Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01383
Legal authority constraint — hardware wallet (2025)
ConstrainedCase description
The GENIUS Act, signed into law in 2025, established the first federal stablecoin framework. While the Act did not directly restrict Bitcoin ownership or custody, it imposed licensing and compliance requirements on stablecoin issuers that had downstream effects on custody arrangements. Exchanges and custodians that handled stablecoin products were required to meet new reserve, disclosure, and operational standards. Some smaller custodians elected to exit stablecoin business lines rather than comply with the new requirements, reducing the custodial options available to users who held stablecoins alongside Bitcoin.
Custody context
| Stress condition | Legal or authority constraint |
| Custody system | Hardware wallet (single key) |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2025 |
| 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
Evidence link
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.