On 26 May 2026, the UK Foreign, Commonwealth and Development Office published the Russia Sanctions Notice of 26 May 2026, designating 18 cryptocurrency exchanges under The Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855). The designations are enforcement-stage measures; affected entities are immediately subject to UK asset freeze obligations and a prohibition on making funds or economic resources available to them. This is the first UK sanctions package to target cryptocurrency exchanges directly under the Russia regime.
The legal basis for the designations is Regulation 6 of S.I. 2019/855, which permits designation of persons involved in destabilising Ukraine or undermining its territorial integrity, sovereignty, or independence. The designated entities include HUOBI GLOBAL S.A., the registered operator of the HTX exchange; OFSI confirmed in updated guidance that HTX is subject to UK financial sanctions by reason of its Huobi ownership. Three Georgian-registered companies operating Russia-focused exchanges were also designated on the basis of involvement in the A7 network, a Russia-linked procurement and financial infrastructure used to channel funds to Russian state entities.
UK-based banks, payment service providers, and FCA-registered cryptoasset businesses must update counterparty screening lists against the UK Sanctions List as amended on 26 May 2026. Any person who makes funds or economic resources available to a designated person without an OFSI licence commits an offence under Regulation 13A of S.I. 2019/855. Firms with existing settlement positions, exchange relationships, or custody arrangements involving HTX or associated Huobi entities must obtain specific legal advice on whether ongoing performance constitutes a prohibited dealing and whether an OFSI specific licence under Regulation 64 is required.
OFSI has not published a general licence covering pre-existing exchange-to-exchange settlement obligations, leaving counterparties to apply for specific licences under Regulation 64 of S.I. 2019/855. The UK Government stated the A7 network was responsible for channelling over USD 1.5 billion into Russian state entities, and further designation rounds targeting related infrastructure remain possible. Counterparties in third countries that provide services to designated exchanges without a relevant licence may themselves become subject to secondary designation consideration.
Licentium advises cryptoasset businesses, payment institutions, and financial intermediaries on UK and EU financial sanctions compliance, OFSI licensing, and counterparty screening obligations. We may advise on this matter or refer you to our partner network for sanctions counsel. Work we undertake includes sanctions risk assessments, OFSI licence applications, FCA cryptoasset registration compliance, and cross-jurisdictional sanctions gap analysis.