Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00328
The exchange implemented mandatory country-of-residence disclosure as part of FATF
ConstrainedCase description
A Bitcoin holder living in a country that had criminalised Bitcoin transactions in 2015 held their BTC on a foreign exchange. In September 2016 the exchange implemented mandatory country-of-residence disclosure as part of FATF compliance. The user could not complete the disclosure without risking domestic prosecution. They could not withdraw without completing the verification.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2016 |
| Country | Unknown |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. Whether full access was ultimately possible is unclear, but significant delay or outside intervention was involved.
Outcome interpretation
Access remained possible, but only with delay, dependence, or significant difficulty.
Source
Publicly Reported
Evidence type
Forum post
Related cases involving forced relocation
This archive documents observed custody survivability failures. It does not attempt to document all Bitcoin losses or security incidents.
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Framework references
Where Bitcoin Custody Intersects Legal and Fiduciary Authority
Where custody creates gaps in estate planning, fiduciary duty, and professional responsibility.
Professional Scope Boundary Matrix
What each professional or product covers, what they do not, and where gaps form between them.
The Independent Assessment Layer in Bitcoin Custody
How independent diagnostic layers emerge when multiple parties depend on shared infrastructure.