Verify a decision

{"actor":"system:backfill","investigation_id":"7f926ba9-0b59-4674-8aa6-34eea1ebc5b1","kind":"publish","page_slug":"exmo-exchange-limited","published_at":"2026-05-27T19:06:25.315Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"EXMO Exchange Limited","sections":[{"content":"On May 26, 2026, the UK Foreign, Commonwealth and Development Office (FCDO) added EXMO Exchange Limited to the UK Sanctions List under the Russia (Sanctions) (EU Exit) Regulations 2019. The designation was part of an 18-entity package grouped under Category 1: 'Entities and individuals involved in supporting the Russian financial sector.' The sanctions bundle applied to EXMO is the most extensive in the May 2026 package and includes: (1) an asset freeze — all funds and economic resources owned or controlled by EXMO must be frozen and UK persons are prohibited from making funds available to the entity; (2) Trust Services Sanctions; (3) Director Disqualification Sanctions; (4) Internet Services Sanctions — UK internet service providers and app stores must take reasonable steps to prevent UK users from accessing EXMO's services; (5) Correspondent Banking Sanctions — UK credit and financial institutions are prohibited from establishing or maintaining correspondent banking relationships with EXMO; and (6) payment processing restrictions. The registered details of the designated entity are: EXMO Exchange Limited, 60 Cannon Street, London, EC4N 6NP, United Kingdom, Companies House registration number 12315005. The stated grounds for designation are that EXMO provided financial services and economic resources to A7 Limited Liability Company.","heading":"UK FCDO Designation (May 26, 2026)","severity":"critical","sources":[{"credibility":1,"name":"List of Russia sanctions designations, 26 May 2026 — GOV.UK","type":"regulatory","url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"credibility":1,"name":"Sanctions Notice: Russia, 26 May 2026 — UK FCDO (PDF)","type":"regulatory","url":"https://assets.publishing.service.gov.uk/media/6a1578669819be865f421cf1/Sanctions_Notice_Russia_26_May_2026.pdf"},{"credibility":2,"name":"UK Sanctions Bitpapa, Exmo and Others Over A7 Links — BanklessTimes","type":"news_article","url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/"},{"credibility":2,"name":"UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion — TRM Labs","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":"UK Moves to Choke Russia's Crypto-Powered Shadow Economy — CryptoTimes","type":"news_article","url":"https://www.cryptotimes.io/2026/05/26/uk-moves-to-choke-russias-crypto-powered-shadow-economy/"}]},{"content":"The UK FCDO's stated grounds for designation allege that EXMO Exchange Limited provided financial services, funds, or economic resources to A7 Limited Liability Company. A7 LLC is described by UK officials as a complex system 'designed to bypass Western sanctions, finance military procurement, and process funds from the sale of oil to fund its war economy.' A7 LLC was itself first sanctioned by the FCDO in May 2025. The A7 network centers on the A7A5 stablecoin, a ruble-backed instrument issued in Kyrgyzstan and circulating on Ethereum and TRON, which is alleged to have logged $93 billion in trading volume in its first year and to have moved over $90 billion into Russia's economy — a figure representing approximately half of Russia's annual military expenditures according to official estimates. Most A7 network flows are alleged to have moved through exchanges with Russian connections, particularly Grinex and Garantex. EXMO's specific role in the A7 network is characterized as providing financial infrastructure that facilitated A7 network operations, though granular transactional details directly linking EXMO to A7 LLC have not been separately released by the FCDO in publicly available documents. EXMO was one of several exchanges designated alongside entities more directly integrated into A7 corporate infrastructure.","heading":"Alleged Connection to A7 LLC and Russian Military