This page was compiled by Blockworks using publicly available information reviewed consistent with the TTF, possibly together with information supplied directly by the project where provided. Project-supplied information may correct, update, or supplement the public record, and may not be independently verifiable; Blockworks presents it as provided and does not verify or warrant its accuracy. Because this page depends on what has been disclosed, it may be incomplete — certain categories are more likely to include undisclosed items (e.g., non-announced fundraisings or material relationships), and the absence of an entry should not be read as confirmation that none exists.
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
HTX DAO issues the HTX token and describes itself as a community governance organization built by community members, early contributors and global advisors, supported by HTX Exchange and the TRON ecosystem. It aims to give users of the HTX exchange, formerly Huobi, a say in platform matters such as listings and ecosystem funding. HTX replaced the exchange's earlier Huobi Token (HT) through a voluntary HT to HTX conversion that began in January 2024. The HTX DAO disclaimer states that HTX has no inherent utilities, carries no claim on any real world or financial assets and has no fundamental distinction from a typical meme coin.
(Source: HTX DAO Whitepaper, The Block, A Deeper Look at the HT to HTX Token Switcheroo)
HTX DAO is not a legal entity and has no disclosed operating budget of its own. Its main economic support comes from the HTX exchange, which as an ecosystem partner provides 50% of its quarterly revenue to buy back and burn HTX. HIP-007, proposed in April 2025, set up a pilot Development Fund of 10,000 to 100,000 USDT or equivalent HTX from project reserved funds and community donations. A July 2026 amendment proposed the HTX DAO Genesis Program for AI and Web3 builders. The staking product launched in March 2026 pays rewards from HTX DAO ecosystem development reserves.
(Source: Bitcoin.com News, HTX Quarterly Burn Hits a New High, HTX DAO Whitepaper, HIP-007 HTX DAO Development Fund, HIP-007 Amendment Genesis Program, HTX DAO Staking Launch)
HTX is a TRC-20 token on TRON with bridged versions on Ethereum and BNB Smart Chain. Holders discuss proposals on the HTX DAO forum and vote onchain on TRON at one HTX per vote. The whitepaper states that approved proposals are presented to the platform, which reviews them against its compliance standards and implements them only if the platform approves. Each quarter HTX DAO announces a buyback and burn funded by HTX exchange revenue, with burned tokens sent to the TRON black hole address. Liquidity pledges of HTX and TRX on SUN.io are sent to an ecosystem liquidity address that resembles a zero address.
(Source: HTX DAO Whitepaper, Forklog, HTX DAO Approves Initial Community Governance Proposals, Tronscan, HTX Token)
HTX is used for governance votes at one token per vote, and staked HTX (sHTX) also votes at one sHTX per vote. Since April 1, 2026 HTX is the only fee-discount token on the HTX exchange. Holders can stake HTX on TRON through the HTX DAO site to earn rewards. HTX carries no right to exchange revenue, and the whitepaper disclaimer states it has no inherent utilities.
(Source: HTX DAO Staking Launch, Bolsamania, HTX DAO Completes Q1 2026 HTX Burn, HTX DAO Whitepaper)
Governance depends on the HTX exchange. Proposals are implemented only after the platform's compliance review, and under the March 2025 temporary rules, proposals that met the forum threshold were reviewed jointly by the HTX DAO Committee and Huobi executives. HIP-001 created a committee whose appointed members include HTX exchange leadership, early contributors and supporters such as Justin Sun and Liu Ye. The whitepaper plans three phases, Platform Co-building, Ecosystem Governance and Financial Governance, and a vote-escrow model called veHTX that is planned and not live as of 2026-10-12. Nominations for the third committee opened on September 14, 2026 and the community vote had not concluded as of 2026-10-12.
