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%)
Sanctions lockout — exchange custody (2024)
Exchange custody
Blocked 2024
Russian residents with Bitcoin on Western exchanges continued to face total access blockage through 2024 under the OFAC and EU sanctions framework. By 2024, add
Under the plan effective January 2024, these customers were projected to recover
Exchange custody
Constrained 2024
Celsius creditors who had held assets in the platform's Earn programme were classified as unsecured creditors throughout the bankruptcy, meaning their recovery
BlockFi had filed for Chapter 11 bankruptcy in November 2022 following FTX's collapse.
Exchange custody
Constrained 2024
BlockFi creditors continued waiting for distributions through 2024. BlockFi had filed for Chapter 11 bankruptcy in November 2022 following FTX's collapse. Throu
Binance subsequently ceased all Nigerian naira services and suspended P2P trading in
Exchange custody
Blocked 2024
In February 2024, Nigerian authorities detained two Binance executives—Tigran Gambaryan, head of financial crime compliance, and Nadeem Anjarwalla, Binance's re
Voyager had filed for bankruptcy in July 2022 and had an initial distribution plan
Exchange custody
Constrained 2024
Voyager Digital customers continued to experience delays in receiving distributions through 2024. Voyager had filed for bankruptcy in July 2022 and had an initi
Platform bankruptcy — exchange custody (2024)
Exchange custody
Blocked 2024
A 2024 estate case involved a deceased Bitcoin holder who had used a now-defunct exchange that had gone out of business in 2019. The exchange had been headquart
Platform bankruptcy — FTX (2024)
Exchange custody
Constrained 2024
On 8 May 2024, FTX filed a proposed reorganisation plan offering 98% of creditors 118% of the value of their claims in cash, based on November 2022 petition-dat
The remaining 3% was expected within 12 months pending additional DCG recoveries.
Exchange custody
Survives 2024
On 21 May 2024, the US Bankruptcy Court for the Southern District of New York confirmed Genesis's reorganisation plan. By end of May 2024, approximately 97% of
Legal authority constraint — exchange custody (2024)
Exchange custody
Constrained 2024
Nigerian authorities arrested two Binance executives in February 2024 and held them for months as part of a dispute over the naira's value and Binance's role in
Gox rehabilitation trustee Nobuaki Kobayashi announced that repayments of Bitcoin
Exchange custody
Constrained 2024
On 24 June 2024, Mt. Gox rehabilitation trustee Nobuaki Kobayashi announced that repayments of Bitcoin and Bitcoin Cash to creditors would commence in July 2024
Legal authority constraint — exchange custody (2024)
Exchange custody
Blocked 2024
An LAPD officer was convicted in late 2024 of physically coercing cryptocurrency holders to force them to transfer approximately $350,000 worth of Bitcoin. The
Gox creditors who received their Bitcoin distributions in July 2024 faced tax questions
Exchange custody
Constrained 2024
Mt. Gox creditors who received their Bitcoin distributions in July 2024 faced tax questions for which there was no established precedent in most jurisdictions.
More than 47,000 BTC valued at approximately $2.7 billion were moved from cold storage
Exchange custody
Constrained 2024
On 5 July 2024, Mt. Gox rehabilitation trustee Nobuaki Kobayashi announced that repayments of Bitcoin and Bitcoin Cash had commenced. The first distributions we
Creditors needed to have registered with the designated exchange partners, completed
Exchange custody
Constrained 2024
A significant cohort of Mt. Gox creditors who had not maintained active contact with the rehabilitation process over the preceding decade faced practical obstac
Institutional lockout — Celsius (2024)
Exchange custody
Constrained 2024
A recurring practical obstacle for Celsius distributions in 2024 was the claims portal itself. Creditors who had not logged in since 2022, whose email addresses
Platform bankruptcy — exchange custody (2024)
Exchange custody
Survives 2024
Silvergate Capital, a crypto-focused bank that had been a critical fiat on-ramp for major exchanges and institutions, filed for Chapter 7 bankruptcy in Septembe
Institutional lockout — FTX (2024)
Exchange custody
Indeterminate 2024
FTX creditors who had submitted claims but subsequently failed to pass KYC verification by the distribution agents faced a secondary blockage in late 2024 as th
Legal authority constraint — exchange custody (2024)
Exchange custody
Indeterminate 2024
Tigran Gambaryan was released from Nigerian detention on humanitarian grounds in October 2024 after eight months in custody, during which he contracted malaria,
Platform bankruptcy — FTX (2024)
Exchange custody
Constrained 2024
On 7 October 2024, US Bankruptcy Judge John Dorsey of the District of Delaware confirmed FTX's reorganisation plan, approving the distribution of more than $14
Owner incapacity — exchange custody (2024)
Exchange custody
Survives 2024
A UK elder law solicitor described a 2024 case involving a 78-year-old Binance user who had suffered a stroke and could no longer use a smartphone—necessary for
Owner incapacity — Coinbase (2024)
Exchange custody
Survives 2024
A 2024 power of attorney case in Texas involved a family attempting to access the Coinbase account of an incapacitated relative. The family held a durable POA t
Owner death — Kraken (2024)
Exchange custody
Survives 2024
A 2024 exchange estate access case on Kraken involved a beneficiary who held the deceased's death certificate and a copy of the will but encountered a verificat
Estate access failure — Coinbase (2024)
Exchange custody
Survives 2024
An Australian estate case in 2024 involved a deceased holder whose Coinbase account was identified by their executor but who had used a mobile phone number for
Sanctions lockout — FTX (2024)
Exchange custody
Indeterminate 2024
FTX creditors in jurisdictions flagged by OFAC faced a unique obstacle in the 2024 reorganisation plan: the distribution agents—BitGo, Kraken, and Payoneer—were
Legal authority constraint — exchange custody (2024)
Exchange custody
Blocked 2024
The US Department of Justice seized approximately $2 billion in Bitcoin connected to the Silk Road in March 2024, following a court ruling that the government h
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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.