Regulation · Enforcement
FCA Takes HTX to Court: The UK's First Crypto Promotion Enforcement Action
In February 2026, the Financial Conduct Authority announced High Court proceedings against HTX, formerly known as Huobi, for repeatedly marketing cryptocurrency services to UK consumers without complying with the UK's financial promotions regime. It is the first enforcement action of its kind brought by the FCA against a cryptoasset firm for unlawful marketing.
- Proceedings filed in the High Court's Chancery Division in October 2025
- HTX continued promoting services despite warnings dating back to October 2023
- FCA seeks an injunction and a formal declaration of breach
- Action covers promotions on X, TikTok, Instagram, Facebook, YouTube and others
Background
The financial promotions regime for cryptoassets
From 8 October 2023, any firm marketing cryptoasset services to UK consumers — including firms based entirely overseas — became subject to the FCA's financial promotions rules. These include requirements such as the FCA's financial promotions rules that include cooling-off requirements for first-time investors. Those rules require that marketing communications be fair, clear and not misleading.
Under Section 21 of the Financial Services and Markets Act 2000, communicating a financial promotion to UK consumers is only lawful through four defined routes: the promotion is made by an FCA-authorised firm; it is made by an unauthorised firm but has been approved by an authorised firm; it is made by a cryptoasset business registered with the FCA under anti-money-laundering regulations; or a specific exemption applies.
Promoting cryptoassets to UK consumers outside these routes is a criminal offence under FSMA. The FCA made this clear before the regime came into force and wrote to a large number of firms in the period July to September 2023 to set out its expectations and ask how each firm planned to comply.
What this means
The HTX case is the FCA's clearest signal yet that it will pursue overseas exchanges actively promoting to UK consumers — not just those with a UK base. Geo-blocks and disclaimers are not sufficient protection. This is context, not advice.
The case against HTX
What the FCA alleges
HTX, the exchange formerly known as Huobi and incorporated in Panama, did not respond meaningfully to the FCA's pre-regime communications. On the day the financial promotions rules came into force, 8 October 2023, the FCA placed HTX on its Warning List — a public register of firms the regulator believes may be operating or marketing without authorisation.
Despite this, the exchange continued to publish promotions accessible to UK consumers across its website and across multiple social media platforms. The FCA's particulars of claim detail examples including website tutorials suggesting users could "buy Bitcoin in a minute" and promotions for high-risk crypto lending products featuring language and imagery the FCA considered inconsistent with required disclosure standards.
An FCA employee was able to purchase and trade cryptoassets on HTX after verifying their identity with a UK driving licence, demonstrating that no effective geographic restrictions had been put in place. In October 2024, more than a year after the regime came into force, HTX wrote to the FCA claiming it had stopped targeting UK customers. The FCA responded by pointing out that promotions accessible to UK consumers — regardless of whether they are specifically targeted at UK users — still fall within the regime's scope under Section 21(3) of FSMA.
The FCA recorded approximately 4.6 million visits to HTX from UK-based users in 2023 and 13,000 visits in the period to the end of October 2024. The exchange's website remained accessible and promotional in character throughout.
This enforcement action establishes a precedent: the FCA's financial promotions regime applies wherever UK consumers can access a service, regardless of where the firm is incorporated.
Legal proceedings
How the case has progressed
The FCA filed proceedings in the High Court's Chancery Division on 21 October 2025, naming Huobi Global S.A. (Panama) as the primary defendant and including a class of unnamed persons — described in the claim as those who own, operate or control the HTX exchange and its associated websites, applications and social media accounts — up to and including 31 October 2028.
Because HTX operates with an opaque organisational structure and its owners' identities were not fully established, the FCA also named persons unknown as defendants. This is an established legal mechanism used where a controlling entity is difficult to formally identify but enforcement action is nonetheless warranted.
On 4 February 2026, Deputy Master Dovar granted the FCA permission to serve the proceedings outside the jurisdiction and by alternative means. This was a significant procedural step. It means HTX's offshore incorporation in Panama does not prevent the proceedings from advancing, and that service of court documents through electronic and online channels is deemed legally effective.
The FCA announced the proceedings publicly on 10 February 2026. At that date the case remained at the pre-trial stage; no judgment had been issued. The FCA is seeking an injunction preventing the defendants from promoting cryptoasset services to UK consumers in breach of the financial promotions rules, together with a formal declaration that the defendants are in breach.
FCA response measures
Steps taken alongside the proceedings
Alongside the court action, the FCA took a number of steps to limit HTX's reach within the UK. The regulator requested that major social media platforms — including X, TikTok, Meta's Facebook and Instagram, and YouTube — block HTX's accounts for UK-based users. It also requested that Google and Apple remove HTX's applications from their UK app stores.
Following the filing of the High Court proceedings, HTX took steps to restrict new UK customers from registering on the exchange. However, existing UK users remained able to log in and access promotional material the FCA considered unlawful. The exchange offered no assurance that the restrictions on new registrations would be maintained permanently.
HTX remains on the FCA's Warning List. Consumers who have funds held with or have experienced problems with a firm on the Warning List do not have access to the Financial Ombudsman Service and are not covered by the Financial Services Compensation Scheme.
Significance
What this case means for the market
The FCA's action against HTX is the first time the regulator has used civil court proceedings specifically to enforce the cryptoasset financial promotions regime against an offshore exchange. This regime sits within the UK's new cryptoasset regulatory framework under FSMA, which extends the FCA's oversight significantly beyond financial promotions. Previous enforcement tools under this regime — warning list placement, website takedown requests, compliance letters — stopped short of formal litigation.
The FCA has been explicit that the majority of firms in scope have made genuine efforts to comply with the regime since it came into force. The HTX case is described by the regulator as standing in contrast to that pattern of cooperative engagement.
The case also establishes a practical precedent on extraterritorial reach. The court's grant of permission to serve proceedings outside the UK's jurisdiction, and by alternative means, illustrates that offshore incorporation does not provide a reliable barrier to UK regulatory enforcement where a firm's promotions are accessible to UK consumers.
For UK users of unregistered exchanges, the principal practical point is that there is no regulatory backstop. The FCA's warning list exists to help consumers identify firms that may be operating outside authorised parameters, and checking an exchange's status on the public register before using it remains a straightforward step any UK crypto user can take.
How to check a firm's status
The FCA register and warning list
The FCA maintains two relevant public lists that UK users can consult directly. The Financial Services Register lists all firms authorised or registered by the FCA, including the approximately 50 cryptoasset businesses registered under the anti-money-laundering framework. The Warning List identifies firms the FCA believes may be providing financial services or products to UK customers without authorisation.
These resources are available at fca.org.uk and require no account or login to access. For reference on what a properly registered exchange looks like in practice, see our guide to FCA-registered exchanges that comply with UK promotional rules. Searching for an exchange or firm by name will return its current regulatory status or, if applicable, its warning list entry.
Firms that appear on the warning list are not necessarily subject to active proceedings, but their presence on the list reflects the FCA's view that consumers dealing with them may not have access to the protections available when using authorised firms.
Market impact snapshot
Several offshore exchanges quietly tightened UK geo-restrictions following the HTX action, reflecting the deterrent effect of high-profile enforcement.
Next
Further research and market analysis
Additional research notes examine the UK's evolving regulatory framework, exchange operations, and the development of GBP-denominated crypto markets.