(Source: HTX DAO Whitepaper, Temporary Proposal Rules Announcement, HIP-001 HTX DAO Committee Member Policy, HIP-001-R3 Third Committee Nominations)
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the: (a) full names, (b) official titles, (c) and prior experience of key team members. For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Justin Sun | Labs/DevCo | Member of the Huobi Global Advisory Board since October 2022, described by HTX DAO's Molly in July 2025 as "our advisor" (Crowdfund Insider, Tron Founder Added to Huobi Advisory Board, Cryptopotato, Justin Sun Confirms Advisory Role in Huobi, Decrypt, HTX 2025 Mid-Year Performance) | Founder of TRON, Permanent Representative of Grenada to the World Trade Organization from 2021 to March 2023, and a graduate of Peking University and the University of Pennsylvania. Wikipedia states that he owns HTX and bought it in 2022, while Sun denied in 2022 that he was the buyer of Huobi founder Leon Li's stake (Wikipedia, Justin Sun, Cryptopotato, Justin Sun Confirms Advisory Role in Huobi). |
Huobi Global S.A. officers | Labs/DevCo | Huobi Global S.A., the Panama company that owns and operates the HTX exchange, does not publicly name its executive officers, and its listed director is the corporate entity Huobi Global Limited (Protos, HTX Misrepresents Huobi Global S.A.). | Prior experience of the operating company's executives is not disclosed in the HTX, HTX DAO or court sources reviewed (FCA, HTX Huobi Legal Proceedings). |
No foundation exists | Foundation | HTX DAO has no foundation, and the whitepaper states that HTX DAO is not a legal entity and does not operate as a registered company (HTX DAO Whitepaper). | Not applicable because no foundation exists (HTX DAO Whitepaper). |
Justin Sun | DAO/Onchain Governance | Named in HIP-001 as a supporter among the appointed members of the HTX DAO Committee (HIP-001 HTX DAO Committee Member Policy) | Founder of TRON and former Permanent Representative of Grenada to the World Trade Organization (Wikipedia, Justin Sun). |
Liu Ye (Molly) | DAO/Onchain Governance | Named in HIP-001 as a supporter among the appointed members of the HTX DAO Committee, and described as HTX DAO's key ambassador (HIP-001 HTX DAO Committee Member Policy, Forklog, HTX Unveils Updated White Paper) | Prior experience is not disclosed in the HTX DAO sources reviewed (HIP-001 HTX DAO Committee Member Policy). |
DaDa (pseudonym) | DAO/Onchain Governance | Second-committee member standing for a further term in the third committee nominations (HIP-001-R3 Third Committee Nominations) | DaDa describes a background in Web2 and Web3 product development and startups and says they hosted nearly 30 HTX DAO community Spaces, and no full name is published (HIP-001-R3 Third Committee Nominations). |
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
HTX DAO does not own or control any disclosed IP. The whitepaper describes the DAO as a collective assembly of token holders operating through smart contracts and states that it is not a legal entity. The HTX trademark in the United States is held by Huobi Global S.A., the company that owns and operates the HTX exchange. The operator of the htxdao.com site and the HTX DAO GitBook is not named.
(Source: HTX DAO Whitepaper, Protos, HTX Misrepresents Huobi Global S.A.)
The TRON HTX contract at TUPM7K8REVzD2UdV4R5fe5M8XbnR2DdoJ6 has no roles with special privileges and no function to mint more tokens, according to ChainSecurity's January 2024 audit. The Ethereum and BNB Smart Chain versions at 0x61ec85ab89377db65762e234c946b5c25a56e99e are bridge-mapped tokens with a mint function. An onchain read of each contract on 2026-10-12 showed that each grants the mint-capable predicate role to one bridge predicate contract, which is an upgradeable proxy with its own owner address, and no default admin is set. Tokenholders vote onchain on TRON at one HTX per vote, and HIP-001 and HIP-002 passed in an onchain vote opened on April 9, 2025. Approved proposals are implemented only if the platform approves them after its compliance review, and the revised HIP-005 draft reserves to HTX a final compliance review before any listing. HIP-007 proposed that a 3-of-5 or 4-of-7 Gnosis Safe managed by the committee hold the Development Fund, and the whitepaper names errors by multi-signature administrators as a risk without publishing signers or thresholds.
