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Woofun AI reports that the Council of the European Union has formally designated HTX, legally identified as Huobi Global SA, alongside 13 other cryptocurrency and payment service providers for immediate transaction bans under the expanded Russia sanctions framework. These entities have been added to Annex XLV of the regulatory regime, marking a targeted escalation against platforms deemed to facilitate sanctions evasion. The move isolates specific operators rather than imposing a blanket prohibition on all crypto activity within the jurisdictions where they are based.
The designated list encompasses a diverse array of operators, including EXMO, BitPapa, and Rapira, alongside three services connected to the A7 cross-border payments network. These 14 platforms are geographically distributed across six distinct jurisdictions: Georgia, Panama, the United Arab Emirates, the Marshall Islands, Kyrgyzstan, and Belarus. This distribution highlights the fragmented nature of the entities targeted, which operate from locations often cited as having weaker regulatory oversight. The inclusion of these specific firms underscores the EU’s focus on disrupting financial channels that preserve access for Russian actors, rather than penalizing entire national economies or the broader cryptocurrency sector within those regions.
The legal foundation for these prohibitions is established in Council Regulation (EU) 2026/1848, which classifies the inclusion of these entities in Annex XLV as a restrictive measure rather than a criminal conviction against the companies or their executives. This regulation mandates a comprehensive ban on both direct and indirect transactions with the listed entities once the specified effective dates are reached. The scope of this prohibition extends beyond simple bank transfers to named platforms; it explicitly covers payment processing, commercial arrangements, and transactions routed through intermediaries. Crucially, the ban applies whenever the sanctioned entity remains the real counterparty or the ultimate beneficiary of the transaction, thereby closing loopholes that might otherwise allow for indirect engagement.
Woofun AI data shows that the regulatory framework deliberately avoids establishing a universal asset freeze on every wallet that has previously interacted with the listed services. Instead, the entities are subject to a transaction prohibition annex, which does not mandate a fixed blockchain-screening distance. The regulation does not stipulate that every wallet located three or five transfers away from a listed platform must be automatically blocked. Regulated businesses are still required to implement controls capable of identifying indirect exposure, but the assessment of such exposure depends on the specific transaction, the counterparties involved, and the available evidence, rather than a standardized number of blockchain 'hops.' This approach places the burden of due diligence on financial institutions to evaluate risk on a case-by-case basis.
A limited withdrawal window is provided 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 authorize 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. This authorization is not automatic and is subject to several conditions, including a maximum duration of three months. Customers cannot 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 required supporting evidence will vary depending on the competent sanctions authority in the relevant member state.
The regulatory package also introduces a new legal tool under Article 5bc, which 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 creates the legal power for such a ban, while Annex LVII serves as the schedule where any country placed under this restriction would be named. Currently, Annex LVII contains only its title and no jurisdictions, meaning the mechanism exists in law but has not yet been activated against any country. Coindoo previously analyzed how this provision in the 21st sanctions package could cut crypto access for Russia’s allies, and the final regulation confirms this structure: Article 5bc supplies the authority, while Annex LVII identifies the target jurisdiction.
The latest sanctions package intensifies pressure on the A7 payments network, although 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, which 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 these restrictions by adding A7 Nigeria, A7 Africa, and PilotFinance to the transaction-ban list.
Additionally, the Council announced four new designations connected to the cross-border A7 network, including its links to Africa. These measures reflect a continued effort to dismantle the infrastructure supporting illicit cross-border payments, particularly those linked to regions with known sanctions evasion activities.
It is critical to distinguish these sanctions measures from the Markets in Crypto-Assets (MiCA) regulation, despite their simultaneous timing near the end of the MiCA transition period. MiCA governs the authorisation, organisation, and conduct of crypto-asset service providers operating in the EU market, whereas 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 permit a regulated company to transact with a sanctioned counterparty. The 14 listings are sanctions measures and should not be conflated with ordinary MiCA licensing or enforcement cases, as they stem from distinct legal objectives and regulatory authorities.
The July legal acts also broaden existing ownership and management restrictions under two separate sanctions regimes. 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 this restriction to EU companies providing other crypto-asset services defined under MiCA.
A parallel restriction applies under the separate Belarus sanctions framework: since March 26, 2025, Belarusian nationals and natural persons residing in Belarus have 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 this 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, as one governs dealings with named foreign entities while the other governs who may own, control, or manage certain EU-incorporated crypto businesses.
Enforcement of these regulations is handled by national authorities across the 27 member states, with investigations, prosecutions, and penalties determined locally. Directive (EU) 2024/1226 requires member states to treat intentional violations and circumvention of EU restrictive measures as criminal offences in specified circumstances. While the directive creates common minimum rules, it does not impose an identical sentence or corporate penalty for every violation in all member states.
The consequences depend on factors including intent, the value and nature of the transaction, the role of intermediaries, and the national legislation implementing the directive. 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, signaling a potential escalation in the EU’s strategy to isolate financial networks supporting Russia and its allies.