Kyrrex presents itself as a regulated global crypto exchange but operates through a fragmented, multi-jurisdictional structure that has facilitated high-risk flows, regulatory arbitrage, and significant losses for retail investors. The ICIJ investigation “Hunt for missing millions unmasks one crypto exchange hidden inside another” exposes that Kyrrex’s offshore arm acted as a nested exchange within HTX (Huobi), processing billions while receiving deposits originating from fraudulent investment schemes. Combined with shifting corporate operators, vanished entities, and unclear governance, Kyrrex poses substantial compliance risks.
2. Corporate Structure
Kyrrex operates through a deliberately opaque multi-layered ownership structure designed to exploit regulatory arbitrage:
- Cyprus Holding Layer: Kyrrex Holding Ltd. (Cyprus, registered 2018) serves as the central controlling entity. Viktor Kochetov is registered as director, with both co-founders holding indirect shareholding interests. Corporate records confirm Romanenko’s role as sole director and legal representative of the SVG entity as of November 2024.
- Malta Entity: Real Exchange (REX) Limited holds MFSA Class 4 VFA license for European operations. Shareholders include K-Worldwide Group 18 Ltd., with upstream ownership through Kyrrex Holding Ltd. (Cyprus), Peter’s Lab (Poland), and RV70 Holding Limited (England). Malta regulators issued a “cease on-boarding” order in 2020 for non-compliance, lifted six months later.
- Offshore Entity: Kyrrex Limited (SVG, registered 2021) operated unregulated exchange services until recently. Romanenko served as sole director. This entity handled customer on-boarding with severely deficient KYC procedures.
- Other Entities: Kyrrex expanded with registrations in the U.S., U.K., and Switzerland—none subject to comprehensive VFA regulation comparable to Malta.
| Entity | Jurisdiction | Status / Role | Notes |
|---|---|---|---|
| Kyrrex Ltd | St. Vincent & the Grenadines | Defunct offshore operator | Controlled the HTX wallet implicated in fraud flows; no meaningful regulation. |
| Real Exchange (REX) Limited | Malta | VFA Services Provider | Used as the “regulated face” of Kyrrex; denies responsibility for offshore operations. |
| Kyrrex Operations LLC | USA | FinCEN-registered MSB (MSB# 310024013725) | Briefly listed as the operator of Kyrrex.com in early 2025. |
| Kyrrex Holding Ltd | Cyprus | Corporate parent | Governance opaque; limited transparency on internal controls. |
| Viktor Kochetov | Ukraine | Co-Founder and CEO | |
| Mike Romanenko | Ukraine | Co-Founder and CVO |
3. Regulatory Framework & Compliance Failures
Malta (REX): Holds Class 4 VFA Service Provider license under Malta’s Virtual Financial Assets Act. MFSA issued a February 2025 notice disclaiming responsibility for non-Malta entities despite shared ownership and brand identity.
St. Vincent: No meaningful VFA regulation existed when Kyrrex Limited registered in 2021. The exchange operated without licensing, supervision, or AML obligations.
Critical Compliance Deficiencies:
- KYC Failures: At least 29 Kyrrex customers linked to fraudulent transactions provided demonstrably false information—nonexistent addresses (e.g., “Poulainnec”), diplomatic mission addresses, P.O. boxes without verification, and potentially stolen identities.
- Nested Services: Kyrrex operated as a nested exchange within HTX (formerly Huobi), routing customer trades through HTX-hosted wallets. This layering obscured transaction monitoring and allowed rapid movement of illicit funds. Nearly $10 billion in Bitcoin passed through one suspect wallet address between February 2022-July 2025.
- Delayed Transaction Monitoring: Romanenko acknowledged that blockchain analysis for illicit activity detection can take “weeks or months,” allowing criminals to move funds before freezing.
- Sanctions Violations: Blockchain tracing identified 82.4 bitcoins ($1.7 million) from sanctioned Russian organization MOO Veche—supporting Russian military operations—routed through Kyrrex wallets. Funds originated partly from ChipMixer, a mixing service shut down by authorities for laundering $3 billion.
4. Litigation Exposure & Victim Losses
The ICIJ investigation documented systemic facilitation of fraud:
- Victim Scale: Dozens of victims from Canada, Netherlands, Belgium, Denmark, Australia, and other countries lost funds to fraudsters using Kyrrex wallets.
- Dutch Lawsuit: Amsterdam lawyer Marius Hupkes represents 20+ Dutch victims seeking $11+ million, alleging Kyrrex “maintained a system in which criminals can easily and repeatedly divert fraudulent funds through untraceable structures.”
- HTX Non-Cooperation: Host exchange HTX ignored repeated requests from victims and law enforcement to freeze suspect wallets until forced by Dutch court order in 2023.
- Corporate Shield: Kyrrex invoked SVG registration to disclaim liability, arguing it has “no responsibility toward EU investors defrauded by third parties” despite shared ownership with Malta entity.
Risk Assessment & Conclusions
Kyrrex exemplifies regulatory arbitrage through multi-jurisdictional structuring, exploiting gaps between Malta’s regulated façade and SVG’s unregulated operations. The exchange’s nested service model, combined with systemic KYC failures and delayed transaction monitoring, created an environment conducive to money laundering, fraud facilitation, and sanctions evasion.
Despite claims of transparency and compliance, beneficial ownership remains opaque, and corporate structures are designed to shield liability. The Malta regulator’s refusal to examine cross-border connections—despite shared ownership—demonstrates critical supervisory failures flagged by the European Banking Authority.
Call for Information
FinTelegram urges insiders, employees, business partners, compliance officers, and affected investors to provide confidential information about Kyrrex, its operations, or its beneficial owners via our whistleblower platform:
