HTX, the crypto exchange tied to Justin Sun, is now under UK sanctions. Blockchain intelligence firm TRM Labs reports that the exchange has been rotating its hot wallets across multiple blockchains — a technique that makes it difficult for address-list screening to keep pace with sanctions compliance.
The sanctions
The UK government added HTX to its sanctions list this week. The exact date of the designation wasn't disclosed, but the move freezes any assets HTX holds in the UK and bars British firms from doing business with the exchange. HTX is one of the larger exchanges still operating without a major Western license, and its association with Sun — who has faced regulatory scrutiny in the US and elsewhere — has long raised red flags.
How wallet rotation works
TRM Labs, a blockchain analytics firm that works with governments and financial institutions, published a report detailing HTX's wallet activity. The exchange isn't just using a handful of static addresses. Instead, it regularly shifts funds between fresh wallets across different blockchains — Ethereum, Tron, BNB Chain, and others. Each new address gets used for a short period before the next rotation.
This isn't a one-off. TRM says the pattern has been ongoing for months. The goal appears straightforward: keep the money moving so that any blacklist of addresses becomes outdated almost as soon as it's published.
Compliance gaps
Sanctions screening typically relies on static address lists. Regulators and exchanges compile known bad addresses and check transactions against them. But when an exchange churns through dozens of wallets across multiple chains, the list can't keep up. By the time a new address is flagged, HTX has already moved on to the next one.
TRM's report doesn't claim that HTX is actively trying to evade sanctions — it just describes what the data shows. But the timing isn't great for the exchange. The UK sanctions came into effect just as the wallet rotation pattern was becoming more pronounced.
The UK's Office of Financial Sanctions Implementation hasn't commented on the TRM findings. For now, the question is whether other exchanges will adopt similar tactics — and whether regulators can adapt their screening methods fast enough.
