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On February 10, 2026, the UK’s Financial Conduct Authority (FCA) published its legal proceedings, which it had filed on October 21, 2025, against Panama-incorporated crypto exchange HTX (formerly Huobi Global) for illegal, continued promotion of services to UK consumers.
The FCA also outlined its request to social media companies to block HTX’s social media accounts to UK-based consumers and the further removal of HTX applications from the Google Play and Apple stores in the UK.
The publication follows the High Court’s decision on February 4, 2026, which granted the FCA permission to serve proceedings outside the UK, reinforcing that global firms targeting UK users must comply with domestic regulations governing financial promotions.
This decision paves the way for the FCA to file legal proceedings against HTX in Panama, where it is registered, and for the regulator to pursue further extraterritorial regulatory actions against the “persons unknown” wherever they may be found, be it in Panama, Seychelles or elsewhere.
The case
The FCA’s claim centres on a breach of Section 21 of the Financial Services and Markets Act (FSMA) 2000, which prohibits unauthorised financial promotion, and on the FCA’s Financial promotion rules for cryptoassets, which came into force in October 2023.
Legal proceedings were launched after HTX continued to publish financial promotions on its website and on social media platforms (such as TikTok, X, Facebook, Instagram and YouTube) despite multiple warnings from the regulator.
The FCA further alleged that HTX operates an opaque organisational structure, purposefully obscuring the identities of its owners and operators, noting that repeated outreach attempts by the regulator have gone ignored.
Since the issue of the proceedings, HTX has taken steps to restrict new UK customers from registering an account; however, according to the FCA, it has not given the regulator any assurance that the changes will be permanent.
Moreover, existing UK users remain able to log in and access unlawful financial promotions. According to the FCA’s suit, an FCA employee was able to buy cryptoassets using a UK IP address and driving licence.
Warning shot
Under the FCA’s cryptoasset financial promotions regime, there are four lawful routes to communicate cryptoasset financial promotions to UK consumers:
- The promotion is issued by an FSMA-authorised firm.
- The promotion is made by an unauthorised person but approved by an FSMA-authorised firm with the relevant permissions (a Section 21 approver).
- The promotion is communicated by (or on behalf of) an unauthorised cryptoasset business registered with the FCA under the Money Laundering Regulations (MLRs), relying on the Article 73ZA exemption in the Financial Promotion Order (FPO).
- The promotion otherwise satisfies conditions of an applicable exemption in the FPO.
Without a UK-authorised presence, overseas firms therefore face limited options when seeking to market crypto products to UK consumers. These routes are set to tighten further under the forthcoming FSMA 2000 cryptoasset authorisation regime, set to commence in October 2027, when firms currently relying on an FCA-authorised Section 21 approver to sign off promotions will also require FCA authorisation themselves.
By targeting a platform with measurable UK engagement — FCA data identified HTX as the sixth most-accessed virtual asset service provider in the UK in 2023 — the regulator ensures the case carries industry-wide resonance. Enforcement against a visible, recognised exchange sends a solid market signal: scale and offshore status do not insulate firms from UK rules.
Vixio’s verdict
These proceedings function as precedent-setting, marking a notable inflexion point in the evolution of UK financial regulation.
From a micro perspective, the case underscores the expansive scope of what amounts to a financial promotion, spanning websites, apps and social media, and highlights the FCA’s readiness to identify and pursue breaches proactively. The FCA’s approach is particularly noteworthy as well. By adopting a “whole-of-chain” enforcement approach that moves beyond warnings to formal legal action and, where necessary, pursues distribution restrictions and constraints on promotional channels, the regulator is reinforcing the credibility of its regulatory framework to industry.
From a macro perspective, the action acutely signals the expansion of extraterritorial regulatory reach in financial markets. It reflects the erosion of assumptions that globalised corporate structures can insulate firms from local enforcement. Wider regulatory trajectory supports this shift; under the Digital Markets, Competition and Consumers Act, the Competition and Markets Authority (CMA) has been granted enhanced investigative powers that extend to overseas entities where UK markets are affected. Likewise, the European Union’s European Market Infrastructure Regulation (EMIR) applies to non-EU entities if a contract has a "direct, substantial and foreseeable effect" in the EU, or if the contract is designed to evade EU regulations.
Taken together, these approaches demonstrate that regulators globally are reinforcing the principle that market impact, rather than place of incorporation, determines supervisory interest.
This marks the first time the FCA has initiated High Court proceedings against a cryptoasset firm under its financial promotions regime, representing a clear escalation in its enforcement posture. It signals a more assertive approach to supervising cross-border digital finance, particularly where offshore entities and complex corporate arrangements are involved. The message to the crypto sector, which has often relied on layered holding structures, diffuse operating models and fluid brand identities, is clear: jurisdictional complexity will not operate as a shield.
