypto-exchange-winds-down-leaves-users-holding-iou-tokens/"},{"date":"2026-08-23","event":"EU transaction ban on EXMO takes effect; Binance and other platforms cease processing EXMO-linked transactions.","source":"EU Today","source_url":"https://eutoday.net/eu-transaction-bans-begin-for-htx-exmo/"}]},"v":1}

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