Procurement","severity":"critical","sources":[{"credibility":2,"name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/"},{"credibility":2,"name":"UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion — TRM Labs","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":"UK Sanctions Bitpapa, Exmo and Others Over A7 Links — BanklessTimes","type":"news_article","url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/"}]},{"content":"Blockchain analytics firms published findings prior to the UK designation that documented EXMO's alleged transactional exposure to sanctioned entities. TRM Labs reported that EXMO conducted more than $19.5 million in direct transactions with sanctioned entities including Garantex (a previously designated Russian exchange), Grinex (a Garantex successor platform), and Chatex (also previously sanctioned). Elliptic, in a February 2026 report identifying five exchanges allegedly filling Garantex's void, found that EXMO.me — the Russia-facing entity created after EXMO's claimed 2022 Russia exit — sent more than $1 million directly to Garantex and continued transacting with other Russia-linked services. A critical on-chain finding concerns the relationship between EXMO.com (the UK entity) and EXMO.me (the Kazakhstan entity): despite the public corporate separation announced in April 2022, blockchain analysis showed the two platforms sharing identical custodial wallet infrastructure, with deposits on both platforms pooling into the same hot wallet addresses and withdrawals executed from matching addresses. This finding directly informed the UK decision to designate the London-registered entity rather than only the Kazakhstan successor, as it indicated the alleged corporate separation did not produce genuine operational independence.","heading":"Blockchain Analytics: Transactions with Sanctioned Entities","severity":"critical","sources":[{"credibility":2,"name":"Russia-linked Cryptocurrency Services and Sanctions Evasion — Elliptic","type":"research","url":"https://www.elliptic.co/blog/russia-linked-cryptocurrency-services-and-sanctions-evasion"},{"credibility":2,"name":"Five Crypto Exchanges Helping Russia Evade Sanctions, Filling Garantex's Void — The Block","type":"news_article","url":"https://www.theblock.co/post/390709/five-crypto-exchanges-are-helping-russia-evade-sanctions-filling-garantexs-void-elliptic"},{"credibility":2,"name":"UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"}]},{"content":"Prior to the UK designation, Ukraine sanctioned EXMO in July 2025 through the National Security and Defense Council (NSDC) State Register of Sanctions. The Ukrainian sanction was applied specifically to the Kazakhstan-registered Exmo entity (EXMO.me), which had been serving Russian, Belarusian, and Kazakhstani users since EXMO.com's claimed Russia exit in April 2022. The Ukrainian designation made EXMO subject to multiple national sanctions regimes before the UK action, with TRM Labs noting this sequential designation pattern across jurisdictions. Granular details of the Ukrainian decree were not separately verified from primary Ukrainian government sources at time of writing.","heading":"Ukraine Sanctions (July 2025)","severity":"critical","sources":[{"credibility":2,"name":"UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"},{"credibility":1,"name":"Ukraine NSDC State Register of Sanctions — OpenSanctions","type":"regulatory","url":"https://www.opensanctions.org/datasets/ua_nsdc_sanctions/"}]},{"content":"Following Russia's invasion of Ukraine in February 2022, EXMO.com announced in April 2022 that it was exiting Russia to 'avoid the damaging association' with the country and to protect its regulatory expansion plans, including planned licenses in Gibraltar, the UK, and 40 US states. The exchange sold its Russian user base — approximately one million accounts — along with associated software and intellectual property to an unnamed Russian-based software development company described as a former EXMO engineering vendor. A new Kazakhstan-registered entity, EXMO RBK LTD., was established to operate the