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%)
Withdrawals of affected tokens were suspended pending the resolution of the SEC actions.
Exchange custody
Survives 2018
The SEC's November 2018 enforcement actions against two ICO projects resulted in asset freezes affecting multiple exchanges that had listed the projects' tokens
An October 2018 case describes a Bitcoin holder incapacitated by a serious accident.
Exchange custody
Survives 2018
An October 2018 case describes a Bitcoin holder incapacitated by a serious accident. Their family attempted to access the exchange account to liquidate holdings
Gox trustee Nobuaki Kobayashi revealed in September 2018 that he had sold approximately
Exchange custody
Constrained 2018
Mt. Gox trustee Nobuaki Kobayashi revealed in September 2018 that he had sold approximately $400 million worth of BTC and BCH from the estate between December 2
A Bitstamp account holder died in August 2018.
Exchange custody
Survives 2018
A Bitstamp account holder died in August 2018. The estate executor contacted Bitstamp and was informed that account transfers required a court order, apostilled
Documentation absent — Coincheck (2018)
Exchange custody
Indeterminate 2018
Coincheck had stored all NEM in a single hot wallet with no multi-signature protection, contrary to industry standards. The exchange had not disclosed this prac
Documentation absent — exchange custody (2018)
Exchange custody
Indeterminate 2018
Italian courts later found that BitGrail's CEO Francesco Firano had been aware of the Nano theft since mid-2017 and had deliberately misrepresented the exchange
Documentation absent — exchange custody (2018)
Exchange custody
Blocked 2018
A Bitcoin fund manager who had raised BTC through informal agreements with friends and family lost 80% of the managed funds through undisclosed leverage trading
When investors demanded redemption, the manager claimed losses from the January 2018
Exchange custody
Blocked 2018
A Bitcoin hedge fund that had raised BTC from high-net-worth individuals in 2017 collapsed in March 2018. The fund manager had never provided audited accounts o
Sanctions lockout — exchange custody (2018)
Exchange custody
Constrained 2018
Russia's Rosfinmonitoring issued new guidance in March 2018 treating cryptocurrency as a potential tool for sanctions circumvention. Several domestic Russian ex
Gox creditor who had been waiting since 2014 for a distribution died in March 2018.
Exchange custody
Constrained 2018
A Mt. Gox creditor who had been waiting since 2014 for a distribution died in March 2018. The estate was unaware of the creditor claim's current status in the c
Within four months of the report the platform suspended operations.
Exchange custody
Indeterminate 2018
A Bitcoin lending platform that had been issuing monthly interest for 18 months posted its first transparency report in May 2018. The report showed headline BTC
Forced relocation — exchange custody (2018)
Exchange custody
Constrained 2018
Chinese Bitcoin holders who had migrated to offshore exchanges after the September 2017 ban faced new complications in June 2018 when multiple offshore exchange
Converting Bitcoin to local currency required accepting punitive rates.
Exchange custody
Constrained 2018
A Bitcoin holder in a country experiencing severe hyperinflation found in June 2018 that all major exchanges had geofenced their home jurisdiction following OFA
Documentation absent — exchange custody (2018)
Exchange custody
Indeterminate 2018
An ICO project that had raised 2,000 BTC in a 2017 token sale collapsed in July 2018 without delivering its product. The founders claimed development costs had
Documentation absent — exchange 2018
Exchange custody
Indeterminate 2018
A Bitcoin staking platform advertised 'proof of reserves' in August 2018 but the proof consisted of screenshots of wallet balances rather than cryptographically
The broker transferred 12 BTC before reporting to police.
Exchange custody
Blocked 2018
A September 2018 incident describes a cryptocurrency OTC broker coerced by organised criminals who threatened violence against their family if they did not tran
Documentation absent — Zaif (2018)
Exchange custody
Indeterminate 2018
Zaif's September 2018 hack involved funds stored in hot wallets, 32% of which were Zaif's own reserves and 68% customer assets. The exchange had never disclosed
Documentation absent — exchange 2018
Exchange custody
Indeterminate 2018
A Bitcoin investment club that had pooled member contributions into a shared wallet since 2016 dissolved in September 2018. The club had maintained a shared spr
Sanctions lockout — exchange custody (2018)
Exchange custody
Constrained 2018
US secondary sanctions tightened significantly in September 2018 following the Trump administration's withdrawal from the Iran nuclear deal. Several global exch
Documentation absent — exchange custody (2018)
Exchange custody
Blocked 2018
Multiple small exchanges that closed in December 2018 during the bear market did not publish final balance snapshots before going offline. Customers who had fun
Owner incapacity — exchange custody (2018)
Exchange custody
Blocked 2018
A cryptocurrency day trader was arrested on unrelated charges in March 2018 and held for 45 days before bail was granted. During that period their exchange acco
Forced relocation — exchange custody (2018)
Exchange custody
Constrained 2018
Following the RBI's April 2018 circular prohibiting banks from serving cryptocurrency businesses, Indian exchanges were forced to close their fiat gateways. Cus
Institutional lockout — exchange custody (2018)
Exchange custody
Survives 2018
Following the IRS's first cryptocurrency tax guidance update in five years, published in draft form in April 2018, multiple US exchanges implemented additional
Multisig quorum failure — 2-of-3 multisig (2018)
Exchange custody
Survives 2018
A Bitcoin family trust structured as a 2-of-3 multisig had one key lost when the key holder's home was destroyed in a fire. The surviving two key holders could
Institutional lockout — exchange custody (2018)
Exchange custody
Constrained 2018
The SEC filed emergency charges in June 2018 against a California-based Bitcoin trading scheme. Court orders froze all assets associated with the defendant incl
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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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