CustodyStress
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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%)
Several exchanges suspended all XRP trading with 72 hours notice.
Exchange custody
Survives 2020
The SEC brought enforcement action against Ripple in November 2020 (charges formally filed in December), triggering a wave of US exchange delistings of XRP and
The trader transferred 4 BTC in two instalments before the blackmailer's address was
Exchange custody
Constrained 2020
An October 2020 case describes a Bitcoin trader who was coerced through a week-long campaign of threatening messages by someone who had obtained their wallet ba
The QuadrigaCX CCAA proceedings entered their second year in January 2020.
Exchange custody
Blocked 2020
The QuadrigaCX CCAA proceedings entered their second year in January 2020. E&Y filed its fifth monitor's report confirming that Gerald Cotten had used customer
Documentation absent — exchange custody (2020)
Exchange custody
Blocked 2020
A Bitcoin fund manager who had operated informally since 2016 disappeared in February 2020, taking client BTC with them. The fund had operated entirely through
Chinese OTC trading desks continued to face intensifying enforcement in February 2020.
Exchange custody
Constrained 2020
Chinese OTC trading desks continued to face intensifying enforcement in February 2020. Bank accounts used for Bitcoin settlement were being frozen routinely und
Documentation absent — exchange custody (2020)
Exchange custody
Blocked 2020
A Bitcoin arbitrage fund that had raised funds informally through social media collapsed in March 2020 during the COVID crash. The operator had never provided a
The operator claimed all Bitcoin had been lost to a 'black swan market event' but could
Exchange custody
Blocked 2020
A Bitcoin loan platform that had been paying consistent monthly returns since 2018 collapsed in April 2020 during COVID. The operator claimed all Bitcoin had be
Forced relocation — exchange custody (2020)
Exchange custody
Constrained 2020
US OFAC added new designations related to Iranian cryptocurrency activities in June 2020. Any exchange with US nexus that had Iranian customers terminated those
Approximately 400 victims sent 12.86 BTC believing they were responding to a verified
Exchange custody
Blocked 2020
On 15 July 2020 attackers compromised the Twitter accounts of major public figures and corporations including Barack Obama, Joe Biden, Elon Musk, Apple, and Coi
Documentation absent — exchange custody (2020)
Exchange custody
Indeterminate 2020
A DeFi yield optimisation protocol that launched in July 2020 attracted significant BTC-backed deposits before being exploited. The protocol's documentation con
Institutional lockout — exchange custody (2020)
Exchange custody
Constrained 2020
China's 'Operation Clean Network' internet security campaign in July 2020 led to enhanced monitoring of all VPN traffic. Chinese Bitcoin users who relied on VPN
Owner incapacity — exchange custody (2020)
Exchange custody
Blocked 2020
A cryptocurrency day trader was sedated and placed on a ventilator due to COVID-19 in April 2020 for 21 days. During this period their exchange account had open
Users who had deposited BTC had no documentation to support insurance or legal claims.
Exchange custody
Indeterminate 2020
A Bitcoin yield farming platform that had launched in July 2020 during the DeFi summer collapsed in August 2020 after being exploited. The platform had no audit
The Lebanese pound lost 80% of its value.
Exchange custody
Constrained 2020
Lebanon's financial crisis reached a critical point in August 2020 following the Beirut port explosion. The Lebanese pound lost 80% of its value. Lebanese Bitco
Institutional lockout — exchange custody (2020)
Exchange custody
Survives 2020
The EU's 5AMLD transposition deadline of January 2020 had passed and EU member states began enforcement. Exchanges in France, Germany, and the Netherlands recei
Documentation absent — exchange custody (2020)
Exchange custody
Indeterminate 2020
Post-hack analysis of the KuCoin breach confirmed the exchange had stored hot wallet private keys without multi-signature protection despite claiming industry-s
Documentation absent — exchange 2020
Exchange custody
Indeterminate 2020
A Bitcoin custody platform popular with European HNW clients published its first proof-of-reserves in September 2020. Independent verification found the proof w
Account frozen — exchange custody (2020)
Exchange custody
Constrained 2020
Following disputed presidential elections in Belarus in August 2020 and subsequent protests, Belarusian authorities began freezing bank accounts of individuals
Institutional lockout — exchange custody (2020)
Exchange custody
Survives 2020
FinCEN's August 2020 proposed rulemaking on convertible virtual currency mixers prompted several exchanges to pre-emptively flag all transactions that had passe
Documentation absent — exchange custody (2020)
Exchange custody
Blocked 2020
An OTC Bitcoin trading desk collapsed in October 2020 with approximately 80 BTC in outstanding client deposits. The desk had never issued formal account stateme
Forced relocation — exchange custody (2020)
Exchange custody
Constrained 2020
Despite the Supreme Court lifting the RBI ban in March 2020, Indian Bitcoin users continued to face banking difficulties throughout 2020. Several large banks re
Gox rehabilitation creditor who had been waiting since 2014 died in October 2020.
Exchange custody
Constrained 2020
A Mt. Gox rehabilitation creditor who had been waiting since 2014 died in October 2020. The estate had to demonstrate that the deceased had been a legitimate Go
Institutional lockout — exchange custody (2020)
Exchange custody
Survives 2020
On 1 October 2020 the CFTC and DOJ simultaneously filed charges against BitMEX and its founders for operating an unregistered trading facility and AML violation
Forced relocation — exchange custody (2020)
Exchange custody
Constrained 2020
Nigeria's CBN issued revised guidelines in November 2020 further restricting cryptocurrency transactions through commercial banks. Exchange accounts linked to N
Institutional lockout — exchange custody (2020)
Exchange custody
Survives 2020
On 16 October 2020 OKEx suspended all cryptocurrency withdrawals for five weeks after a key holder — one of several required for cold wallet transactions — was
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Other stress categories
Terms guide
Survives
Access remained possible under the reported conditions.
Constrained
Access remained possible, but only with delay, dependence, or significant difficulty.
Blocked
Access was not possible under the reported conditions.
Indeterminate
There was not enough information to determine the outcome.
Single-person knowledge
Recovery depended on information or capability held by one individual who was unavailable.
Institutional dependence
Recovery depended on a third-party institution or service that was inaccessible or uncooperative.
Documentation gap
Recovery depended on instructions that were missing, incomplete, or unclear.
Authority mismatch
The person with legal authority to act did not have operational access, or vice versa.
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