Russia/Belarus/Kazakhstan-facing service under the domain EXMO.me. Co-founder Eduard Bark, a Russian citizen who held a 37.51% stake, departed and transferred his shares to CEO Serhii Zhdanov as part of the restructuring. Despite these public announcements, blockchain analytics subsequently identified that EXMO.com and EXMO.me continued to share the same custodial hot wallet infrastructure — with funds from both platforms pooling into identical wallet addresses. This finding directly contradicted EXMO's public assertions of separation and formed a central element of the UK FCDO's decision to designate the London-registered EXMO Exchange Limited rather than only the Kazakhstan successor. The identity of the unnamed buyer of the Russian business was never publicly disclosed.","heading":"Russia Exit (April 2022) and Alleged Operational Continuity","severity":"high","sources":[{"credibility":2,"name":"EXMO Exits Russia, Sells User Base There to Unnamed Buyer — CoinDesk","type":"news_article","url":"https://www.coindesk.com/business/2022/04/18/crypto-exchange-exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"},{"credibility":2,"name":"EXMO Exits Russia, Sells User Base There to Unnamed Buyer — Nasdaq","type":"news_article","url":"https://www.nasdaq.com/articles/exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"},{"credibility":2,"name":"Russia-linked Cryptocurrency Services and Sanctions Evasion — Elliptic","type":"research","url":"https://www.elliptic.co/blog/russia-linked-cryptocurrency-services-and-sanctions-evasion"}]},{"content":"On December 21, 2020, EXMO detected unauthorized access to its hot wallets. Attackers obtained private keys to hot wallets and extracted approximately 6% of the exchange's total crypto assets. Assets stolen included 306.99 BTC (valued at approximately $7.2 million at time of the breach), XRP, Tether (USDT), Ethereum, and Ethereum Classic. Some stolen XRP and ETH were traced to Poloniex, which EXMO contacted to freeze the associated account. EXMO notified London police and conducted a private forensic investigation to identify the attack vector. The specific entry method was not publicly confirmed, though the exchange stated attackers had obtained 'prior access to some hot wallet keys.' The exchange fully suspended deposits and withdrawals during the investigation. EXMO subsequently confirmed that 100% of affected user funds were reimbursed. Following the breach, the UK Financial Conduct Authority (FCA) directly contacted EXMO to discuss prevention measures. The specific attackers were not publicly identified or charged.","heading":"Security Breach (December 2020)","severity":"high","sources":[{"credibility":2,"name":"EXMO Exchange Now Says It Lost 6% of Total Crypto Assets in Monday's Hack — CoinDesk","type":"news_article","url":"https://www.coindesk.com/markets/2020/12/22/exmo-exchange-now-says-it-lost-6-of-total-crypto-assets-in-mondays-hack/"},{"credibility":2,"name":"Customer Funds Stolen in Hack of UK Cryptocurrency Exchange EXMO — SiliconANGLE","type":"news_article","url":"https://siliconangle.com/2020/12/22/uk-cryptocurrency-exchange-exmo-hacked-customer-funds-stolen/"},{"credibility":2,"name":"UK Crypto Exchange EXMO Says $4M of Hacked Funds Was Through Poloniex — CoinDesk","type":"news_article","url":"https://www.coindesk.com/markets/2020/12/25/uk-crypto-exchange-exmo-says-4m-of-hacked-funds-was-through-poloniex"}]},{"content":"On December 26, 2017, Pavel Lerner, a Russian national serving as EXMO's managing director and lead analyst, was kidnapped outside his Kyiv office by individuals in dark clothing and balaclavas who forced him into a black Mercedes-Benz Vito vehicle. He was held for approximately three days. According to reporting citing a Ukrainian member of parliament and contemporaneous Financial Times coverage, a ransom of approximately $1 million was paid, with some sources reporting the figure as 102 BTC (worth approximately $2 million at prevailing Bitcoin prices). Lerner was released without serious physical harm. Ukrainian police opened an investigation; no