CustodyStress
Archive › Exchange custody
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%)
Hidden wallet discovered — exchange custody (2019)
Exchange custody
Indeterminate 2019
Grant Thornton, appointed liquidator for Cryptopia in May 2019, found that the exchange had pooled all customer funds in a single shared wallet rather than main
Bank accounts used for OTC Bitcoin settlement were frozen across dozens of banks.
Exchange custody
Constrained 2019
Chinese authorities launched a targeted operation against offshore exchange accounts operated by Chinese nationals in June 2019. Bank accounts used for OTC Bitc
Estate access failure — Coinbase (2019)
Exchange custody
Survives 2019
A Bitcoin holder died in June 2019 leaving a Coinbase account with a substantial balance. The estate's executor was located in a different country and needed to
Binance disputed the authenticity of the data but acknowledged a third-party KYC
Exchange custody
Indeterminate 2019
In July 2019 Binance experienced a reported KYC data leak where a Telegram channel began posting KYC documents — passport photos and identity documents — of Bin
A Bitcoin-backed energy trading platform collapsed in July 2019.
Exchange custody
Blocked 2019
A Bitcoin-backed energy trading platform collapsed in July 2019. The platform had claimed to use blockchain for energy certificate verification, but independent
The platform's CEO published a blog post saying all BTC had been lost in a hack
Exchange custody
Indeterminate 2019
A Bitcoin lending platform that had been paying monthly returns suspended operations in August 2019 and claimed insolvency. The platform's CEO published a blog
A Bitcoin OTC trading desk collapsed in September 2019 with disputed balances.
Exchange custody
Indeterminate 2019
A Bitcoin OTC trading desk collapsed in September 2019 with disputed balances. Clients had deposited BTC for settlement purposes. The desk's internal accounting
Iran's ongoing US sanctions situation intensified in September 2019.
Exchange custody
Constrained 2019
Iran's ongoing US sanctions situation intensified in September 2019. Virtually all international exchanges had geofenced Iranian users. Iranian Bitcoin holders
Their account was suspended pending KYC completion.
Exchange custody
Constrained 2019
A Bitcoin user in Libya who had maintained BTC on a foreign exchange found in October 2019 that escalating conflict had made it impossible to complete the ident
Gox rehabilitation creditor died in October 2019.
Exchange custody
Constrained 2019
A Mt. Gox rehabilitation creditor died in October 2019. The estate's executor found that the claim deadline for the rehabilitation proceeding had passed while p
Institutional lockout — QuadrigaCX (2019)
Exchange custody
Blocked 2019
The Ontario Securities Commission expanded its investigation into QuadrigaCX in December 2019, seeking additional documents from Cotten's estate. The expanded i
Owner death — QuadrigaCX (2019)
Exchange custody
Blocked 2019
A QuadrigaCX customer died in February 2019 while the exchange was under CCAA protection. Their estate, already dealing with a personal bereavement, discovered
Owner incapacity — exchange custody (2019)
Exchange custody
Blocked 2019
A Bitcoin trader was remanded in custody in March 2019 pending trial on unrelated charges. Their exchange account held leveraged positions requiring active mana
Estate access failure — exchange custody (2019)
Exchange custody
Survives 2019
A May 2019 estate case involved a deceased who had purchased Bitcoin through a business and held it in a corporate account. The estate had to navigate both prob
Physical coercion — exchange custody (2019)
Exchange custody
Constrained 2019
A cryptocurrency exchange employee was subjected to a prolonged social engineering campaign in June 2019. The attacker spent three weeks posing as an IT support
Account frozen — exchange custody (2019)
Exchange custody
Constrained 2019
The SEC brought enforcement action against a Bitcoin trading scheme operator in June 2019, seeking emergency asset freeze. The court's ex parte order froze asse
Multisig quorum failure — 2-of-3 multisig (2019)
Exchange custody
Survives 2019
A June 2019 case describes a 2-of-3 multisig Bitcoin custody arrangement for a small family office where one key holder's spouse died and the key holder entered
Estate access failure — exchange custody (2019)
Exchange custody
Survives 2019
A November 2019 estate case involved a deceased who had used their Bitcoin exchange account as a primary savings vehicle. The exchange required proof that the d
The exchange's books showed large customer liabilities that had no corresponding
Exchange custody
Indeterminate 2019
The E&Y forensic investigation into QuadrigaCX found that Gerald Cotten had operated six 'cold wallets' that were actually empty or nearly empty. The exchange's
Bittrex immediately suspended all New York customer account registration.
Exchange custody
Survives 2019
Bittrex was denied a BitLicense by the New York Department of Financial Services in March 2019 for inadequate AML controls. Bittrex immediately suspended all Ne
Bitfinex and Tether were sued by the New York Attorney General in April 2019.
Exchange custody
Survives 2019
Bitfinex and Tether were sued by the New York Attorney General in April 2019. The NYAG alleged that Tether had backstopped Bitfinex's $850 million hole using Te
The exchange required in-person identity verification to reset the 2FA to a new phone.
Exchange custody
Survives 2019
A Bitcoin trader serving a prison sentence found in April 2019 that their exchange's 2FA had expired and could not be renewed without a working phone number. Th
The US Congress held hearings on Facebook's Libra cryptocurrency in May 2019.
Exchange custody
Survives 2019
The US Congress held hearings on Facebook's Libra cryptocurrency in May 2019. The associated regulatory attention caused several US exchanges to reassess their
A Bitcoin trader was hospitalised for eight weeks following a cardiac event in May 2019.
Exchange custody
Blocked 2019
A Bitcoin trader was hospitalised for eight weeks following a cardiac event in May 2019. Their exchange account had open margin positions that were auto-liquida
A Bitfinex account holder died in November 2018.
Exchange custody
Survives 2018
A Bitfinex account holder died in November 2018. Their estate found the account had a significant BTC balance. The exchange required a court order specifically
← Previous Next →
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.
Original text
Rate this translation
Your feedback will be used to help improve Google Translate