CustodyStress
Archive › Exchange custody
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%)
Institutional lockout — exchange custody (2021)
Exchange custody
Survives 2021
The G7 published recommendations on cryptocurrency regulation in July 2021, calling for mandatory registration of cryptocurrency service providers and applicati
Owner incapacity — exchange custody (2021)
Exchange custody
Blocked 2021
An August 2021 case describes a Bitcoin holder who was seriously injured in an accident and placed on sedation for 10 days. Their exchange account had open shor
Forced relocation — exchange custody (2021)
Exchange custody
Constrained 2021
India's Finance Minister announced in April 2021 that a crypto ban bill would be introduced to Parliament. The announcement triggered a sell-off on Indian excha
Platform bankruptcy — Coinbase (2021)
Exchange custody
Indeterminate 2021
Coinbase's Nasdaq IPO on 14 April 2021 made it a public company subject to SEC disclosure requirements. Coinbase disclosed in its S-1 filing that in a bankruptc
A Bitcoin investor died suddenly in April 2021 near the BTC all-time high of $64,000.
Exchange custody
Survives 2021
A Bitcoin investor died suddenly in April 2021 near the BTC all-time high of $64,000. The estate found a paper note that read 'Bitcoin account – Binance' with n
Institutional lockout — exchange custody (2021)
Exchange custody
Indeterminate 2021
On 24 September 2021 China's People's Bank of China issued a comprehensive ban on all cryptocurrency transactions, declaring all crypto-related business activit
Institutional lockout — exchange custody (2021)
Exchange custody
Survives 2021
The SEC issued guidance in December 2021 clarifying that certain Bitcoin custody structures used by public companies required specific financial reporting treat
Turkey banned cryptocurrency payments in April 2021.
Exchange custody
Blocked 2021
Turkey banned cryptocurrency payments in April 2021. Two major Turkish exchanges — Thodex and Vebitcoin — collapsed within days of the announcement, with Thodex
Documentation absent — exchange custody (2021)
Exchange custody
Blocked 2021
AfriCrypt, a South African Bitcoin investment platform, allegedly disappeared in June 2021 with an estimated 69,000 BTC worth $3.6 billion. The founders, Raees
A cryptocurrency fund's 3-of-5 multisig was compromised in June 2021.
Exchange custody
Blocked 2021
A cryptocurrency fund's 3-of-5 multisig was compromised in June 2021. One key holder's credentials were phished. The attacker gained control of one key and then
Documentation absent — exchange custody (2021)
Exchange custody
Indeterminate 2021
An automated Bitcoin trading bot service published its first audit in July 2021 after two years of operations. The audit found the bot had never achieved the cl
Multisig quorum failure — exchange custody (2021)
Exchange custody
Blocked 2021
A DAO treasury held in a 2-of-3 Gnosis Safe multisig was compromised in July 2021 when one key holder's private key was phished through a malicious governance p
Hidden wallet discovered — exchange custody (2021)
Exchange custody
Indeterminate 2021
The Liquid hack post-mortem found the exchange had not published any description of its warm wallet architecture to customers. Customers who had relied on Liqui
A Bitcoin-denominated reinsurance platform collapsed in September 2021.
Exchange custody
Blocked 2021
A Bitcoin-denominated reinsurance platform collapsed in September 2021. The platform had claimed to hold Bitcoin reserves sufficient to cover all outstanding po
Sanctions lockout — exchange custody (2021)
Exchange custody
Constrained 2021
Following the Taliban takeover of Afghanistan in August 2021, Afghan Bitcoin holders found international exchanges immediately geofencing Afghan IP addresses du
Documentation absent — exchange 2021
Exchange custody
Indeterminate 2021
A Bitcoin exchange published a proof-of-reserves in October 2021 that was later found to contain duplicated addresses. The same wallet address appeared under mu
Nigeria's CBN in 2021 continued its pressure on cryptocurrency exchanges.
Exchange custody
Constrained 2021
Nigeria's CBN in 2021 continued its pressure on cryptocurrency exchanges. Flutterwave and other payment processors suspended crypto-related transactions in Octo
Forced relocation — exchange custody (2021)
Exchange custody
Constrained 2021
Russia's central bank published a report in October 2021 recommending a complete ban on cryptocurrency operations. While the ban was not implemented until 2022,
Hidden wallet discovered — exchange custody (2021)
Exchange custody
Blocked 2021
A Bitcoin-backed investment platform that had attracted $50 million collapsed in November 2021. Post-collapse investigation found the platform had never actuall
The fund had been launched in January 2021 and attracted 600 BTC.
Exchange custody
Blocked 2021
A Bitcoin fund collapsed in December 2021. The fund had been launched in January 2021 and attracted 600 BTC. The fund's offering documents described a sophistic
A UK Bitcoin investor died in March 2021.
Exchange custody
Survives 2021
A UK Bitcoin investor died in March 2021. Their Kraken account had a substantial balance. The UK executor found that Kraken's estate process required original,
The former colleague threatened to front-run the desk's large orders unless paid 5 BTC
Exchange custody
Constrained 2021
A Bitcoin OTC desk employee was extorted in June 2021 by a former colleague who had obtained knowledge of the desk's proprietary trading positions. The former c
The exchange automatically closed all positions after 7 days of no response to margin
Exchange custody
Blocked 2021
A Bitcoin holder was the victim of a serious assault in June 2021 and was hospitalised unconscious for five weeks. Their exchange account had margin positions.
A Coinbase customer died in September 2021.
Exchange custody
Survives 2021
A Coinbase customer died in September 2021. Coinbase's estate process required a government-issued death certificate, proof of executorship, and an affidavit of
During custody their exchange account's time-limited API keys expired.
Exchange custody
Survives 2020
A November 2020 case describes a Bitcoin investor remanded in custody for four months on criminal charges. During custody their exchange account's time-limited
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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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