Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01209
Sanctions lockout — exchange custody (2024)
BlockedCase description
Russian residents with Bitcoin on Western exchanges continued to face total access blockage through 2024 under the OFAC and EU sanctions framework. By 2024, additional guidance had clarified that even facilitating transactions for sanctioned individuals—including in some contexts processing withdrawal requests—was prohibited for US and EU exchange operators. Russian holders who had not transferred assets out of Western exchanges before March 2022 faced de facto permanent loss, as there was no legal mechanism for regulated exchanges to return assets to sanctioned Russian nationals.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Blocked |
| Documentation | Unknown |
| Year observed | 2024 |
| Country | International |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. Access was not recoverable.
Outcome interpretation
Access was not possible under the reported conditions.
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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