Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01104
Sanctions lockout — exchange custody (2023)
IndeterminateCase description
Russian individuals who had moved crypto to non-Western exchanges in 2022 to avoid sanction-related restrictions found in 2023 that those exchanges—some based in Asia or the Middle East—were themselves under increasing pressure to comply with international FATF standards. Several exchanges began requesting enhanced KYC for Russian users or restricting withdrawals pending compliance reviews. The multi-step migration of assets across exchanges, each imposing its own verification barriers, created a cumulative access constraint for holders navigating around geopolitical restrictions.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Indeterminate |
| Documentation | Unknown |
| Year observed | 2023 |
| Country | Russia |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. It's not clear whether anyone ever regained access.
Outcome interpretation
Not enough information is available to determine the outcome.
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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