CustodyStress
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Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01383

Legal authority constraint — hardware wallet (2025)

Constrained
Case 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 conditionLegal or authority constraint
Custody systemHardware wallet (single key)
OutcomeConstrained
DocumentationUnknown
Year observed2025
CountryUnited States
Structural dependencies observed
Legal process required
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) View archive statistics →
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Framework references
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.