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%)
Multisig quorum failure — exchange custody (2020)
Exchange custody
OKEx's five-week withdrawal suspension from October 2020 was caused by a key holder being detained by Chinese police. The exchange used a multi-party authorisat
Documentation absent — exchange custody (2020)
Exchange custody
A November 2020 estate case involved a deceased who had operated as an informal Bitcoin market maker since 2015. Dozens of counterparties had outstanding settle
Multisig quorum failure — 2-of-3 multisig (2020)
Exchange custody
A December 2020 case describes a Bitcoin investment club with a 2-of-3 multisig where all three key holders were resident in different countries. An internation
Estate access failure — exchange custody (2020)
Exchange custody
A December 2020 estate case involved a deceased who had accumulated significant Bitcoin holdings during the year's bull run. The will was clear about the Bitcoi
Passphrase unavailable — exchange custody (2020)
Exchange custody
A December 2020 case describes an exchange account holder who had not logged in since 2016. The account's 2FA was linked to a phone number that had been reassig
India's Supreme Court struck down the RBI's April 2018 banking ban on 4 March 2020.
Exchange custody
India's Supreme Court struck down the RBI's April 2018 banking ban on 4 March 2020. Exchanges immediately began restoring banking relationships. However, severa
During this period, open leveraged positions on their exchange account were
Exchange custody
A Bitcoin trader hospitalised with severe COVID-19 in March 2020 was placed in an induced coma for three weeks. During this period, open leveraged positions on
Turkey's lira came under pressure in April 2020 as COVID impacted its economy.
Exchange custody
Turkey's lira came under pressure in April 2020 as COVID impacted its economy. Bitcoin demand surged as a hedge. Turkish exchanges experienced massive withdrawa
A Bitcoin holder died from COVID-19 in April 2020.
Exchange custody
A Bitcoin holder died from COVID-19 in April 2020. The estate discovered BTC holdings on three exchanges. Two exchanges responded to the executor's requests wit
A Bitcoin investor died in May 2020.
Exchange custody
A Bitcoin investor died in May 2020. The estate found a note that read 'Bitcoin on Bitfinex — login in safe.' The safe contained a username but no password. Bit
The FATF 12-month review of its Travel Rule guidance was published in June 2020.
Exchange custody
The FATF 12-month review of its Travel Rule guidance was published in June 2020. It confirmed that the unhosted wallet rule applied globally. Exchanges that had
A June 2020 estate case involved an account holder at Kraken who had died.
Exchange custody
A June 2020 estate case involved an account holder at Kraken who had died. Kraken required a death certificate, apostilled will, certified copy of the grant of
Owner incapacity — exchange custody (2020)
Exchange custody
A cryptocurrency investor was incapacitated in a traffic accident in August 2020 and remained in an intensive care unit for six weeks. During this period their
The exchange's account recovery process required the 2FA device, creating a deadlock.
Exchange custody
A December 2019 case describes a user who had not logged into a Bitcoin exchange since 2015 and found the account's 2FA had been tied to a phone number that had
Documentation absent — exchange — Japan 2019
Exchange custody
In October 2019 the Mt. Gox rehabilitation plan trustee began its claim verification process. Thousands of creditors had to produce documentation of their origi
An August 2019 case describes a family Bitcoin trust using a 2-of-3 multisig.
Exchange custody
An August 2019 case describes a family Bitcoin trust using a 2-of-3 multisig. One key holder was the family patriarch who died. The trust's lawyers had not incl
The trustee company was acquired by a bank in July 2019.
Exchange custody
A Bitcoin inheritance structure used a 2-of-3 multisig where the three key holders were a trustee company, the grantor, and a child. The trustee company was acq
Forced relocation — exchange custody (2019)
Exchange custody
During the prolonged Supreme Court challenge to the RBI ban in early 2019, Indian Bitcoin users continued to face an inaccessible banking system. Exchange custo
A Bitcoin syndicate that had been operating since 2016 collapsed in February 2019.
Exchange custody
A Bitcoin syndicate that had been operating since 2016 collapsed in February 2019. The syndicate had never provided members with formal account statements, rely
Documentation absent — exchange custody (2019)
Exchange custody
An ICO project that had raised 1,500 BTC in 2017 published its first—and only—financial report in March 2019 before collapsing. The report showed funds 'allocat
Algeria formally banned cryptocurrency transactions in March 2019 under its Finance Law.
Exchange custody
Algeria formally banned cryptocurrency transactions in March 2019 under its Finance Law. Algerian Bitcoin holders who had maintained accounts on foreign exchang
Institutional lockout — exchange custody (2019)
Exchange custody
Chinese authorities intensified crackdowns on OTC Bitcoin trading platforms in March 2019. Dozens of P2P trading platforms were shut down and operators arrested
No other person at QuadrigaCX had access credentials to the exchange's operational
Exchange custody
The E&Y report confirmed that Gerald Cotten had personally controlled all exchange functions and had operated without any documented succession plan. No other p
The attacker threatened to send doctored emails to clients falsely claiming the broker
Exchange custody
A Bitcoin OTC broker was blackmailed in April 2019 by an attacker who had hacked their email and found client correspondence revealing the broker's BTC holdings
Forced relocation — exchange custody (2019)
Exchange custody
Following Central Bank of Nigeria directives in April 2019 discouraging banks from servicing cryptocurrency businesses, Nigerian exchanges faced renewed banking