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%)
Documentation absent — exchange 2023
Exchange custody
Constrained 2023
Mt. Gox creditors who had not retained documentation of their 2014 holdings encountered a claims verification problem in 2023 as the trustee prepared for distri
The Celsius bankruptcy court approved creditor voting on a reorganization plan
Exchange custody
Constrained 2023
In August 2023, the Celsius bankruptcy court approved creditor voting on a reorganization plan involving the sale of assets to the Fahrenheit consortium. Court
98% of Celsius creditors voted in favor of the reorganization plan, an overwhelming
Exchange custody
Constrained 2023
In September 2023, 98% of Celsius creditors voted in favor of the reorganization plan, an overwhelming mandate reflecting customers' preference for any structur
Over 2,000 complaints were filed with Hong Kong police.
Exchange custody
Blocked 2023
The September 2023 JPEX collapse in Hong Kong saw an estimated HK$1.4 billion (approximately $180 million USD) frozen when the exchange suspended withdrawals. T
The SEC objected to Celsius's plan to use Coinbase as a distribution agent
Exchange custody
Constrained 2023
In September 2023, the SEC objected to Celsius's plan to use Coinbase as a distribution agent for international customers, arguing the arrangement exceeded a ty
The government subsequently blocked access to the websites of these exchanges
Exchange custody
Constrained 2023
Indian crypto exchanges faced a series of enforcement actions in 2023. India's Financial Intelligence Unit issued show-cause notices to several offshore exchang
However, actual distributions did not begin until January 2024, when the plan became
Exchange custody
Constrained 2023
On 9 November 2023, Bankruptcy Judge Martin Glenn confirmed Celsius's Chapter 11 reorganization plan. The confirmation—18 months after the initial withdrawal fr
Platform bankruptcy — Celsius (2023)
Exchange custody
Constrained 2023
As Bitcoin's price began recovering in Q4 2023—approaching $35,000 by October—Celsius, Genesis, and Voyager creditors found themselves in an ironic situation: t
Binance CEO Changpeng Zhao pleaded guilty to federal money laundering charges as part
Exchange custody
Constrained 2023
In December 2023, Binance CEO Changpeng Zhao pleaded guilty to federal money laundering charges as part of a $4.3 billion settlement between Binance and US auth
The April 2023 deadline for Mt.
Exchange custody
Indeterminate 2023
The April 2023 deadline for Mt. Gox creditors to provide repayment information revealed that many creditors had not updated their contact details or banking inf
Circle's USDC briefly de-pegged when $3.3 billion of its reserves were confirmed at SVB.
Exchange custody
Survives 2023
The March 2023 collapse of Silvergate Bank and Silicon Valley Bank—both of which provided banking services to crypto companies—caused temporary access disruptio
When the bankruptcy required active participation to recover funds—including
Exchange custody
Blocked 2023
Bittrex's bankruptcy revealed a documentation problem specific to long-inactive accounts: the exchange had millions of customers who had opened accounts years e
Platform bankruptcy — Celsius (2023)
Exchange custody
Indeterminate 2023
By mid-2023 the combined Celsius, Voyager, FTX, BlockFi, and Genesis bankruptcy proceedings had produced a distinct new problem for estate executors: multiple o
Platform bankruptcy — Celsius (2023)
Exchange custody
Indeterminate 2023
As Celsius, Voyager, and Genesis creditors waited through 2023 for resolution, tax professionals identified a specific custody stress that extended beyond acces
Platform bankruptcy — exchange custody (2023)
Exchange custody
Survives 2023
Bittrex's August 2023 deadline for customers to claim assets through the bankruptcy process required all claimants to complete KYC verification—including provid
Platform bankruptcy — Celsius (2023)
Exchange custody
Constrained 2023
A July 2023 Celsius bankruptcy court ruling extended the January 2023 Earn decision to retail borrowers, holding that customers who had borrowed from Celsius an
Estate access failure — Coinbase (2023)
Exchange custody
Survives 2023
A 2023 Coinbase estate access case involved a beneficiary who held a death certificate and the deceased's government ID but could not produce a copy of the will
Platform bankruptcy — exchange custody (2023)
Exchange custody
Survives 2023
The US Department of Justice filed a motion in June 2023 to block Bittrex's plan to repay customers before government creditors—including OFAC (owed $24 million
Platform bankruptcy — FTX (2023)
Exchange custody
Indeterminate 2023
FTX estate administrators in 2023 began the process of identifying and clawing back funds from various counterparties, including exchanges, lending desks, and i
Institutional lockout — Coinbase (2023)
Exchange custody
Survives 2023
The June 2023 SEC lawsuits against Coinbase and Binance prompted immediate self-protective actions by both exchanges. Coinbase restricted certain trading pairs
Platform bankruptcy — exchange custody (2023)
Exchange custody
Survives 2023
On 8 May 2023, Bittrex filed for Chapter 11 bankruptcy in Delaware after the SEC sued the exchange in April for operating an unregistered securities exchange. U
Owner incapacity — Kraken (2023)
Exchange custody
Survives 2023
A family member acting under a durable power of attorney for an incapacitated Bitcoin holder encountered a systematic barrier at Kraken in 2023: the exchange re
Platform bankruptcy — Celsius (2023)
Exchange custody
Indeterminate 2023
Estate executors dealing with Celsius, Voyager, FTX, or BlockFi holdings in 2023 faced a compounded custody problem: the deceased had held Bitcoin on one or mor
Estate access failure — Coinbase (2023)
Exchange custody
Survives 2023
A 2023 probate case in Florida involved a deceased Bitcoin holder who had accounts on three different exchanges—Coinbase, Kraken, and a now-defunct smaller exch
Sanctions lockout — exchange custody (2023)
Exchange custody
Indeterminate 2023
Russian individuals who had moved crypto to non-Western exchanges in 2022 to avoid sanction-related restrictions found in 2023 that those exchanges—some based i
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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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