(Source: ChainSecurity, HTX DAO HTX Token Audit, Etherscan, HTX Token, Forklog, HTX DAO Approves Initial Community Governance Proposals, HTX DAO Whitepaper, HIP-005 Revised Draft, HIP-007 HTX DAO Development Fund)
HTX DAO Staking launched in public beta on March 16, 2026 and in full on March 23, 2026. Staking HTX on TRON in an ERC-4626 vault mints sHTX, which earns rewards and votes at one sHTX per vote, the same weight as unstaked HTX. The launch post says some proposals may apply voting weight decay or other proposal-specific parameters. Unstaking has a 48-hour cooldown. Staking adds yield but no extra governance rights, and stakers cannot decide on exchange revenue, the buyback rate or the platform's compliance review. The veHTX vote-escrow model is planned and not live as of 2026-10-12.
(Source: HTX DAO Staking Launch, HTX DAO Whitepaper)
HTX holders have no right to receive exchange revenue or to direct a treasury. The HTX exchange, as an ecosystem partner, provides 50% of its quarterly revenue to buy back and burn HTX, which is a policy of the exchange and not a right of holders. The Q2 2026 burn of 7,474,935,439,560 HTX was completed on July 15, 2026, bringing cumulative HTX burned and pledged to about 117.79 trillion. HTX gives fee discounts on the HTX exchange, and staking pays rewards from ecosystem development reserves. HIP-007 proposed a Development Fund held by the committee, and its funding sources are project reserved funds and community donations.
(Source: Bitcoin.com News, HTX Quarterly Burn Hits a New High, Yellow, HTX DAO Burns Over $32.82 Million of HTX in H1 2026, HTX DAO Staking Launch, HIP-007 HTX DAO Development Fund)
No party has a disclosed power to dissolve HTX DAO, and no tokenholder vote threshold for dissolution is published. Because the DAO is not a legal entity, there is no legal wrapper to wind up. The TRON token contract has no admin role, so it would continue to exist regardless of any decision to stop DAO activity.
(Source: HTX DAO Whitepaper, ChainSecurity, HTX DAO HTX Token Audit)
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
No Primary Foundation exists for HTX. The whitepaper states that HTX DAO is not a legal entity and does not function as a traditional registered company, and no foundation is named in the whitepaper, the governance forum or the token audit.
(Source: HTX DAO Whitepaper, ChainSecurity, HTX DAO HTX Token Audit)
Not applicable because no foundation exists.
(Source: HTX DAO Whitepaper)
Not applicable because no foundation exists.
(Source: HTX DAO Whitepaper)
Not applicable because no foundation exists.
(Source: HTX DAO Whitepaper)
Not applicable because no foundation exists.
(Source: HTX DAO Whitepaper)
Not applicable because no foundation exists.
(Source: HTX DAO Whitepaper)
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
HTX DAO names no development company, and the whitepaper says the DAO was initiated by early community supporters independent of HTX Exchange or TRON. The entity most directly involved in issuing HTX to holders is Huobi Global S.A., a company incorporated in Panama on May 19, 2023, which describes itself in a US court filing as the entity that owns and operates HTX and developed the Huobi Eco Chain (HECO). The HTX exchange ran the HT to HTX conversion and distributed the TRON user airdrop. Wikipedia states that Justin Sun owns HTX, while Sun has described himself as an advisor to the exchange. This filing treats Huobi Global S.A. as the Primary DevCo on that basis. The deployer of the TRON HTX contract, TXj9DhSiUxnN6w6ooZGgDgjKfqfztBgdfF, is not publicly attributed to a named entity.
(Source: HTX DAO Whitepaper, Protos, HTX Misrepresents Huobi Global S.A., Wikipedia, Justin Sun, The Block, A Deeper Look at the HT to HTX Token Switcheroo, Tronscan, HTX Token)
Huobi Global S.A. holds the HTX trademark in the United States and owns and operates the HTX exchange. Its director is Huobi Global Limited, and no subsidiary structure is published. The UK Financial Conduct Authority began High Court proceedings on October 21, 2025 against Huobi Global S.A. and persons unknown who control the HTX exchange, citing the HTX Platform User Agreement dated July 13, 2023. The HTX token code, audited by ChainSecurity, is not published in a repository attributed to Huobi Global S.A.
