Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01257
Sanctions lockout — exchange custody (2025)
BlockedCase description
US Treasury expanded OFAC sanctions designations related to North Korean cryptocurrency activities in 2025, designating additional exchanges and individuals connected to the Lazarus Group's cryptocurrency operations. While the direct targets were criminal actors, the designations created secondary effects for any exchanges that had knowingly or unknowingly processed transactions involving designated entities. Exchanges with compliance operations were required to freeze accounts associated with designated parties, creating access blockages that affected some users whose transaction histories included indirect exposure to the sanctioned entities.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Blocked |
| Documentation | Unknown |
| Year observed | 2025 |
| Country | North Korea / 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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