suspects were publicly charged. EXMO's public statement at the time stated that Lerner 'didn't have direct access to any cryptocurrency account or other personal data' and that all user funds were safe. Following his release, Lerner departed Ukraine. The incident occurred shortly before a separate DDoS attack on EXMO's website, though no causal link between the two events was established by investigators.","heading":"Kidnapping of Pavel Lerner (December 2017)","severity":"high","sources":[{"credibility":2,"name":"FT: EXMO Director Released From Kidnap After Paying $1 Mln Ransom — CoinTelegraph","type":"news_article","url":"https://cointelegraph.com/news/ft-exmo-director-released-from-kidnap-after-paying-1-mln-ransom"},{"credibility":2,"name":"Director of UK Cryptocurrency Exchange EXMO Kidnapped in Ukraine — CCN","type":"news_article","url":"https://www.ccn.com/head-of-cryptocurrency-exchange-exmo-kidnapped-in-kiev/"},{"credibility":2,"name":"CEO of Major UK-Based Cryptocurrency Exchange Kidnapped in Ukraine — The Hacker News","type":"news_article","url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html"},{"credibility":2,"name":"A Bitcoin Exchange's Exec Was Kidnapped Before Hackers Attacked Its Site — Quartz","type":"news_article","url":"https://qz.com/1168060/bitcoin-btc-exchange-exmo-exec-pavel-lerner-kidnapped-before-ddos-attack"}]},{"content":"EXMO Exchange Limited received temporary registration from the UK Financial Conduct Authority as a cryptoasset business in December 2020, as one of approximately 95 companies granted temporary authorization under the UK anti-money laundering regime for crypto firms. The FCA contacted EXMO in January 2020 regarding upcoming KYC and verification requirements. Following EXMO's December 2020 hack, the FCA contacted the exchange again to discuss prevention measures. During the temporary registration period, EXMO's compliance team grew to 26 people, and the company reported a 10% decline in overall income attributable to new compliance infrastructure costs. The exchange reported approximately 500 monthly active UK users and 400,000 users who had completed at least one trade. Subsequently, EXMO representatives confirmed the exchange had withdrawn its full FCA registration application and restructured to serve UK clients from other jurisdictions, including Lithuania, Poland, and Cyprus. EXMO's Russian-facing domain was at one point blocked by Roskomnadzor, Russia's telecom regulator — a decision EXMO challenged in court. At the time of the UK designation in May 2026, EXMO's full FCA registration had lapsed.","heading":"FCA Registration History and Regulatory Compliance","severity":"medium","sources":[{"credibility":2,"name":"What Does It Cost to Become an FCA-Approved Exchange? EXMO Execs Explain — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2021/01/06/what-does-it-cost-to-become-an-fca-approved-exchange-exmo-execs-explain"}]},{"content":"EXMO was founded in 2013 by Ivan Petukhovsky and Pavel Lerner, both Russian nationals, as a cryptocurrency exchange targeting the Russian-speaking retail market. The exchange registered its principal entity in the United Kingdom and established operational offices in Ukraine, Poland, Lithuania, and the United States. At its peak EXMO was reported as the leading exchange in Eastern Europe and the CIS region, offering over 46 trading pairs, direct fiat on-ramps in Russian rubles and Ukrainian hryvnia, and an EXMO Code system enabling commission-free transfers between users — a key feature for peer-to-peer usage. By late 2017 EXMO reported approximately $133 million in daily trading volume and ranked among the top 20 exchanges globally. Co-founder Eduard Bark, who held a 37.51% stake, departed in April 2022, transferring his shares to CEO Serhii Zhdanov — a Ukrainian national, qualified accountant (FCCA), and former Ernst and Young audit professional. Eduard Bark died from cardiac arrest on the night of November 24-25, 2024, at the age of 37, having departed the crypto industry to co-found AllStars Music, a production