(Source: Protos, HTX Misrepresents Huobi Global S.A., FCA, HTX Huobi Legal Proceedings, ChainSecurity, HTX DAO HTX Token Audit)
The platform reviews approved HTX DAO proposals against its compliance standards and implements them only if it approves. Under the March 2025 temporary rules, Huobi executives reviewed qualifying proposals jointly with the HTX DAO Committee, and HIP-001 names HTX exchange leadership among the appointed committee members. The exchange decides the revenue it provides for quarterly buybacks and burns, ran the HT to HTX conversion with a variable rate and a locked tranche tied to trading tasks, and holds the largest TRON balance of HTX. The address TDToUxX8sH4z6moQpK3ZLAN24eupu2ivA4, tagged HTX 6 on Tronscan, held about 230.97 trillion HTX, about 23% of the initial supply, as of 2026-10-12.
(Source: HTX DAO Whitepaper, Temporary Proposal Rules Announcement, HIP-001 HTX DAO Committee Member Policy, The Block, A Deeper Look at the HT to HTX Token Switcheroo, Tronscan, HTX Holders)
Not applicable because no foundation exists for HTX.
(Source: HTX DAO Whitepaper)
Huobi Global S.A. holds no disclosed admin role on the TRON HTX contract, which has no privileged roles. It controls implementation of DAO proposals through the platform compliance review and controls the exchange wallets that hold HTX. The Ethereum and BNB Smart Chain HTX versions can be minted by a single bridge predicate contract on each chain, and the owner of each predicate proxy is not publicly attributed to Huobi Global S.A. or to another named entity.
(Source: ChainSecurity, HTX DAO HTX Token Audit, HTX DAO Whitepaper, Etherscan, HTX Token)
No mechanism directs HTX DAO resources to Huobi Global S.A. The flow runs the other way, with the HTX exchange providing 50% of its quarterly revenue to buy back and burn HTX. HIP-001 appointed members include HTX exchange leadership, and committee members receive no extra voting power. Whether committee members are paid is not disclosed.
(Source: Bitcoin.com News, HTX Quarterly Burn Hits a New High, HIP-001 HTX DAO Committee Member Policy)
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
The TRON HTX contract was deployed on November 1, 2023 UTC and minted the full fixed supply of 999,990,000,000,000 HTX to the deployer address in one transaction. The contract has no lock or vesting function, so all tokens were unlocked at the contract level. The whitepaper does not state how many tokens were held back or locked by policy at launch. Tokens converted from HT on the HTX exchange were split into unlocked and locked portions, with the locked portion released after trading tasks were met.
(Source: Tronscan, HTX Token, ChainSecurity, HTX DAO HTX Token Audit, HTX DAO Whitepaper, The Block, A Deeper Look at the HT to HTX Token Switcheroo)
The whitepaper gives only the category names and percentages, so the use descriptions above restate the category names.
(Source: HTX DAO Whitepaper)
No fixed price was set. HT holders converted at rates set by the exchanges. Gate offered a fixed rate of 1 HT to 1,000,000 HTX from January 30 to February 2, 2024, filled by sell orders placed by the HTX DAO project owner, and scheduled HTX trading to start on February 2, 2024. On the HTX exchange the rate varied with the time and amount converted. The Block reported that a January 2024 test conversion gave 1.6 million unlocked and 900,000 locked HTX per HT, and that by March 2024 the rate it calculated had fallen to one to 0.22 for unlocked tokens and one to 0.34 including locked tokens. HTX traded at about $0.00000168 on 2026-10-12.
(Source: Gate, HT to HTX Conversion Announcement, The Block, A Deeper Look at the HT to HTX Token Switcheroo, CoinGecko, HTX DAO)
The ticker is HTX. The TRC-20 contract is TUPM7K8REVzD2UdV4R5fe5M8XbnR2DdoJ6 with 18 decimals, and the Ethereum and BNB Smart Chain versions use 0x61ec85ab89377db65762e234c946b5c25a56e99e.
