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%)
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Russia's Rosfinmonitoring published new guidance in June 2017 requiring domestic financial institutions to block transfers to cryptocurrency exchanges. Several
Documentation absent — exchange 2017
Exchange custody
Blocked 2017
AlphaBay's escrow system had never published a proof-of-reserves or auditable balance mechanism. When the market was seized, users had no independent record of
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Bangladesh Bank issued a formal directive in July 2017 prohibiting all Bitcoin transactions by Bangladeshi nationals. Bangladeshis who held BTC on international
Holders faced a choice between converting at a punitive rate or leaving Bitcoin
Exchange custody
Constrained 2017
Zimbabwe's Bitcoin premium — driven by a shortage of US dollars — led several Zimbabwean Bitcoin holders to hold BTC on international exchanges to access dollar
Institutional lockout — exchange custody (2017)
Exchange custody
Blocked 2017
The CFTC filed an action in August 2017 against a Bitcoin trading scheme operator, resulting in a court-ordered asset freeze. Customer BTC held by the operator
Institutional lockout — exchange custody (2017)
Exchange custody
Constrained 2017
The CFTC's August 2017 enforcement action against a Bitcoin trading scheme resulted in an asset freeze that also affected several customers who had participated
Owner incapacity — exchange custody (2017)
Exchange custody
Constrained 2017
A cryptocurrency investor was in a six-week rehabilitation programme in August 2017, during which internet access was prohibited. Their exchange account held po
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Huobi and OKCoin, forced to cease China-mainland operations by the September 2017 ban, migrated their platforms offshore to Hong Kong and international markets.
Forced relocation — exchange custody (2017)
Exchange custody
Survives 2017
Chinese Bitcoin users who had held accounts on domestic exchanges were forced to liquidate or transfer holdings to overseas exchanges following the September 20
The total transferred was approximately 8 BTC.
Exchange custody
Blocked 2017
An October 2017 reported incident describes a Bitcoin business owner coerced by organised crime into transferring operational BTC to an attacker-controlled wall
Platform bankruptcy — exchange custody (2017)
Exchange custody
Indeterminate 2017
YouBit's December 2017 bankruptcy filing never disclosed the precise amount stolen in either the April or December hacks. The exchange's total asset disclosures
Institutional lockout — exchange custody (2017)
Exchange custody
Survives 2017
Japan's Payment Services Act licensing requirement for Bitcoin exchanges took effect in April 2017. In March, exchanges that had not yet completed registration
Documentation absent — exchange custody (2017)
Exchange custody
Constrained 2017
A Bitcoin-backed mortgage product offered to overseas property buyers collapsed in June 2017. The product documentation did not specify what happened to BTC col
Owner incapacity — exchange custody (2017)
Exchange custody
Survives 2017
A Bitcoin holder in a long-term care facility in July 2017 had a significant exchange account. Their power of attorney had not been updated to cover digital ass
Owner death — Bitfinex (2017)
Exchange custody
Survives 2017
A Bitfinex account holder who had BFX tokens still outstanding from the 2016 hack died in September 2017. The estate discovered the BFX token redemption process
Passphrase unavailable — exchange custody (2017)
Exchange custody
Survives 2017
An exchange account holder who had not logged in since 2014 found in September 2017 that the exchange had migrated to a new authentication system. Their old pas
Institutional lockout — Coinbase (2017)
Exchange custody
Survives 2017
The IRS won a court case in November 2017 requiring Coinbase to turn over records of 14,355 customers who had transacted more than $20,000 in any single year. C
Owner incapacity — Coinbase (2017)
Exchange custody
Survives 2017
A cryptocurrency investor with late-stage dementia had a Coinbase account with a substantial BTC balance in November 2017. Their family initiated a conservators
Physical coercion — exchange custody (2017)
Exchange custody
Constrained 2017
On 26 December 2017 Pavel Lerner, CEO of EXMO Bitcoin exchange, was kidnapped in Kyiv and held for ransom. The kidnappers demanded $1 million in Bitcoin. Lerner
Documentation absent — NiceHash (2017)
Exchange custody
Constrained 2017
NiceHash's December 2017 hack announcement did not confirm the precise BTC amount stolen, citing an ongoing investigation. Security researchers independently id
The SEC issued a ruling in July 2017 that the DAO tokens constituted securities.
Exchange custody
Survives 2017
The SEC issued a ruling in July 2017 that the DAO tokens constituted securities. Several US-based platforms that had supported DAO-related activities suspended
When a partner demanded an accounting in March 2017, the lead trader produced records
Exchange custody
Indeterminate 2017
A Bitcoin investment partnership used an informal agreement to divide trading profits. When a partner demanded an accounting in March 2017, the lead trader prod
Owner incapacity — exchange 2016
Exchange custody
Survives 2016
A Bitcoin day trader was diagnosed with a terminal illness in December 2016 and needed to liquidate exchange holdings to cover medical expenses. Their exchange
Owner incapacity — exchange 2016
Exchange custody
Survives 2016
A Bitcoin exchange account holder with late-stage Alzheimer's disease in October 2016 had a family member attempt to gain access to their exchange account. The
PBoC officials visited the three major Chinese Bitcoin exchanges and issued formal
Exchange custody
Constrained 2016
In January 2016 PBoC officials visited the three major Chinese Bitcoin exchanges (BTC China, Huobi, OKCoin) and issued formal warnings about leverage trading an
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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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