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%)
The EU's seventh sanctions package in July 2022 included specific provisions targeting
Exchange custody
Following Russia's invasion of Ukraine and subsequent EU sanctions, European exchanges were required to freeze accounts belonging to sanctioned Russian individu
Institutional lockout — exchange custody (2022)
Exchange custody
Crypto lending platform Nexo announced in October 2022 that it was winding down its US operations following regulatory pressure from multiple state attorneys ge
Institutional lockout — Gemini (2022)
Exchange custody
Gemini's approximately 350,000 Earn customers discovered in November 2022 that their assets—estimated at approximately $1 billion—were locked inside Genesis and
Platform bankruptcy — FTX (2022)
Exchange custody
FTX customers in Japan found themselves in a separate legal proceeding from the main US bankruptcy after Japanese regulators at the FSA moved quickly to ring-fe
Platform bankruptcy — FTX (2022)
Exchange custody
Following the FTX collapse, crypto exchange Liquid Global—which had been acquired by FTX in early 2022—also suspended withdrawals. Liquid customers had believed
Institutional lockout — FTX (2022)
Exchange custody
FTX's collapse triggered a bank-run dynamic across the entire crypto exchange sector, with customers on Binance, OKX, and Crypto.com withdrawing billions in the
Platform bankruptcy — FTX (2022)
Exchange custody
The SEC and CFTC both claimed jurisdiction over FTX assets following the November 2022 bankruptcy, creating regulatory overlap that complicated and delayed the
Account frozen — exchange custody (2022)
Exchange custody
The Terra/LUNA collapse in May 2022 prompted multiple South Korean exchanges including Upbit and Bithumb to temporarily suspend LUNA and UST trading and withdra
Platform bankruptcy — FTX (2022)
Exchange custody
As the FTX bankruptcy estate began the lengthy claims submission process in December 2022, creditors were required to submit proof-of-claim forms through a digi
Institutional lockout — FTX (2022)
Exchange custody
Crypto lender Salt Lending suspended withdrawals in December 2022 citing FTX exposure and difficult market conditions. Borrowers who had posted Bitcoin as colla
Platform bankruptcy — Celsius (2022)
Exchange custody
Celsius creditors who filed objections in the bankruptcy court over the classification of Earn accounts as unsecured loans discovered in late 2022 that the lega
Platform bankruptcy — FTX (2022)
Exchange custody
The December 2022 arrest of Sam Bankman-Fried in the Bahamas triggered an additional freezing event for certain FTX-affiliated wallets that were under investiga
Institutional lockout — Voyager (2022)
Exchange custody
Three Arrows Capital, a major crypto hedge fund, defaulted on a $650 million loan from Voyager Digital in late June 2022 and was ordered into liquidation by a B
Institutional lockout — Celsius (2022)
Exchange custody
Throughout the June 2022 crypto market crash—triggered by the Terra collapse and tightening monetary policy—multiple centralized lending platforms simultaneousl
Institutional lockout — exchange custody (2022)
Exchange custody
Babel Finance, a Hong Kong-based crypto lending firm, froze withdrawals on 17 June 2022 citing 'unusual liquidity pressures.' The company had approximately $2 b
Platform bankruptcy — Celsius (2022)
Exchange custody
Celsius customers outside the United States faced additional barriers to participating in the US bankruptcy process in 2022. Filing a proof of claim in a US Cha
The bankruptcy proceedings revealed that Celsius had been using customer assets
Exchange custody
Celsius's terms of service had contained language giving the company ownership of deposited assets in exchange for yield, but the vast majority of users were un
Customers had deposited Bitcoin and other assets under a materially false understanding
Exchange custody
Voyager had marketed its services with prominent references to FDIC insurance, leading many customers to believe their crypto deposits were federally insured. T
A class action lawsuit filed in 2022 alleged that this constituted fraudulent
Exchange custody
Voyager's marketing materials had prominently displayed the FDIC logo and used language suggesting customer protection equivalent to an FDIC-insured bank. A cla
Platform bankruptcy — Celsius (2022)
Exchange custody
Following the Celsius bankruptcy filing, customers who held assets in Celsius's Custody accounts—a separate product marketed as segregated, non-yielding storage
This multi-party legal structure—standard in large Chapter 11 cases—meant
Exchange custody
In the Celsius bankruptcy proceedings, the US Trustee's office, the Celsius creditor committee, and the examiner appointed by the court all conducted overlappin
After withdrawals were frozen, it emerged that the company had lost approximately $190
Exchange custody
Hodlnaut had hidden its exposure to TerraUSD from customers and regulators. After withdrawals were frozen, it emerged that the company had lost approximately $1
The court approved the release of approximately $270 million in cash held in Voyager's
Exchange custody
In August 2022, distressed Voyager customers submitted letters to the bankruptcy judge in New York begging for their funds back. Many described having deposited
The Celsius estate continued to accrue collateral management fees post-petition.
Exchange custody
Celsius customers who had borrowed against their Bitcoin as collateral on the platform faced a specific and acute custody problem: their collateral—held by Cels
Platform bankruptcy — Voyager (2022)
Exchange custody
Voyager's bankruptcy court approved the payment of customer cash balances in August 2022, returning approximately $270 million in FDIC-insured funds held at Met
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