Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00605
Sanctions lockout — exchange custody (2018)
ConstrainedCase description
Russia's Rosfinmonitoring issued new guidance in March 2018 treating cryptocurrency as a potential tool for sanctions circumvention. Several domestic Russian exchanges suspended operations voluntarily to avoid regulatory liability. Russian users who had migrated to foreign exchanges found those platforms increasingly applying enhanced due diligence to Russian account holders.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2018 |
| Country | Russia |
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
News article
Evidence link
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.
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