agency.","heading":"Company Background and Founding History","severity":"low","sources":[{"credibility":2,"name":"EXMO Exits Russia, Sells User Base There to Unnamed Buyer — CoinDesk","type":"news_article","url":"https://www.coindesk.com/business/2022/04/18/crypto-exchange-exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"},{"credibility":3,"name":"Eduard Bark, ex-Co-Founder of EXMO, Dies at 37 — RWATimes","type":"news_article","url":"https://rwatimes.io/articles/coinmarketcap-eduard-bark-ex-co-founder-of-the-exmo-crypto-exchange-dies-at-37-2205836875"},{"credibility":3,"name":"EXMO Exchange Review — BitcoinWiki","type":"other","url":"https://bitcoinwiki.org/wiki/exmo"}]},{"content":"The 18-entity UK sanctions package of May 26, 2026 targeted a range of actors across the Russian crypto-evasion ecosystem. Alongside EXMO, designated entities included HTX (formerly Huobi), Bitpapa IC FZC LLC, Aifory LLC, Rapira Group LLC, and financial entities including Eurasian Savings Bank. The action followed the March 2025 international takedown of Garantex — coordinated by the US Department of Justice, Germany, and Finland — which created a vacuum rapidly filled by successor platforms. Chainalysis reported that HTX processed over $1.5 billion to Russia via Grinex and Garantex connections in the 14 months following the Garantex takedown. Elliptic's February 2026 report named EXMO among five exchanges alleged to be filling Garantex's role, alongside Bitpapa, ABCeX, Rapira, and Aifory Pro. The UK action was coordinated with the EU's broader sectoral restrictions on Russian and Belarusian crypto activity and represents what TRM Labs characterized as the first application of UK banking-style Regulation 17A sanctions against cryptocurrency exchanges at this scope.","heading":"Broader Sanctions Enforcement Context","severity":"high","sources":[{"credibility":2,"name":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/"},{"credibility":2,"name":"Russia-linked Cryptocurrency Services and Sanctions Evasion — Elliptic","type":"research","url":"https://www.elliptic.co/blog/russia-linked-cryptocurrency-services-and-sanctions-evasion"},{"credibility":2,"name":"UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"}]}],"sources_used":[{"credibility":1,"name":"List of Russia Sanctions Designations, 26 May 2026 — GOV.UK","type":"regulatory","url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"},{"credibility":1,"name":"Sanctions Notice: Russia, 26 May 2026 — UK FCDO (PDF)","type":"regulatory","url":"https://assets.publishing.service.gov.uk/media/6a1578669819be865f421cf1/Sanctions_Notice_Russia_26_May_2026.pdf"},{"credibility":1,"name":"Ukraine NSDC State Register of Sanctions — OpenSanctions","type":"regulatory","url":"https://www.opensanctions.org/datasets/ua_nsdc_sanctions/"},{"credibility":2,"name":"UK Designates Huobi, Exmo, Bitpapa, and 11 Other Entities for Russian Crypto Sanctions Evasion — TRM Labs","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":"UK Sanctions Crypto Companies With Russia Ties — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/"},{"credibility":2,"name":"Russia-linked Cryptocurrency Services and Sanctions Evasion — Elliptic","type":"research","url":"https://www.elliptic.co/blog/russia-linked-cryptocurrency-services-and-sanctions-evasion"},{"credibility":2,"name":"UK Sanctions Bitpapa, Exmo and Others Over A7 Links — BanklessTimes","type":"news_article","url":"https://www.banklesstimes.com/articles/2026/05/27/uk-sanctions-bitpapa-exmo-and-others-over-a7-links/"},{"credibility":2,"name":"Five Crypto Exchanges Helping Russia Evade Sanctions, Filling Garantex's Void — The Block","type":"news_article","url":"https://www.theblock.co/post/390709/five-crypto-exchanges-are-helping-russia-evade-sanctions-filling-garantexs-void-elliptic"},{"credibility":2,"name":"UK Moves to Choke Russia's Crypto-Powered Shadow Economy — CryptoTimes","type":"news_article","url":"https://www.cryptotimes.io/2026/05/26/uk-moves-to-choke-russias-crypto-powered-shadow-economy/"},{"credibility":2,"name":"EXMO Exits Russia, Sells User Base