Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01050
The EU's seventh sanctions package in July 2022 included specific provisions targeting
ConstrainedCase description
Following Russia's invasion of Ukraine and subsequent EU sanctions, European exchanges were required to freeze accounts belonging to sanctioned Russian individuals and entities. The EU's seventh sanctions package in July 2022 included specific provisions targeting crypto assets. Some Russian nationals who were not themselves sanctioned but who had transaction history with sanctioned parties found their exchange accounts flagged and access restricted pending compliance review, sometimes for weeks.
Custody context
| Stress condition | Legal or authority constraint |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2022 |
| Country | European Union |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. Whether full access was ultimately possible is unclear, but significant delay or outside intervention was involved.
Outcome interpretation
Access remained possible, but only with delay, dependence, or significant difficulty.
Source
Publicly Reported
Evidence type
News article
Related cases involving legal or authority constraint
39 cases involve legal or authority constraint
512 cases involve exchange custody
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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.