Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01216
Sanctions lockout — exchange custody (2024)
BlockedCase description
Russian nationals remained completely blocked from all major Western exchange platforms through 2024 under OFAC and EU sanctions. Despite the legal complexity of their situation, some Russian Bitcoin holders attempted to access funds through intermediaries or non-sanctioned jurisdictions, but these attempts were often frustrated by secondary sanctions risk that caused even non-Western exchanges to refuse service. The situation created a bifurcated outcome: Russians with self-custody wallets established before sanctions could transact freely on-chain, while Russians who had trusted exchange custody had no viable legal path to access their funds.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Blocked |
| Documentation | Unknown |
| Year observed | 2024 |
| Country | Russia |
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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