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%)
Exchanges including Kraken, Binance, and OKX published Merkle-tree-based reserve proofs.
Exchange custody
Constrained 2022
Following the wave of exchange insolvencies in 2022, several surviving centralized exchanges introduced proof-of-reserves audits in Q4 2022 in response to custo
The bankruptcy proceedings revealed this was false: customer assets had been commingled
Exchange custody
Blocked 2022
FTX had published terms of service stating that customer assets were held in segregated accounts and were not company property. The bankruptcy proceedings revea
AAX Exchange suspended withdrawals on 13 November 2022, citing a 'system upgrade,'
Exchange custody
Blocked 2022
In the weeks following FTX's collapse, several smaller exchanges and lending platforms that had significant FTX exposure—including Liquid Global, AAX Exchange,
Institutional lockout — exchange custody (2022)
Exchange custody
Blocked 2022
Crypto exchange AAX suspended withdrawals on 13 November 2022, initially claiming a 'system upgrade' following a third-party partner's technical failure. The ex
When Genesis froze withdrawals in November 2022, several institutional
Exchange custody
Constrained 2022
Crypto prime brokerage Genesis Trading had been a key counterparty for institutional Bitcoin holders seeking to earn yield on idle holdings. When Genesis froze
Platform bankruptcy — Voyager (2022)
Exchange custody
Constrained 2022
Voyager's bankruptcy estate entered a complex bidding process in late 2022, with Binance US initially winning a $1.02 billion acquisition bid that was later blo
Institutional custody dependency — exchange — United States 2022
Exchange custody
Constrained 2022
Celsius custody account holders who had been promised faster access saw their withdrawals delayed until late 2022, approximately 263 days after the initial free
Platform bankruptcy — BlockFi (2022)
Exchange custody
Constrained 2022
BlockFi sought bankruptcy court approval in December 2022 to resume withdrawals for customers with assets held in its BlockFi Wallet product, which was structur
Platform bankruptcy — Celsius (2022)
Exchange custody
Constrained 2022
The full scale of 2022 crypto lending insolvencies became clear by December when bankruptcy estates for Celsius, Voyager, BlockFi, and Genesis were all simultan
Institutional lockout — exchange custody (2022)
Exchange custody
Constrained 2022
CoinFLEX, a Hong Kong-registered derivatives exchange, froze withdrawals on 23 June 2022, citing a $47 million debt owed by a single large customer (later ident
Owner incapacity — Coinbase (2022)
Exchange custody
Survives 2022
An incapacitated Bitcoin holder's family presented a durable power of attorney to Coinbase in 2022 seeking access on behalf of their family member. Coinbase's p
Institutional lockout — exchange custody (2022)
Exchange custody
Constrained 2022
The collapse of the Terra/LUNA ecosystem in May 2022 caused cascading custody failures across multiple platforms. Exchanges that had listed LUNA froze trading a
Estate access failure — Kraken (2022)
Exchange custody
Survives 2022
A 2022 estate that included Bitcoin held on Kraken required the executor to submit notarized documentation, a death certificate, letters testamentary, and the a
Sanctions lockout — exchange custody (2022)
Exchange custody
Indeterminate 2022
Ukrainian citizens who had crypto on exchanges based in Russia or operated by Russian entities faced access constraints following the invasion and subsequent sa
Physical coercion — exchange custody (2022)
Exchange custody
Blocked 2022
A crypto entrepreneur in Hong Kong was kidnapped and held for 38 hours in April 2022 by a gang demanding a ransom in Bitcoin. Attackers had prior knowledge of t
Institutional lockout — exchange custody (2022)
Exchange custody
Constrained 2022
Crypto lender Vauld froze withdrawals, trading, and deposits on 4 July 2022, citing market conditions and the withdrawal of more than $197 million by customers
Documentation absent — Celsius (2022)
Exchange custody
Blocked 2022
BlockFi's interest accounts had terms of service that transferred ownership of deposited crypto to BlockFi in exchange for yield payments, similar to Celsius. M
An elderly Bitcoin holder was diagnosed with dementia in November 2021.
Exchange custody
Survives 2021
An elderly Bitcoin holder was diagnosed with dementia in November 2021. Their family sought to take over management of their accounts. The process of obtaining
They transferred 6 BTC from their personal wallet before contacting police.
Exchange custody
Constrained 2021
A Bitcoin exchange employee was placed under sustained pressure by organised criminals who had identified their role from LinkedIn. Over three weeks the employe
The executor applied for access in October 2021.
Exchange custody
Survives 2021
A deceased Bitcoin holder's Coinbase account was identified by the estate through their email history. The executor applied for access in October 2021. Coinbase
Institutional lockout — exchange custody (2021)
Exchange custody
Survives 2021
The FinCEN December 2020 unhosted wallet rule proposal's comment period closed in January 2021 with over 7,000 objections. While the rule was never finalised, t
The 3,200 BTC gap had been spent on personal expenses over four years.
Exchange custody
Blocked 2021
A Bitcoin fund that had claimed to hold 4,000 BTC on behalf of investors was found in February 2021 to have actual holdings of only 800 BTC. The fund manager ha
Owner incapacity — exchange custody (2021)
Exchange custody
Blocked 2021
A cryptocurrency day trader was committed to psychiatric care under a mental health act in February 2021 following a manic episode triggered partly by the extre
Documentation absent — exchange custody (2021)
Exchange custody
Indeterminate 2021
A DeFi yield aggregator that had accumulated over $200 million in Bitcoin-backed collateral was found in June 2021 to have published exaggerated reserve figures
The chat history showed 142 BTC contributed but none traceable.
Exchange custody
Blocked 2021
A Bitcoin savings club run informally through a messaging app since 2019 collapsed in March 2021. Members had contributed regularly but no formal records existe
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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.