EU Names HTX and 13 Crypto Services for Transaction Bans Under 21st Sanctions Package
Key Takeaways
- •The EU’s 21st Russia sanctions package prohibits transactions with 14 named crypto and payment services, including HTX, EXMO, BitPapa and Rapira.
- •Three services linked to the A7 cross-border payments network face restrictions from August 13, while the other 11 are covered from August 23.
- •The transaction ban applies only to the listed legal entities and does not impose a blanket prohibition on crypto trading or on all firms in the six associated countries.
- •Certain existing customers may seek national-authority approval to withdraw funds or close accounts, but there is no automatic withdrawal window.
- •The package creates a legal mechanism for future countrywide crypto-service bans, but no jurisdiction has yet been added to the relevant annex.

The Council of the European Union has designated 14 cryptocurrency and payment services — including HTX, legally identified as Huobi Global SA — for transaction prohibitions under its 21st sanctions package against Russia. The restrictions take effect in two phases: three services linked to the A7 cross-border payments network face restrictions from August 13, while the remaining 11 follow on August 23.
HTX, formerly known as Huobi, has ranked among the world's largest cryptocurrency exchanges by trading volume, which gives the designation broader resonance across the digital-asset industry even though the measure is limited to transactions with the named legal entity. The full list, published in Council Regulation (EU) 2026/1848, adds the entities to Annex XLV of the EU's Russia sanctions framework. Alongside HTX, the named platforms include EXMO, BitPapa, Rapira and several smaller crypto, payment and exchange operators. According to the Council of the European Union, the 14 platforms are based across Georgia, Panama, the United Arab Emirates, the Marshall Islands, Kyrgyzstan and Belarus.
The measure targets only the entities named in the legal act. It is not a general ban on cryptocurrency trading, every non-EU exchange, or every crypto company operating from those six jurisdictions.
Scope of the Transaction Ban
The regulation prohibits both direct and indirect transactions with the listed entities once the relevant effective date arrives. This extends beyond a bank transfer sent directly to a named platform. It can also cover payment processing, commercial arrangements, and transactions routed through intermediaries where the sanctioned entity remains the real counterparty or beneficiary.
The measure is not equivalent to a universal asset freeze on every wallet that has previously interacted with one of the services. Similarly, the regulation does not establish a fixed blockchain-screening distance. It does not mandate that every wallet three or five transfers away from a listed platform be automatically blocked. Regulated businesses still need controls capable of identifying indirect exposure, but the assessment depends on the transaction, counterparties, and available evidence rather than a standard number of blockchain "hops."
The Council states that the listed entities significantly frustrate the purpose of EU sanctions or help preserve financial channels used by Russia. Inclusion in Annex XLV constitutes a restrictive measure, not a criminal conviction against a company or its executives.
Existing Customer Withdrawal Provisions
The regulation provides a limited route for certain existing customers who held funds with an entity added to Annex XLV on or after July 24, 2026. A national competent authority may authorise a transaction strictly necessary to withdraw funds or close an account belonging to an EU, European Economic Area, or Swiss national, or a person holding a temporary or permanent residence permit in one of those jurisdictions.
Several conditions apply:
- The transaction must end the customer's operations, contracts, or other arrangements with the listed entity.
- The request for authorisation must be submitted within three months of the date the ban begins for that entity.
- Funds must be transferred to an EU financial or credit institution, or to a qualifying institution controlled by an EU financial institution.
- Any authorisation may be granted for a maximum period of three months.
This is not an automatic withdrawal window. Customers should not assume that trading, transfers, or withdrawals can continue after August 13 or August 23 simply because an account was opened before the restrictions took effect. The application procedure and supporting evidence will depend on the competent sanctions authority in the relevant member state.
Country-Level Crypto Ban Mechanism Established
The package also creates a legal tool that could eventually extend beyond individually named platforms. New Article 5bc allows the EU to prohibit direct and indirect transactions with crypto-asset service providers and exchange or transfer platforms established in an entire non-EU country.
The Council can designate a country when it determines that the jurisdiction has systematically and persistently failed to prevent crypto services from being used to frustrate EU sanctions. Article 5bc establishes the legal power, while Annex LVII serves as the schedule in which any country placed under that restriction would be named.
