Part of the CustodyStress archive of observed Bitcoin custody incidents
Exchange custody
Cases in this category involve Bitcoin held on exchanges or custodial platforms. The user does not control private keys — access depends on the platform remaining operational and the account remaining accessible.
Exchange custody cases cluster around platform insolvency, account access loss, and regulatory action. Unlike self-custody failures, exchange cases often involve a recoverable path — but one that runs through legal or institutional processes that can take months or years.
512 observed cases
Blocked
135 (26%)
Constrained
181 (35%)
Survives
128 (25%)
Indeterminate
68 (13%)
FTX announced a third distribution of approximately $1.6 billion on September 30, 2025.
Exchange custody
FTX announced a third distribution of approximately $1.6 billion on September 30, 2025. Dotcom customer entitlement claims received an incremental 6% distributi
The exchange account held approximately $120,000 in Bitcoin.
Exchange custody
A 2025 case described by a California elder law attorney involved a 74-year-old Bitcoin exchange user whose cognitive decline had reached the point where they c
Garantex—a sanctioned Russian cryptocurrency exchange—had its infrastructure seized by
Exchange custody
In March 2025, Garantex—a sanctioned Russian cryptocurrency exchange—had its infrastructure seized by US and German law enforcement in a coordinated operation.
A US federal judge issued a temporary restraining order on approximately March 5, 2026
Exchange custody
In February 2025, Chicago-based crypto lender BlockFills suspended all client withdrawals and disclosed it had incurred approximately $75 million in losses. The
Binance announced new identity verification requirements for all users as part of
Exchange custody
In November 2025, Binance announced new identity verification requirements for all users as part of a global compliance upgrade. Users in affected jurisdictions
Institutional lockout — exchange custody (2025)
Exchange custody
A 2025 US regulatory development required cryptocurrency exchanges operating in the US to implement enhanced transaction monitoring and suspicious activity repo
Owner incapacity — Coinbase (2025)
Exchange custody
A 2025 UK elder care case involved an 81-year-old Coinbase user diagnosed with vascular dementia whose cognitive decline had progressed to the point where they
In jurisdictions that had adopted stronger Travel Rule enforcement in 2024–2025
Exchange custody
A 2025 survey of mid-tier exchange users found that a significant proportion of self-reported Bitcoin holders who used custodial exchanges had not updated their
The holder's will made general reference to 'my cryptocurrency.' However, one of
Exchange custody
A 2025 estate case described by a California probate attorney involved a holder who had purchased Bitcoin through multiple exchanges between 2017 and 2021. The
Legal authority constraint — exchange custody (2025)
Exchange custody
The 2025 Digital Asset Market Clarity Act, working its way through Congress, proposed clarifying the SEC/CFTC jurisdictional boundary for digital assets. During
The platform, which had filed for bankruptcy in November 2022, approved a plan in late
Exchange custody
BlockFi's distribution to creditors continued throughout 2025. The platform, which had filed for bankruptcy in November 2022, approved a plan in late 2024 that
An Australian estate case in 2025 involved a deceased holder with a Binance account.
Exchange custody
An Australian estate case in 2025 involved a deceased holder with a Binance account. Binance's Australian entity had undergone restructuring in 2024 following t
The April 2025 FTX distribution record date for mid-range creditors saw a significant
Exchange custody
The April 2025 FTX distribution record date for mid-range creditors (claims above $50,000) saw a significant group of creditors discover that their claim had be
Platform bankruptcy — exchange custody (2025)
Exchange custody
A 2025 report on dormant exchange accounts estimated that approximately $2.1 billion in cryptocurrency remained in accounts on exchanges that had undergone bank
The disclosure confirmed earlier CBC reporting that the ransom paid was approximately
Exchange custody
In April 2025, WonderFi—Canada's largest regulated cryptocurrency exchange—disclosed that it had incurred $3.6 million CAD in total costs in Q4 2024 related to
The account held approximately $85,000 in Bitcoin.
Exchange custody
A 2025 estate case in Texas involved a deceased holder whose Coinbase account was located through tax records showing crypto-related income. The executor obtain
Legal authority constraint — exchange custody (2025)
Exchange custody
A 2025 European Union ruling began enforcing the Travel Rule requirement that cryptocurrency exchanges share sender and recipient identity information for trans
Sanctions lockout — exchange custody (2025)
Exchange custody
Russian Bitcoin holders continued to face complete exclusion from Western exchange and custody services in 2025 under sustained OFAC and EU sanctions. The seizu
Institutional lockout — FTX (2025)
Exchange custody
The FTX first distribution on February 18, 2025 raised a practical access issue for creditors in US states with specific abandoned property laws. Several US sta
Sanctions lockout — exchange custody (2025)
Exchange custody
Garantex, a Russia-based cryptocurrency exchange that had been sanctioned by OFAC in April 2022 for facilitating transactions for sanctioned entities, was targe
Institutional lockout — FTX (2025)
Exchange custody
A significant fraction of FTX creditors who had completed partial onboarding steps discovered they were ineligible for the February 18, 2025 Convenience Class d
The plan set January 3, 2025 as the initial record date.
Exchange custody
FTX's Chapter 11 plan became effective on January 3, 2025, initiating the first genuine access restoration for FTX customers since the exchange froze withdrawal
Institutional lockout — exchange custody (2025)
Exchange custody
A mid-tier centralised exchange that had operated since 2020 and served primarily users in Latin America announced a suspension of all withdrawal services in Ma
Legal authority constraint — exchange custody (2025)
Exchange custody
Ukrainian Bitcoin holders faced a growing set of legal restrictions in 2025 as Ukraine's wartime financial controls required registration of cryptocurrency hold
Institutional lockout — FTX (2025)
Exchange custody
On February 18, 2025, FTX began the first distribution under its confirmed reorganisation plan, paying approximately $800 million to 162,000 accounts in the Con