Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01360
Sanctions lockout — exchange custody (2025)
BlockedCase description
Russian Bitcoin holders continued to face complete exclusion from Western exchange and custody services in 2025 under sustained OFAC and EU sanctions. The seizure and shutdown of Garantex in March 2025 eliminated one of the last major Russia-accessible exchange options. Russian nationals with self-custody wallets remained technically able to hold and transact Bitcoin, but faced extreme difficulty converting Bitcoin to fiat or accessing services, as even nominally non-sanctioned exchanges applied enhanced due diligence to Russian counterparties out of secondary sanctions concern. The bifurcation between self-custody access (intact) and institutional access (effectively zero) was near-total.
Custody context
| Stress condition | Forced relocation |
| Custody system | Exchange custody |
| Outcome | Blocked |
| Documentation | Unknown |
| Year observed | 2025 |
| 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
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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