There to Unnamed Buyer — CoinDesk","type":"news_article","url":"https://www.coindesk.com/business/2022/04/18/crypto-exchange-exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"},{"credibility":2,"name":"EXMO Exchange Now Says It Lost 6% of Total Crypto Assets in Monday's Hack — CoinDesk","type":"news_article","url":"https://www.coindesk.com/markets/2020/12/22/exmo-exchange-now-says-it-lost-6-of-total-crypto-assets-in-mondays-hack/"},{"credibility":2,"name":"UK Crypto Exchange EXMO Says $4M of Hacked Funds Was Through Poloniex — CoinDesk","type":"news_article","url":"https://www.coindesk.com/markets/2020/12/25/uk-crypto-exchange-exmo-says-4m-of-hacked-funds-was-through-poloniex"},{"credibility":2,"name":"Customer Funds Stolen in Hack of UK Cryptocurrency Exchange EXMO — SiliconANGLE","type":"news_article","url":"https://siliconangle.com/2020/12/22/uk-cryptocurrency-exchange-exmo-hacked-customer-funds-stolen/"},{"credibility":2,"name":"FT: EXMO Director Released From Kidnap After Paying $1 Mln Ransom — CoinTelegraph","type":"news_article","url":"https://cointelegraph.com/news/ft-exmo-director-released-from-kidnap-after-paying-1-mln-ransom"},{"credibility":2,"name":"Director of UK Cryptocurrency Exchange EXMO Kidnapped in Ukraine — CCN","type":"news_article","url":"https://www.ccn.com/head-of-cryptocurrency-exchange-exmo-kidnapped-in-kiev/"},{"credibility":2,"name":"CEO of Major UK-Based Cryptocurrency Exchange Kidnapped in Ukraine — The Hacker News","type":"news_article","url":"https://thehackernews.com/2017/12/crypto-exchange-kidnap.html"},{"credibility":2,"name":"A Bitcoin Exchange's Exec Was Kidnapped Before Hackers Attacked Its Site — Quartz","type":"news_article","url":"https://qz.com/1168060/bitcoin-btc-exchange-exmo-exec-pavel-lerner-kidnapped-before-ddos-attack"},{"credibility":2,"name":"What Does It Cost to Become an FCA-Approved Exchange? EXMO Execs Explain — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2021/01/06/what-does-it-cost-to-become-an-fca-approved-exchange-exmo-execs-explain"},{"credibility":2,"name":"UK Sanctions Russian Crypto Networks — Investing.com","type":"news_article","url":"https://www.investing.com/news/economy-news/uk-sanctions-russian-crypto-networks-to-curb-sanctions-evasion-93CH-4709829"},{"credibility":3,"name":"Eduard Bark, ex-Co-Founder of EXMO, Dies at 37 — RWATimes","type":"news_article","url":"https://rwatimes.io/articles/coinmarketcap-eduard-bark-ex-co-founder-of-the-exmo-crypto-exchange-dies-at-37-2205836875"},{"credibility":3,"name":"EXMO Exchange Review — BitcoinWiki","type":"other","url":"https://bitcoinwiki.org/wiki/exmo"}],"summary":"EXMO Exchange Limited is a London-registered cryptocurrency exchange (Companies House No. 12315005, registered address 60 Cannon Street, London EC4N 6NP) founded in 2013 that historically dominated Eastern European and CIS retail crypto markets. On May 26, 2026, the UK Foreign, Commonwealth and Development Office designated EXMO under the Russia (Sanctions) (EU Exit) Regulations 2019 — one of 18 entities in a Russia sanctions package — applying the most comprehensive sanctions bundle in the package: asset freeze, Trust Services Sanctions, Director Disqualification Sanctions, Internet Services Sanctions, Correspondent Banking Sanctions, and payment processing restrictions. EXMO is accused of providing financial services and economic resources to A7 LLC, a Kremlin-linked network alleged to have moved over $90 billion for Russian military procurement; blockchain analytics firms separately documented more than $19.5 million in direct transactions between EXMO and sanctioned entities including Garantex, Grinex, and Chatex, and found that EXMO's claimed 2022 Russia exit was contradicted by shared custodial wallet infrastructure between EXMO.com and its Russia-facing successor EXMO.me.","timeline":[{"date":"2013-01-01","event":"EXMO Exchange founded by Ivan Petukhovsky and Pavel Lerner, targeting Eastern European and CIS retail crypto users.","source":"BitcoinWiki / CoinDesk","source_url":"https://bitcoinwiki.org/wiki/exmo"},{"date":"2017-12-26","event":"EXMO