The European Union’s transaction bans now apply to 11 non-EU payment or crypto-asset service providers, including HTX and EXMO, following the postponement of the effective date set out in the EU’s July regulation on sanctions against Russia.
The entities concerned are Rapira; Aifory Pro, operated by Sooty Ltd; ABCeX, linked in the legal annex to Nueva Cryptologia SAS de CV; WhiteBird; NoOnecrypto Inc.; Tradex, linked to Brightum LLC; Monease Ltd; BitPapa; Exnode and Exnode Pay, linked to Arvix; HTX, identified as Huobi Global SA; and EXMO Ltd.
Regulation (EU) 2026/1848 added these 11 names to Part A of Annex XLV, with an application date of August 23. The annex describes them as third-country credit, financial, crypto-asset or payment service providers that significantly undermine the objective of the EU’s sanctions against Russia.
Article 5ad prohibits EU natural and legal persons from carrying out transactions, directly or indirectly, with the listed entities and with persons acting on their behalf or under their instructions. The regulation provides for exceptions and allows national authorities, under certain conditions and within specified time limits, to authorize strictly limited withdrawals or account closures for eligible European users.
This measure does not automatically constitute a conventional asset freeze. An analysis of HTX’s listing published by EU Today in July explained the distinction: a transaction ban restricts dealings with a specifically designated entity under the applicable article, whereas an asset freeze uses a different legal mechanism to immobilize funds and prevent resources from being made available.
For banks and crypto companies, the effective date triggers practical compliance checks. They must verify legal names and known aliases, identify payments or services involving the providers, determine whether an intermediary is acting on behalf of a listed platform, and establish whether a transaction falls under an exception or requires authorization from a national authority.
