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%)
Platform bankruptcy — FTX (2023)
Exchange custody
FTX creditors attempting to submit claims in early 2023 encountered a pervasive documentation problem: FTX's pre-bankruptcy records were incomplete, disorganise
Institutional lockout — exchange custody (2023)
Exchange custody
Nexo, a crypto lender, reached a $45 million settlement with a coalition of US state regulators in January 2023 after being accused of operating illegally as an
Institutional lockout — FTX (2023)
Exchange custody
Throughout the first half of 2023, FTX creditors navigated a complex claims submission process managed by new CEO John Ray III. The process required submission
Platform bankruptcy — Celsius (2023)
Exchange custody
On 4 January 2023, Judge Martin Glenn of the Southern District of New York ruled definitively that Celsius's Earn account funds belonged to the Celsius bankrupt
Platform bankruptcy — Gemini (2023)
Exchange custody
On 19 January 2023, Genesis Global Capital filed for Chapter 11 bankruptcy protection in the Southern District of New York, listing liabilities between $1.2 bil
Celsius filed for Chapter 11 bankruptcy on 13 July 2022.
Exchange custody
On 12 June 2022 Celsius Network froze all withdrawals, swaps, and transfers for its approximately 1.7 million users without prior warning. The platform cited 'e
Voyager filed for Chapter 11 bankruptcy on 5–6 July 2022.
Exchange custody
On 1 July 2022, Voyager Digital suspended all trading, deposits, withdrawals, and loyalty rewards for its approximately 3.5 million customers. The company cited
Hodlnaut had approximately $500 million in assets under management and had suffered
Exchange custody
On 8 August 2022, Singapore-based crypto lender Hodlnaut froze all withdrawals, token swaps, and deposits, citing 'recent market conditions.' The company simult
Documentation absent — exchange — Japan 2022
Exchange custody
Many Mt. Gox creditors attempting to register their 2022 claims encountered documentation barriers stemming from the 2014 collapse era. Original account stateme
Gox rehabilitation trustee Nobuaki Kobayashi set a deadline of 15 September 2022
Exchange custody
In September 2022, Mt. Gox rehabilitation trustee Nobuaki Kobayashi set a deadline of 15 September 2022 for the approximately 127,000 creditors to register thei
Institutional custody dependency — exchange — Japan 2022
Exchange custody
After the September 2022 Mt. Gox claim registration deadline passed, the trustee still could not set a repayment date, stating it would be determined 'in due co
Bahamian regulators seized approximately $3.5 billion in assets from FTX Digital
Exchange custody
International FTX customers—particularly those on FTX.com rather than the US-only FTX.US—found their accounts immediately frozen when FTX filed for bankruptcy.
On 10 November 2022, BlockFi paused client withdrawals as FTX contagion spread.
Exchange custody
On 10 November 2022, BlockFi paused client withdrawals as FTX contagion spread. BlockFi had significant exposure to FTX, including a $400 million revolving cred
Genesis eventually filed for bankruptcy in January 2023.
Exchange custody
On 16 November 2022, Genesis Global Capital suspended customer withdrawals, citing its $175 million locked in FTX and abnormal withdrawal requests following FTX
Bitfront, a US-licensed exchange operated by Line Corporation, announced on 28 November
Exchange custody
Bitfront, a US-licensed exchange operated by Line Corporation (a Japanese tech company), announced on 28 November 2022 that it was shutting down and gave custom
Platform bankruptcy — FTX (2022)
Exchange custody
The Bahamas Securities Commission froze FTX Digital Markets' assets and transferred approximately $3.5 billion to a government wallet on 12 November 2022, one d
Several Indian exchanges that had not built TDS infrastructure suspended trading
Exchange custody
India's Finance Ministry introduced a 30% flat tax on cryptocurrency gains in April 2022 along with a 1% TDS (tax deducted at source) on every transaction. Seve
This institutional dependency on legal process was a new form of access constraint
Exchange custody
Coinbase's 2022 estate access process required heirs to submit a death certificate, letters testamentary or letters of administration from a probate court, and
On 11 November 2022, FTX and approximately 130 affiliated companies filed for Chapter
Exchange custody
On 8 November 2022, FTX halted customer withdrawals after a liquidity crisis triggered by revelations about its balance sheet. On 11 November 2022, FTX and appr
Estate access failure — exchange custody (2022)
Exchange custody
In the UK, Bitcoin held on exchanges formed part of a deceased's digital estate but required Letters of Administration or Grant of Probate before an exchange wo
Estate access failure — exchange custody (2022)
Exchange custody
Australian exchanges including CoinSpot and Independent Reserve had established executor access protocols by 2022, but the process required submission of a cert
Several exchanges, including Coinbase and Kraken, received orders to freeze specific
Exchange custody
In February 2022, the Canadian government invoked the Emergencies Act to freeze bank accounts and financial assets—including cryptocurrency—of individuals assoc
Forced relocation — Coinbase (2022)
Exchange custody
Following Russia's invasion of Ukraine in February 2022, Western exchanges including Coinbase, Kraken, and Binance faced pressure from regulators to restrict se
Sanctions lockout — exchange custody (2022)
Exchange custody
Following the Tornado Cash sanctions in August 2022, USDC issuer Circle blacklisted wallet addresses associated with the sanctioned smart contracts. Holders of
Forced relocation — Coinbase (2022)
Exchange custody
Russian holders of Bitcoin on international exchanges faced unexpected access constraints in early 2022 as multiple exchanges—including Coinbase, Binance, and K
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