Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01007
Texas, New Jersey, and Vermont all took regulatory action in November 2022
ConstrainedCase description
Following FTX's collapse, several US state regulators issued emergency cease-and-desist orders against crypto lenders and exchanges with a US nexus. Texas, New Jersey, and Vermont all took regulatory action in November 2022 that required certain platforms to halt operations. Users of affected platforms in these states found their accounts subject to additional regulatory freezes layered on top of any voluntary operational suspension the platform had already implemented, creating multi-layered access barriers.
Custody context
| Stress condition | Legal or authority constraint |
| Custody system | Hardware wallet (single key) |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2022 |
| Country | United States |
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
274 cases involve hardware wallet (single key)
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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.