CustodyStress
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Part of the CustodyStress archive of observed Bitcoin custody incidents

Forced relocation

Cases in this category involve custody arrangements that depended on physical access to a specific location or jurisdiction which the owner was forced to leave.

Forced relocation cases expose geographic dependencies that are invisible during normal operation. Most custody setups implicitly assume the owner retains physical access to their home country, devices, and stored materials. Cases in this category involve deportation, border detention, conflict displacement, and emergency evacuation — situations where that assumption fails abruptly.

91 observed cases
Blocked
15 (16%)
Constrained
49 (54%)
Survives
18 (20%)
Indeterminate
9 (10%)
Sanctions lockout — exchange custody (2018)
Exchange custody
Constrained 2018
Russia's Rosfinmonitoring issued new guidance in March 2018 treating cryptocurrency as a potential tool for sanctions circumvention. Several domestic Russian ex
Forced relocation — exchange custody (2018)
Exchange custody
Constrained 2018
Chinese Bitcoin holders who had migrated to offshore exchanges after the September 2017 ban faced new complications in June 2018 when multiple offshore exchange
Converting Bitcoin to local currency required accepting punitive rates.
Exchange custody
Constrained 2018
A Bitcoin holder in a country experiencing severe hyperinflation found in June 2018 that all major exchanges had geofenced their home jurisdiction following OFA
Sanctions lockout — exchange custody (2018)
Exchange custody
Constrained 2018
US secondary sanctions tightened significantly in September 2018 following the Trump administration's withdrawal from the Iran nuclear deal. Several global exch
Forced relocation — exchange custody (2018)
Exchange custody
Constrained 2018
Following the RBI's April 2018 circular prohibiting banks from serving cryptocurrency businesses, Indian exchanges were forced to close their fiat gateways. Cus
Forced relocation — exchange custody (2018)
Exchange custody
Survives 2018
Following Zebpay's September 2018 closure, Indian Bitcoin holders who had used the platform as their primary exchange were forced to migrate to offshore exchang
Account frozen — exchange custody (2018)
Exchange custody
Survives 2018
Following the UK's finalisation of Brexit terms in December 2018, several EU-licensed exchanges notified UK customers that their EU-passported services would te
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Following the Chinese exchange ban, the PBoC issued further guidance in October 2017 targeting offshore exchanges with Chinese-language interfaces. VPN usage to
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Following the South Korean government's December 2017 announcement about a potential exchange ban, multiple exchanges implemented real-name verification require
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Russia's Rosfinmonitoring published new guidance in June 2017 requiring domestic financial institutions to block transfers to cryptocurrency exchanges. Several
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Bangladesh Bank issued a formal directive in July 2017 prohibiting all Bitcoin transactions by Bangladeshi nationals. Bangladeshis who held BTC on international
Holders faced a choice between converting at a punitive rate or leaving Bitcoin
Exchange custody
Constrained 2017
Zimbabwe's Bitcoin premium — driven by a shortage of US dollars — led several Zimbabwean Bitcoin holders to hold BTC on international exchanges to access dollar
Forced relocation — exchange custody (2017)
Exchange custody
Constrained 2017
Huobi and OKCoin, forced to cease China-mainland operations by the September 2017 ban, migrated their platforms offshore to Hong Kong and international markets.
Forced relocation — exchange custody (2017)
Exchange custody
Survives 2017
Chinese Bitcoin users who had held accounts on domestic exchanges were forced to liquidate or transfer holdings to overseas exchanges following the September 20
Forced relocation — software wallet (2017)
Mobile or software wallet
Survives 2017
A Venezuelan Bitcoin holder attempting to relocate to Argentina in April 2017 had their phone seized at the Venezuelan border by security officials. The phone c
PBoC officials visited the three major Chinese Bitcoin exchanges and issued formal
Exchange custody
Constrained 2016
In January 2016 PBoC officials visited the three major Chinese Bitcoin exchanges (BTC China, Huobi, OKCoin) and issued formal warnings about leverage trading an
During a period of civil unrest in April 2016 they attempted to relocate to Colombia.
Mobile or software wallet
Survives 2016
A Venezuelan Bitcoin holder in 2016 faced currency controls that made it impossible to convert BTC to bolivars through official channels. During a period of civ
Forced relocation — exchange custody (2016)
Exchange custody
Constrained 2016
Nigerian authorities imposed foreign exchange restrictions in June 2016 that prevented Nigerian bank accounts from making international wire transfers. Nigerian
Venezuelan hyperinflation in mid-2016 drove citizens to Bitcoin as a store of value.
Exchange custody
Constrained 2016
Venezuelan hyperinflation in mid-2016 drove citizens to Bitcoin as a store of value. Several Venezuelans who held BTC on international exchanges found that thei
The exchange implemented mandatory country-of-residence disclosure as part of FATF
Exchange custody
Constrained 2016
A Bitcoin holder living in a country that had criminalised Bitcoin transactions in 2015 held their BTC on a foreign exchange. In September 2016 the exchange imp
Forced relocation — exchange custody (2016)
Exchange custody
Survives 2016
Following the Brexit referendum announcement in February 2016, several EU-based Bitcoin exchanges restricted UK account services in anticipation of regulatory u
Forced relocation — software wallet (2016)
Mobile or software wallet
Survives 2016
A migrant worker who used Bitcoin to remit earnings to their home country found in March 2016 that their host country had implemented new requirements for Bitco
Forced relocation — software wallet (2016)
Mobile or software wallet
Survives 2016
Following the UK's Brexit vote in June 2016, several British nationals living in EU countries on EU-residency documents found their exchange accounts flagged fo
Forced relocation — exchange custody (2016)
Exchange custody
Survives 2016
A Syrian refugee who had stored Bitcoin as portable wealth was granted asylum in a European country in October 2016. The exchange they used for their primary ho
They had memorised their seed phrase and were able to recover their funds
Mobile or software wallet
Survives 2015
A Bitcoin holder who fled their home country as a political refugee in 2015 had stored their primary holdings on a hardware wallet that was left behind in the e
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Other stress categories
Terms guide
Survives
Access remained possible under the reported conditions.
Constrained
Access remained possible, but only with delay, dependence, or significant difficulty.
Blocked
Access was not possible under the reported conditions.
Indeterminate
There was not enough information to determine the outcome.
Single-person knowledge
Recovery depended on information or capability held by one individual who was unavailable.
Institutional dependence
Recovery depended on a third-party institution or service that was inaccessible or uncooperative.
Documentation gap
Recovery depended on instructions that were missing, incomplete, or unclear.
Authority mismatch
The person with legal authority to act did not have operational access, or vice versa.
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