Annex LVII currently contains only its title and no jurisdictions. The mechanism therefore exists in law but has not been activated against any country. Coindoo previously examined the proposal in its analysis of how the EU's 21st sanctions package could cut crypto access for Russia's allies.
The six countries associated with the 14 listed platforms have not been placed under a blanket jurisdiction-wide prohibition.
A7A5 Stablecoin Was Already Restricted
The latest package increases pressure on the A7 payments network, but it did not introduce the EU's first restriction involving the A7A5 stablecoin. The EU had already prohibited transactions involving A7A5 through its 19th sanctions package in October 2025. That package also targeted the stablecoin's developer, its Kyrgyz issuer, and the operator of a platform where significant A7A5 volumes were traded.
The 21st package extends the restrictions around the network by adding A7 Nigeria, A7 Africa, and PilotFinance to the transaction-ban list. The Council separately announced four new designations connected to the cross-border A7 network, including its links to Africa.
Sanctions and MiCA: Distinct Frameworks
The measures arrived shortly after the end of the maximum MiCA transition period, but the two frameworks should not be treated as the same regulatory action. MiCA governs the authorisation, organisation, and conduct of crypto-asset service providers operating in the EU market. The sanctions framework determines whether transactions with particular companies, people, services, or jurisdictions are prohibited for foreign-policy and security reasons.
A crypto provider was not added to Annex XLV simply because it lacked a MiCA licence. Equally, holding an EU authorisation does not allow a regulated company to transact with a sanctioned counterparty. The 14 listings are sanctions measures and should not be described as ordinary MiCA licensing or enforcement cases.
Expanded Ownership Restrictions for Russian and Belarusian Nationals
The July legal acts also broaden existing ownership and management restrictions under two separate sanctions regimes.
Russian nationals and residents: Since January 18, 2024, Russian nationals and natural persons residing in Russia have generally been prohibited from directly or indirectly owning, controlling, or holding positions in the governing bodies of EU companies that provide crypto-wallet, crypto-account, or custody services. From August 25, 2026, Regulation (EU) 2026/1848 extends that restriction to EU companies providing other crypto-asset services defined under MiCA.
Belarusian nationals and residents: A parallel restriction applies under the separate Belarus sanctions framework. Since March 26, 2025, Belarusian nationals and natural persons residing in Belarus have generally been prohibited from owning, controlling, or holding governing-body positions in EU companies providing crypto-wallet, crypto-account, or custody services. From August 25, 2026, Council Regulation (EU) 2026/1846 extends that ban to EU companies providing the wider range of crypto-asset services covered by MiCA.
These ownership restrictions are legally distinct from the transaction bans on the 14 platforms. One governs dealings with named foreign entities; the other governs who may own, control, or manage certain EU-incorporated crypto businesses.
Penalties Under National Law
EU regulations apply directly in all member states without the need for national implementing legislation, but investigations, prosecutions, and penalties are handled by national authorities. Directive (EU) 2024/1226 requires member states to treat intentional violations and circumvention of EU restrictive measures as criminal offences in specified circumstances. The directive creates common minimum rules but does not impose an identical sentence or corporate penalty across all 27 member states.
Consequences depend on factors including intent, the value and nature of the transaction, the role of intermediaries, and the national legislation implementing the directive.
Practical Considerations for EU Users and Crypto Firms
- Confirm the legal entity. A brand may operate through several companies, while the sanctions annex identifies particular legal names and aliases.
- Check the effective date. Restrictions begin on August 13 for three A7-linked services and August 23 for the other 11 platforms.
- Do not assume an intermediary makes a transaction lawful. The prohibition covers indirect as well as direct dealings.
- Review national guidance before attempting a withdrawal. Closing an existing account may require authorisation.
- Keep screening and transaction records. Businesses should be able to explain how counterparties, beneficiaries, and payment routes were checked.
- Separate sanctions checks from licensing checks. MiCA authorisation does not override a transaction prohibition.
The immediate effect of the package is the scheduled cutoff of transactions with the 14 named crypto services. The country-level mechanism could produce a much wider restriction in the future, but only if the Council formally adds a jurisdiction to Annex LVII. Until that happens, the new power remains available but unused.
This article is provided for informational purposes only and does not constitute legal, regulatory, or financial advice. Individuals and businesses affected by EU sanctions should review the official regulations, guidance from their national competent authority, and advice from a qualified sanctions professional before making or attempting a transaction.