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%)
Estate access failure — Kraken (2025)
Exchange custody
A 2025 Kraken estate access case involved an executor who discovered that the deceased holder had registered their Kraken account under a pseudonym that did not
Estate access failure — Coinbase (2025)
Exchange custody
A 2025 industry survey found that cryptocurrency estate access requests had become a significant operational category for major exchanges, with Coinbase, Kraken
Platform bankruptcy — FTX (2025)
Exchange custody
Voyager Digital's bankruptcy distribution process continued in 2025, with creditors of the platform—which had frozen withdrawals in July 2022—still awaiting fin
Institutional lockout — FTX (2025)
Exchange custody
A class of FTX creditors that remained structurally disadvantaged through all 2025 distribution rounds were those who had originally deposited Bitcoin but whose
Institutional lockout — Coinbase (2025)
Exchange custody
Bitcoin ETF custody infrastructure continued to concentrate around Coinbase Custody Trust in 2025. By mid-year, Coinbase held custody for the overwhelming major
Forced relocation — exchange custody (2025)
Exchange custody
Bitcoin holders in conflict-affected regions of East Africa faced complete access disruption in 2025 as civil war in Sudan and ongoing conflicts in parts of Eth
Forced relocation — exchange custody (2025)
Exchange custody
Bitcoin holders in areas of Myanmar controlled by the military junta continued to face severe internet restrictions and communication blackouts in 2025. Regions
Institutional lockout — FTX (2025)
Exchange custody
FTX announced a second major distribution of approximately $5 billion scheduled for May 30, 2025. This second phase covered non-Convenience Class creditors—prim
Sanctions lockout — exchange custody (2025)
Exchange custody
US Treasury expanded OFAC sanctions designations related to North Korean cryptocurrency activities in 2025, designating additional exchanges and individuals con
Institutional lockout — FTX (2025)
Exchange custody
Multiple FTX creditors in jurisdictions newly added to the list of eligible distribution countries in January 2025 found that their distribution service provide
For creditors who had been frozen since November 2022, the distribution ended
Exchange custody
Genesis Global Capital completed its debt restructuring in August 2024, distributing approximately $4 billion in digital assets and US dollars to creditors. The
Gox creditors who chose to receive their distributions through Kraken discovered
Exchange custody
Mt. Gox creditors who chose to receive their distributions through Kraken discovered that Kraken required up to 90 days from the moment Bitcoin was transferred
Paradoxically, the ETF approval highlighted an existing access problem: millions of
Exchange custody
In June 2024, the SEC approved the first US spot Bitcoin ETFs from BlackRock, Fidelity, and others—opening a regulated access pathway for institutional and reta
A mid-tier crypto exchange that had been operating since 2019 announced it was
Exchange custody
In June 2024, a mid-tier crypto exchange that had been operating since 2019 announced it was suspending withdrawal processing for all users to 'investigate susp
Coinbase required a death certificate plus letters testamentary, typically a 4–8 week
Exchange custody
A 2024 analysis of exchange estate access procedures by a digital estate planning firm found significant variation across major platforms. Coinbase required a d
The announcement ended a 15-month period during which approximately 340,000 Earn users
Exchange custody
On 28 February 2024, Gemini announced it had reached a settlement in principle with Genesis and other creditors that would result in all Gemini Earn users recei
Coinbase, which had been subject to an SEC enforcement action since June 2023
Exchange custody
In early 2024, former US President Donald Trump began actively campaigning on a pro-Bitcoin platform, including proposals for a strategic Bitcoin reserve. As cr
Following Donald Trump's election victory on a pro-crypto platform, the SEC began
Exchange custody
In November 2024, following Donald Trump's election victory on a pro-crypto platform, the SEC began signalling a shift in its enforcement posture under the inco
A creditor who deposited 1 BTC in October 2022—when Bitcoin was worth approximately
Exchange custody
Many FTX creditors who expected to receive 119% of their November 2022 claim values in cash described a practical access problem: their claim was denominated in
Gox trustee Kobayashi announced that most repayments to verified creditors had been
Exchange custody
On 10 October 2024, Mt. Gox trustee Kobayashi announced that most repayments to verified creditors had been completed but that approximately 34,689 BTC remained
Court approval of the FTX reorganisation plan, international creditors across more than
Exchange custody
Following the October 2024 court approval of the FTX reorganisation plan, international creditors across more than 200 jurisdictions faced varying timelines and
Sanctions lockout — exchange custody (2024)
Exchange custody
Russian nationals remained completely blocked from all major Western exchange platforms through 2024 under OFAC and EU sanctions. Despite the legal complexity o
The announcement—more than 14 months after FTX froze customer withdrawals in November
Exchange custody
In January 2024, FTX CEO John Jay Ray III revised the estate's recovery estimate upward, telling the Delaware bankruptcy court that he expected to be able to pa
The settlement established a victims' fund for the 29,000 New York investors who had
Exchange custody
The New York Attorney General reached a $2 billion settlement with Genesis Global Capital in early 2024. The settlement established a victims' fund for the 29,0
Institutional lockout — Celsius (2024)
Exchange custody
Celsius customers who had received partial BTC and ETH distributions in January 2024 under the reorganisation plan then discovered that the equity component of
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