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%)
Multisig quorum failure — exchange custody (2018)
Exchange custody
Constrained 2018
A June 2018 case describes a DAO-structured investment vehicle whose Bitcoin treasury required token holder votes to release funds. During a governance attack,
Forced relocation — exchange custody (2018)
Exchange custody
Survives 2018
Following Zebpay's September 2018 closure, Indian Bitcoin holders who had used the platform as their primary exchange were forced to migrate to offshore exchang
Institutional lockout — exchange custody (2018)
Exchange custody
Survives 2018
The SEC issued a report in September 2018 that several token exchanges had been operating as unregistered securities exchanges. Multiple platforms suspended US
Account frozen — exchange custody (2018)
Exchange custody
Survives 2018
Following the UK's finalisation of Brexit terms in December 2018, several EU-licensed exchanges notified UK customers that their EU-passported services would te
The Coincheck hack triggered an immediate FSA crackdown.
Exchange custody
Survives 2018
The Coincheck hack triggered an immediate FSA crackdown. Japan's Financial Services Agency issued emergency on-site inspections of all licensed and operating cr
A Bitcoin investor suffered a stroke in February 2018 that caused partial aphasia.
Exchange custody
Survives 2018
A Bitcoin investor suffered a stroke in February 2018 that caused partial aphasia. They retained cognitive understanding of their holdings but could not reliabl
Bithumb deleted its tweets about the June 2018 hack within days of the announcement.
Exchange custody
Constrained 2018
Bithumb deleted its tweets about the June 2018 hack within days of the announcement. Security researchers who had archived the original announcements noted inco
The trader transferred 4 BTC under duress.
Exchange custody
Constrained 2018
A well-known UK Bitcoin trader was the victim of a home invasion in July 2018. Attackers forced the trader to transfer all accessible Bitcoin from their primary
A Bitcoin custody arrangement for a small foundation used a 2-of-3 multisig.
Exchange custody
Survives 2018
A Bitcoin custody arrangement for a small foundation used a 2-of-3 multisig. The foundation's accountant, who held one key, was fired following an embezzlement
Several large European exchanges launched early implementation programmes in August
Exchange custody
Survives 2018
The EU's Fifth Anti-Money Laundering Directive (5AMLD) was published in July 2018 with a transposition deadline of January 2020. Several large European exchange
Platform bankruptcy — exchange custody (2018)
Exchange custody
Blocked 2018
Italian police confiscated all of BitGrail's remaining cryptocurrency assets in March 2018 as part of a criminal investigation into Firano. The confiscation ord
The independent third party relocated internationally in September 2017 and their
Exchange custody
Survives 2017
A Bitcoin family trust used a 2-of-3 multisig where the three key holders were the trustee, the grantor, and an independent third party. The independent third p
Bithumb declined to disclose the precise amount stolen in its July 2017 hack.
Exchange custody
Constrained 2017
Bithumb declined to disclose the precise amount stolen in its July 2017 hack. Estimates from security researchers ranged from several hundred to several thousan
The trustee firm merged with a competitor in June 2017 and the key was migrated to
Exchange custody
Survives 2017
A Bitcoin inheritance arrangement using a 1-of-2 multisig designed for survivorship had a key held by a professional trustee. The trustee firm merged with a com
A Coinbase account holder died in May 2017.
Exchange custody
Survives 2017
A Coinbase account holder died in May 2017. Coinbase's estate process required a court order, a death certificate with apostille, and a notarised letter from th
The fund's BTC was inaccessible for two months while negotiations continued.
Exchange custody
Survives 2017
A Bitcoin venture fund's treasury was held in a 3-of-5 multisig. In April 2017 the fund underwent a restructuring in which two key holders were removed without
Documentation absent — exchange — Japan 2017
Exchange custody
Constrained 2017
The Mt. Gox civil rehabilitation process in 2017 required creditors to resubmit claims using an updated online portal. Hundreds of creditors whose original docu
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Following the Chinese exchange ban, the PBoC issued further guidance in October 2017 targeting offshore exchanges with Chinese-language interfaces. VPN usage to
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Following the South Korean government's December 2017 announcement about a potential exchange ban, multiple exchanges implemented real-name verification require
Gox creditor died in October 2017 before the civil rehabilitation claim process was
Exchange custody
Constrained 2017
A Mt. Gox creditor died in October 2017 before the civil rehabilitation claim process was complete. The creditor's estate was unaware that the Mt. Gox claim was
Documentation absent — exchange 2017
Exchange custody
Indeterminate 2017
A Bitcoin investment club that had been operating since 2014 dissolved in February 2017 following an internal dispute. The club had never maintained formal acco
When a run on the exchange occurred in April 2017 following rumours of insolvency,
Exchange custody
Blocked 2017
An exchange that had been operating since 2014 was found to have been operating fractional reserves. When a run on the exchange occurred in April 2017 following
Members had contributed varying amounts of BTC over two years.
Exchange custody
Blocked 2017
A Bitcoin investment syndicate that had operated since 2015 dissolved in July 2017. Members had contributed varying amounts of BTC over two years. The syndicate
Physical coercion — exchange custody (2017)
Exchange custody
Blocked 2017
An exchange employee was targeted in June 2017 by an attacker who gained leverage through compromising personal communications. The attacker demanded that the e
Hidden wallet discovered — exchange custody (2017)
Exchange custody
Blocked 2017
A Bitcoin high-yield investment programme collapsed in June 2017 after four months of operation. The operator had never published proof of how returns were gene
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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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