Regulatory Intervention — Exchange custody

This archive documents cases where a legitimate owner, heir, or authorized party encountered barriers accessing or recovering Bitcoin due to a failure in the custody arrangement. The central question for inclusion is: did the custody structure fail a legitimate access or recovery attempt?

A case must satisfy all three of the following to be included:

1. Legitimate access attempt. The person attempting to access or recover the Bitcoin was the owner, a designated heir, an executor, a legal authority, or another party with a legitimate claim — not a thief, attacker, or unauthorized third party.
2. Custody structure failure. The failure was caused by a property of the custody arrangement — missing credentials, structural dependencies, documentation gaps, knowledge concentration, legal barriers, or institutional constraints — not market conditions, individual-level fraud or theft, or protocol-level issues. Platform-level failures that block legitimate user access are in scope regardless of their cause.
3. Documentable outcome or access constraint. The case must have a stated or inferable outcome: access blocked, access constrained, access delayed, or access eventually achieved through a recovery path. Cases with entirely unknown outcomes are included only where the structural failure is documented and the constraint is unambiguous.

• Owner death or incapacity — Bitcoin held in self-custody that becomes inaccessible to heirs or designated parties because credentials, documentation, or operational knowledge were not transferred
• Passphrase loss — BIP39 passphrase forgotten or unavailable, blocking access to a funded wallet even where the seed phrase is present
• Seed phrase or wallet backup unavailable — no independent recovery path existed or the backup was destroyed, lost, or never created
• Device loss without independent backup — hardware wallet, phone, or computer lost or destroyed with no recovery path outside the device
• Documentation absent or ambiguous — heirs or executors cannot determine that Bitcoin exists, which wallet holds it, or how to access it
• Knowledge concentration — only one person knew the procedure, passphrase, or access method; that person is dead, incapacitated, or unreachable
• Multisig quorum failure — a threshold signature arrangement cannot be completed because signers are unavailable, uncooperative, incapacitated, or have lost their keys
• Legal authority / access mismatch — a court order, probate ruling, or power of attorney establishes legal entitlement but provides no technical path to access
• Institutional custody barrier — exchange or platform hacks, insolvency, regulatory seizure, or operational failure that caused a access constraint or failure for legitimate users, whether temporary, prolonged, or permanent. The failure of the custodian to remain available or solvent is itself the in-scope event.
• Forced relocation or geographic constraint — physical access to a device or location required for recovery is blocked by displacement, border restrictions, or political circumstances
• Coercion — the holder was compelled under threat to transfer Bitcoin or disclose credentials during an access event
• Hidden asset discovery — heirs or executors locate a wallet or account but cannot access it due to missing credentials or operational knowledge

• Market losses, investment losses, yield scheme losses, or Ponzi scheme losses
• Hacks or theft targeting an individual's personal security (phishing, SIM swap, social engineering, malware) where the custody architecture itself did not fail
• Unauthorized transfers where the holder's custody system was not the cause of the failure
• Ordinary transaction mistakes — wrong-address sends, fee errors, mistaken amounts
• Protocol-level failures — cryptographic vulnerabilities, consensus bugs, firmware integrity failures
• Deliberate burns or tribute burns
• Cases where the stated loss is unverifiable and no structural custody failure is described

Cases are drawn from public sources including forum posts, news reporting, court documents, academic research, and direct submissions. Each case is reviewed against the inclusion criteria above before publication. Source material is retained and available on request for documented cases.

The archive is observational and descriptive. It does not attempt to document all Bitcoin custody failures — only those meeting the criteria above with sufficient documentation to describe the structural failure and its outcome.