Is Xcom 2 region locked?

I don't think there is any region lock

My HB monthly code works, I am in Hong Kong

I won a XCOM 2 that I believe was from HB Monthly, and it works perfectly in my region Brazil. The guy was from US. So I don't believe it is locked. Probably ROW.

Saw that if you buy it in Brazil, it stays locked to Brazil (it's a region for a country) and you can't activate it in South America. Don't know about other regions. You could check here https://steamdb.info/app/268500/subs/

When you generated the key or gift code on Humble, they popped up the notification of which countries it won't activate in. YOu couldn't reveal the code/key without acknowledging it with an Okay button. And yes, it is region-locked.