(Source: Tronscan, HTX Token, CoinGecko, HTX DAO)
The TRON supply is fixed at 999,990,000,000,000 HTX and the contract cannot mint more. The whitepaper describes a deflationary model. Burned HTX is sent to the TRON black hole address T9yD14Nj9j7xAB4dbGeiX9h8unkKLxmGkn, which held about 101.76 trillion HTX as of 2026-10-12, and CoinGecko reports a total and circulating supply of about 898.23 trillion HTX, the fixed supply less that balance. HTX DAO reported cumulative HTX burned and pledged of about 117.79 trillion after the Q2 2026 burn on July 15, 2026, a figure that includes liquidity pledges as well as burns. The Ethereum and BNB Smart Chain versions are bridged and held about 2.09 trillion and 4.92 trillion HTX as of 2026-10-12.
(Source: ChainSecurity, HTX DAO HTX Token Audit, HTX DAO Whitepaper, Tronscan, HTX Holders, CoinGecko, HTX DAO, Yellow, HTX DAO Burns Over $32.82 Million of HTX in H1 2026, Etherscan, HTX Token)
(Source: HTX DAO Whitepaper, The Block, A Deeper Look at the HT to HTX Token Switcheroo, HTX DAO Proposal Processing Update March 21, 2025, HTX DAO Airdrop Rules for TRX and USDT Holders)
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Planned but not yet executed airdrop
Not applicable. No new HTX airdrop is planned as of 2026-10-12.
(Source: HTX DAO Whitepaper)
Executed airdrop
HTX DAO airdropped 14,999,850,000,000 HTX, 1.5% of supply, to TRON TRX and USDT holders under the TRON Users Airdrop in the Early Contributor Support Program. TRON addresses holding at least 20,000 TRX or 70,000 USDT at a snapshot were eligible. The total was split equally between TRX and USDT holders at stated rates of 130 HTX per TRX and 280 HTX per USDT, with the fixed total shared out if eligible holdings exceeded 57 billion TRX or 25 billion USDT. Under the February 27, 2024 rules, the first round of 1% of supply used a February 28, 2024 snapshot and five further rounds followed on April 30, May 30, June 30, July 30 and August 30, 2024. HTX DAO sent tokens to supporting exchanges such as Bitget and MEXC within five days of each snapshot, and those exchanges allocated them pro rata to user balances. Self-custody holders claimed through the HTX exchange by binding their TRON address to an HTX account. No per-address recipient list, Merkle dump or claim contract has been published. The separate HT to HTX conversion was a voluntary exchange of an existing token rather than an airdrop.
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself. If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
No exploit has affected the HTX token contract, HTX supply or HTX holder balances as of 2026-10-12. Two 2023 incidents hit the HTX exchange and its HECO chain bridge, the platform behind the token, and are disclosed here. On September 24 to 25, 2023 an HTX exchange hot wallet on Ethereum was drained. On November 22, 2023 the HECO Bridge, a bridge between Ethereum and Huobi Eco Chain, and HTX exchange hot wallets on Ethereum and TRON were drained. The HTX token had been deployed on November 1, 2023 but did not begin trading until February 2024, and neither incident involved the HTX token.
(Source: Cointelegraph, Huobi Global Crypto Exchange Hacked, CertiK, HECO Bridge Exploit, Tronscan, HTX Token)
In September 2023 an attacker withdrew ETH from an HTX hot wallet, and the method was not published. In November 2023 the attacker held the private key of the HECO Bridge operator address 0x3d655889D197125fb90dcB72e4a287A8410ED1B9 and used it to call the operator-only withdrawToken function to drain the bridge, while also draining HTX exchange hot wallets. CertiK classified the November incident as a private-key compromise.
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
(Source: HTX DAO Whitepaper, HTX DAO Airdrop Rules for TRX and USDT Holders, Bitget, HTX DAO Airdrop for TRX and USDT Holders, MEXC, HTX DAO Airdrop Support)
No airdrop planned or conducted
Not applicable. HTX DAO conducted the TRON Users Airdrop described above.
(Source: HTX DAO Whitepaper)
The September 2023 incident took 5,000 ETH, valued at about $7.9 million to $8 million. The November 2023 incident took about $113.3 million according to CertiK, made up of about $87 million from the HECO Bridge, including 10,145 ETH, 42.11 million USDT, 489 HBTC, about 346.87 billion SHIB, 173,200 UNI, 619,000 USDC, 42,399 LINK and 346,994 TUSD, plus about $13.6 million from HTX Ethereum hot wallets and about $12.6 million from HTX TRON hot wallets. PeckShield put the bridge loss at $86.6 million. No HTX tokens were lost.
(Source: Cointelegraph, Huobi Global Crypto Exchange Hacked, Cointelegraph, HTX Claws Back Stolen Funds, CertiK, HECO Bridge Exploit, Cointelegraph, HECO Chain Bridge Hack)
After the September incident HTX offered a 5% bounty with an October 2 deadline, and the attacker returned the funds in full in exchange for a 250 ETH white-hat bounty. After the November incident HTX suspended deposits and withdrawals, and Justin Sun stated that HTX would fully compensate the losses from its hot wallets. HECO withdrawals of HT were still suspended in March 2024. HecoDAO announced in November 2024 that HECO would go offline on January 15, 2025, and that holders of eight bridged HRC-20 assets, including HRC20ETH and HRC20USDT, could deposit them before January 10, 2025 for points at one point per USDT of value, each point redeemable for up to 200,000 HTX paid in 12 installments from January 15, 2025.
(Source: Cointelegraph, HTX Claws Back Stolen Funds, Cointelegraph, HECO Chain Bridge Hack, The Block, A Deeper Look at the HT to HTX Token Switcheroo, Odaily, HECO Network Will Go Offline on January 15, 2025)
The September 2023 incident is resolved, with Justin Sun confirming on October 7, 2023 that the funds had been fully returned. The November 2023 incident is closed for exchange users, with HTX stating it would cover hot wallet losses, but recovery of bridge funds is in litigation. On February 2, 2026 Huobi Global S.A. filed a claim in the US District Court for the District of Columbia over Tether tokens tied to the hack, describing itself as the developer of the Huobi Eco Chain.
(Source: Cointelegraph, HTX Claws Back Stolen Funds, Cointelegraph, HECO Chain Bridge Hack, Protos, HTX Misrepresents Huobi Global S.A.)
CertiK published an analysis of the November 2023 HECO Bridge exploit, and Cointelegraph covered both incidents and the fund return.
(Source: CertiK, HECO Bridge Exploit, Cointelegraph, HTX Claws Back Stolen Funds, Cointelegraph, HECO Chain Bridge Hack)
Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?
Response
Impact of Regulatory Change on TGE and Listings:
HTX launched in 2023 and has no pending TGE, so regulatory risk falls on continued trading. The EU named HTX (Huobi Global SA) in its 21st Russia sanctions package, adopted July 23, 2026, with a transaction ban from August 23, 2026, and the UK designated Huobi Global S.A. on May 26, 2026. Venues serving EU and UK users may stop supporting HTX or limit transfers to and from the HTX exchange, which supplies most HTX liquidity and funds its burns.
(Source: Decrypt, EU Names Justin Sun's HTX in Russia Sanctions, The Block, EU Adds HTX to Russia Sanctions List, Protos, HTX Misrepresents Huobi Global S.A.)
Entity-Level Regulatory Impact:
The UK Foreign, Commonwealth and Development Office designated Huobi Global S.A. on May 26, 2026 over alleged links to Russian sanctions evasion through the A7, A7A5 and Garantex networks, and HTX said that entity is distinct from the online HTX exchange. The FCA began High Court proceedings against Huobi Global S.A. and persons unknown who control the HTX exchange on October 21, 2025, with the latest court order dated October 5, 2026. The EU transaction ban took effect August 23, 2026, and OFAC had not acted as of 2026-10-12. The SEC settled its US case against Justin Sun in 2026 for $10 million. Further action against the exchange could cut the revenue that funds HTX buybacks and the platform that implements DAO proposals.
