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 (2024)
Exchange custody
Indeterminate 2024
Palestinians holding Bitcoin on international exchanges faced a layered access problem in 2024: some exchanges had restricted accounts for Palestinian passport
Estate access failure — exchange custody (2024)
Exchange custody
Indeterminate 2024
As the 2024 bull market drove Bitcoin toward new highs, digital asset estate attorneys reported a significant rise in estate access engagements involving exchan
Institutional lockout — Coinbase (2024)
Exchange custody
Survives 2024
Following the SEC approval of spot Bitcoin ETFs in January 2024, several crypto exchanges and custodians reported record onboarding backlogs. Custodians approve
Platform bankruptcy — exchange custody (2024)
Exchange custody
Survives 2024
The January 2024 approval of spot Bitcoin ETFs in the United States led to a surge in trading volume that stressed some exchange infrastructure. Several smaller
Platform bankruptcy — Celsius (2024)
Exchange custody
Constrained 2024
On 16 January 2024, the Celsius Network bankruptcy plan became effective and distributions began to creditors who had filed claims. The plan involved returning
Hidden wallet discovered — exchange custody (2024)
Exchange custody
Blocked 2024
Bitcoin holders in Sudan who had used mobile money–linked exchange accounts found their access completely severed during the escalating civil war in 2024. Banki
Gox rehabilitation trustee Nobuaki Kobayashi extended the creditor repayment deadline
Exchange custody
Indeterminate 2023
In September 2023, Mt. Gox rehabilitation trustee Nobuaki Kobayashi extended the creditor repayment deadline from 31 October 2023 to 31 October 2024, citing del
The New York Attorney General filed suit alleging that Genesis and Gemini had concealed
Exchange custody
Constrained 2023
In October 2023, the New York Attorney General filed suit alleging that Genesis and Gemini had concealed more than $1.1 billion in losses from investors who dep
Former Celsius CEO Alex Mashinsky was arrested and charged with securities fraud
Exchange custody
Constrained 2023
In July 2023, former Celsius CEO Alex Mashinsky was arrested and charged with securities fraud, commodities fraud, wire fraud, and conspiracy to manipulate the
The 2023 Binance settlement included findings about sanctions evasion facilitation.
Exchange custody
Blocked 2023
North Korean citizens and organisations designated under US, EU, and UN sanctions continued in 2023 to be blocked from all Western-linked crypto services. Attem
Platform bankruptcy — Gemini (2023)
Exchange custody
Constrained 2023
On 12 January 2023, the SEC charged Genesis Global Capital and Gemini Trust Company with the unregistered offer and sale of securities through the Gemini Earn p
Its collapse meant Voyager creditors—still blocked from their Bitcoin since July
Exchange custody
Constrained 2023
In January 2023, US regulators blocked the proposed $1.02 billion acquisition of Voyager's assets by Binance US, citing national security and regulatory concern
Some creditors received fiat payments via bank transfer and PayPal in December
Exchange custody
Constrained 2023
In November 2023, the Mt. Gox trustee sent an email to creditors stating that cash repayments would commence 'shortly' within the 2023 calendar year but would l
Platform bankruptcy — FTX (2023)
Exchange custody
Indeterminate 2023
FTX creditors in October 2023 faced a claims deadline for submitting proofs of claim in the bankruptcy. The process required logging into a claims portal, verif
Legal authority constraint — FTX (2023)
Exchange custody
Indeterminate 2023
On 2 November 2023, Sam Bankman-Fried was convicted on all seven counts of fraud and conspiracy in a New York federal court. The conviction—while vindicating cr
Legal authority constraint — exchange custody (2023)
Exchange custody
Survives 2023
Binance's November 2023 $4.3 billion settlement with the US Department of Justice and other regulators—and the departure of CEO Changpeng Zhao—triggered a brief
Platform bankruptcy — exchange custody (2023)
Exchange custody
Survives 2023
Bittrex Global—the non-US arm of Bittrex that had continued operating while the US entity went through bankruptcy—announced in early December 2023 that it was c
Sanctions lockout — Coinbase (2023)
Exchange custody
Blocked 2023
Russian residents whose Bitcoin was held on Western exchanges continued to be blocked in 2023 following the February 2022 sanctions. Kraken, Coinbase, and Binan
For the 340,000 Earn users still blocked, this was the first concrete indication of
Exchange custody
Constrained 2023
In February 2023, Gemini announced it would contribute up to $100 million of its own cash to the Genesis bankruptcy recovery plan, specifically earmarked for Ge
Platform bankruptcy — FTX (2023)
Exchange custody
Constrained 2023
BlockFi's bankruptcy estate spent much of 2023 in complex negotiations with the FTX bankruptcy estate, which owed BlockFi approximately $355 million and against
Institutional lockout — exchange custody (2023)
Exchange custody
Constrained 2023
Babel Finance, the Hong Kong-based crypto lender that had frozen withdrawals in June 2022, secured a moratorium on legal proceedings in Q2 2023 as it pursued a
Institutional lockout — exchange custody (2023)
Exchange custody
Blocked 2023
JPEX, a Hong Kong-based crypto exchange, began showing signs of stress in mid-2023, ultimately blocking customer withdrawals in September 2023. The exchange, he
BKex exchange suspended all customer withdrawals, citing an ongoing money laundering
Exchange custody
Blocked 2023
In May 2023, BKex exchange suspended all customer withdrawals, citing an ongoing money laundering probe. The exchange then shut down its website, apps, and cust
The SEC's enforcement actions against Coinbase and Binance named over 60 tokens as
Exchange custody
Constrained 2023
In June 2023, the SEC's enforcement actions against Coinbase and Binance named over 60 tokens as securities. Both exchanges moved quickly to delist or restrict
Legal authority constraint — Coinbase (2023)
Exchange custody
Constrained 2023
The SEC's June 2023 lawsuits against Coinbase and Binance triggered significant uncertainty about the regulatory status of multiple cryptocurrencies, with the S
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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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