managing director Pavel Lerner kidnapped in Kyiv, Ukraine. Released approximately three days later after alleged payment of approximately 102 BTC (~$1-2 million) in ransom. Ukrainian police investigation opened; no perpetrators publicly charged.","source":"CoinTelegraph / Financial Times / CCN","source_url":"https://cointelegraph.com/news/ft-exmo-director-released-from-kidnap-after-paying-1-mln-ransom"},{"date":"2020-01-01","event":"UK FCA contacts EXMO directly regarding upcoming KYC and verification requirements for crypto asset businesses.","source":"CoinDesk","source_url":"https://www.coindesk.com/policy/2021/01/06/what-does-it-cost-to-become-an-fca-approved-exchange-exmo-execs-explain"},{"date":"2020-12-01","event":"EXMO receives UK FCA Temporary Registration as a cryptoasset business, one of approximately 95 firms given temporary authorization.","source":"CoinDesk","source_url":"https://www.coindesk.com/policy/2021/01/06/what-does-it-cost-to-become-an-fca-approved-exchange-exmo-execs-explain"},{"date":"2020-12-21","event":"EXMO hot wallets compromised in security breach. Approximately 6% of total crypto assets stolen, including 306.99 BTC valued at approximately $7.2 million. Exchange suspends all deposits and withdrawals. FCA subsequently contacts EXMO to discuss prevention measures.","source":"CoinDesk","source_url":"https://www.coindesk.com/markets/2020/12/22/exmo-exchange-now-says-it-lost-6-of-total-crypto-assets-in-mondays-hack/"},{"date":"2022-04-18","event":"EXMO announces sale of Russian, Belarusian, and Kazakhstani operations (~1 million users, associated software and IP) to an unnamed Russian software development company. Kazakhstan-registered EXMO RBK LTD. (EXMO.me) created to serve those markets. Co-founder Eduard Bark departs and transfers 37.51% stake to CEO Serhii Zhdanov.","source":"CoinDesk","source_url":"https://www.coindesk.com/business/2022/04/18/crypto-exchange-exmo-exits-russia-sells-user-base-there-to-unnamed-buyer"},{"date":"2024-11-25","event":"EXMO co-founder Eduard Bark dies from cardiac arrest at age 37.","source":"RWATimes","source_url":"https://rwatimes.io/articles/coinmarketcap-eduard-bark-ex-co-founder-of-the-exmo-crypto-exchange-dies-at-37-2205836875"},{"date":"2025-05-01","event":"UK FCDO first designates A7 LLC under Russia sanctions for supporting Russia's war in Ukraine. A7 LLC is the entity to which EXMO is later alleged to have provided financial services.","source":"Chainalysis","source_url":"https://www.chainalysis.com/blog/uk-sanctions-crypto-entities-russian-trade-blockade-evasion-may-2026/"},{"date":"2025-07-01","event":"Ukraine imposes sanctions on EXMO through the NSDC State Register of Sanctions, targeting the Kazakhstan-registered EXMO entity. First national sanctions designation against EXMO.","source":"TRM Labs","source_url":"https://www.trmlabs.com/resources/blog/uk-designates-huobi-exmo-bitpapa-and-11-other-entities-for-russian-crypto-sanctions-evasion"},{"date":"2026-02-01","event":"Elliptic publishes report identifying EXMO among five exchanges filling Garantex's void in Russia-linked sanctions evasion. Documents over $1 million in direct EXMO.me transactions with sanctioned Garantex and shared hot wallet infrastructure between EXMO.com and EXMO.me.","source":"Elliptic / The Block","source_url":"https://www.elliptic.co/blog/russia-linked-cryptocurrency-services-and-sanctions-evasion"},{"date":"2026-05-26","event":"UK FCDO designates EXMO Exchange Limited under Russia (Sanctions) (EU Exit) Regulations 2019. Sanctions bundle includes asset freeze, Trust Services Sanctions, Director Disqualification Sanctions, Internet Services Sanctions, Correspondent Banking Sanctions, and payment processing restrictions. Designation cites provision of financial services and economic resources to A7 LLC. Most comprehensive sanctions package applied to any entity in the 18-entity May 2026 Russia action.","source":"UK GOV.UK / FCDO","source_url":"https://www.gov.uk/government/publications/list-of-russia-sanctions-designations-26-may-2026"}]},"v":1}