Part of the CustodyStress archive of observed Bitcoin custody incidents
Legal or authority constraint
Cases in this category involve situations where legal or institutional constraints prevented or delayed access by a party with legitimate authority.
Legal authority constraint cases expose the gap between legal entitlement and operational access. Cases involve estate proceedings, regulatory freezes, sanction compliance, and jurisdictional conflicts. In many cases, the party seeking access has clear legal authority; the constraint is institutional or procedural rather than technical.
37 observed cases
Blocked
4 (11%)
Constrained
24 (65%)
Survives
4 (11%)
Indeterminate
5 (14%)
Garantex—a sanctioned Russian cryptocurrency exchange—had its infrastructure seized by
Exchange custody
In March 2025, Garantex—a sanctioned Russian cryptocurrency exchange—had its infrastructure seized by US and German law enforcement in a coordinated operation.
Legal authority constraint — hardware wallet (2025)
Hardware wallet (single key)
The GENIUS Act, signed into law in 2025, established the first federal stablecoin framework. While the Act did not directly restrict Bitcoin ownership or custod
Legal authority constraint — exchange custody (2025)
Exchange custody
The 2025 Digital Asset Market Clarity Act, working its way through Congress, proposed clarifying the SEC/CFTC jurisdictional boundary for digital assets. During
Legal authority constraint — exchange custody (2025)
Exchange custody
A 2025 European Union ruling began enforcing the Travel Rule requirement that cryptocurrency exchanges share sender and recipient identity information for trans
Legal authority constraint — exchange custody (2025)
Exchange custody
Ukrainian Bitcoin holders faced a growing set of legal restrictions in 2025 as Ukraine's wartime financial controls required registration of cryptocurrency hold
Legal authority constraint — hardware wallet (2025)
Hardware wallet (single key)
A US district court ruled in February 2025 on a civil forfeiture case involving Bitcoin seized from a defendant who was acquitted of the underlying criminal cha
Estate access failure — hardware wallet (2025)
Hardware wallet (single key)
A 2025 US Senate Banking Committee inquiry into cryptocurrency estate planning highlighted that despite more than 40 US states having adopted the Revised Unifor
Platform bankruptcy — FTX (2025)
Exchange custody
Voyager Digital's bankruptcy distribution process continued in 2025, with creditors of the platform—which had frozen withdrawals in July 2022—still awaiting fin
Legal authority constraint — hardware wallet (2025)
Hardware wallet (single key)
The January 2025 inauguration of President Trump ushered in a significant policy shift on cryptocurrency regulation. Acting SEC Chair Mark Uyeda paused ongoing
Paradoxically, the ETF approval highlighted an existing access problem: millions of
Exchange custody
In June 2024, the SEC approved the first US spot Bitcoin ETFs from BlackRock, Fidelity, and others—opening a regulated access pathway for institutional and reta
Coinbase, which had been subject to an SEC enforcement action since June 2023
Exchange custody
In early 2024, former US President Donald Trump began actively campaigning on a pro-Bitcoin platform, including proposals for a strategic Bitcoin reserve. As cr
Following Donald Trump's election victory on a pro-crypto platform, the SEC began
Exchange custody
In November 2024, following Donald Trump's election victory on a pro-crypto platform, the SEC began signalling a shift in its enforcement posture under the inco
Binance subsequently ceased all Nigerian naira services and suspended P2P trading in
Exchange custody
In February 2024, Nigerian authorities detained two Binance executives—Tigran Gambaryan, head of financial crime compliance, and Nadeem Anjarwalla, Binance's re
The traveller was returning from a trip and was carrying a Trezor in their carry-on
Hardware wallet (single key)
A documented 2024 case involved a US customs seizure of a hardware wallet at a border crossing. The traveller was returning from a trip and was carrying a Trezo
Legal authority constraint — exchange custody (2024)
Exchange custody
Nigerian authorities arrested two Binance executives in February 2024 and held them for months as part of a dispute over the naira's value and Binance's role in
The holder retained their seed phrase backups, meaning the Bitcoin could theoretically
Hardware wallet (single key)
A 2024 civil forfeiture case involved US federal agents seizing two hardware wallets during a search warrant execution. The wallets were listed as seized proper
Legal authority constraint — exchange custody (2024)
Exchange custody
Tigran Gambaryan was released from Nigerian detention on humanitarian grounds in October 2024 after eight months in custody, during which he contracted malaria,
Legal authority constraint — exchange custody (2024)
Exchange custody
The US Department of Justice seized approximately $2 billion in Bitcoin connected to the Silk Road in March 2024, following a court ruling that the government h
Former Celsius CEO Alex Mashinsky was arrested and charged with securities fraud
Exchange custody
In July 2023, former Celsius CEO Alex Mashinsky was arrested and charged with securities fraud, commodities fraud, wire fraud, and conspiracy to manipulate the
Legal authority constraint — exchange custody (2023)
Exchange custody
Binance's November 2023 $4.3 billion settlement with the US Department of Justice and other regulators—and the departure of CEO Changpeng Zhao—triggered a brief
The SEC's enforcement actions against Coinbase and Binance named over 60 tokens as
Exchange custody
In June 2023, the SEC's enforcement actions against Coinbase and Binance named over 60 tokens as securities. Both exchanges moved quickly to delist or restrict
Legal authority constraint — Coinbase (2023)
Exchange custody
The SEC's June 2023 lawsuits against Coinbase and Binance triggered significant uncertainty about the regulatory status of multiple cryptocurrencies, with the S
The SEC objected to Celsius's plan to use Coinbase as a distribution agent
Exchange custody
In September 2023, the SEC objected to Celsius's plan to use Coinbase as a distribution agent for international customers, arguing the arrangement exceeded a ty
The government subsequently blocked access to the websites of these exchanges
Exchange custody
Indian crypto exchanges faced a series of enforcement actions in 2023. India's Financial Intelligence Unit issued show-cause notices to several offshore exchang
Binance CEO Changpeng Zhao pleaded guilty to federal money laundering charges as part
Exchange custody
In December 2023, Binance CEO Changpeng Zhao pleaded guilty to federal money laundering charges as part of a $4.3 billion settlement between Binance and US auth
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