(Source: Protos, HTX Misrepresents Huobi Global S.A., FCA, HTX Huobi Legal Proceedings, Decrypt, EU Names Justin Sun's HTX in Russia Sanctions, Unchained, EU Names HTX in 21st Russia Sanctions Package)
Tokenholder Tax Treatment:
Tax treatment is uncertain for HTX received through the HT conversion, the TRON user airdrop and staking rewards, and for burns funded by exchange revenue. HTX DAO publishes no tax guidance. Tokenholders are responsible for understanding and meeting their own tax obligations in their jurisdictions.
(Source: HTX DAO Whitepaper, HTX DAO Staking Launch)
Jurisdictional & User Access Restrictions:
The whitepaper prohibits access by users in the United States and in OFAC-sanctioned countries. EU persons are barred from transactions with HTX (Huobi Global SA) from August 23, 2026, and UK persons are restricted by the UK designation. These limits narrow the user base and expose users who misstate their location to account action.
(Source: HTX DAO Whitepaper, Decrypt, EU Names Justin Sun's HTX in Russia Sanctions, Protos, HTX Misrepresents Huobi Global S.A.)
Bugs and Design Flaws:
The TRON HTX contract is a simple fixed-supply token derived from legacy OpenZeppelin code adapted to Solidity 0.8, with no admin roles. The larger technical risks sit outside it. The Ethereum and BNB Smart Chain versions can be minted by a bridge predicate held behind an upgradeable proxy, so a compromised bridge or proxy owner could mint unbacked HTX on those chains. The 2023 HECO Bridge loss shows how an operator key compromise can drain a bridge. Staking runs in a separate sHTX vault contract, and the whitepaper lists errors by multi-signature administrators as a risk.
(Source: ChainSecurity, HTX DAO HTX Token Audit, Etherscan, HTX Token, CertiK, HECO Bridge Exploit, HTX DAO Staking Launch, HTX DAO Whitepaper)
Security Measures & Their Limitations:
ChainSecurity audited the HTX token in January 2024 and rated it a high level of security. No audit of the staking vault, the bridge predicates or the liquidity management system is published, and no HTX DAO bug bounty is disclosed. The audit does not cover exchange custody or key management, where both 2023 incidents occurred.
(Source: ChainSecurity, HTX DAO HTX Token Audit, HTX DAO Whitepaper, CertiK, HECO Bridge Exploit)
Critical Economic Assumptions:
HTX's deflation depends on the HTX exchange continuing to fund buybacks with 50% of its revenue. Quarterly burns fell from about 13.62 trillion HTX in Q4 2025 to about 10.83 trillion in Q1 2026 and about 7.47 trillion in Q2 2026, and sanctions on the exchange operator could reduce that revenue further. Supply is concentrated, with the exchange address tagged HTX 6 holding about 23% of supply as of 2026-10-12. Staking rewards come from ecosystem development reserves, and the staking post described a base rate of about 5% APY while the Q1 2026 release cited up to 10% APY during the boost campaign.
(Source: Bitcoin.com News, HTX Quarterly Burn Hits a New High, Bolsamania, HTX DAO Completes Q1 2026 HTX Burn, Yellow, HTX DAO Burns Over $32.82 Million of HTX in H1 2026, Tronscan, HTX Holders, HTX DAO Staking Launch)
Governance Control over Monetary Policy & Rewards:
TRON HTX supply cannot be increased because the contract has no mint function. Tokenholders cannot set the buyback rate, which is a policy of the HTX exchange that it can change or end. Staking rewards, fee discounts and Development Fund spending are run by HTX DAO and the platform, and the platform's compliance review can block any approved proposal. The committee stated in March 2025 that HTX is fully circulating, but the wallets that hold the Strategic Partners and other allocations are not identified, so holders cannot see when those balances may be sold.
(Source: ChainSecurity, HTX DAO HTX Token Audit, HTX DAO Whitepaper, HIP-007 HTX DAO Development Fund, HTX DAO Proposal Processing Update March 21, 2025)
