Part of the CustodyStress archive of observed Bitcoin custody incidents
Regulatory Intervention — Legal Authority Constraint
Cases where a regulatory body, law enforcement agency, or government authority was involved in the access constraint — and where regulatory or governmental action was also the primary recovery path pursued.
Among the 13 cases using this recovery path, 0% of determinate cases resulted in access restored and 62% resulted in a blocked outcome.
Archive analysis — 13 cases
Outcomes
62% of determinate cases resulted in blocked access — 7 percentage points below the archive-wide average of 69%. Only 0% resulted in recovered access — one of the lower survival rates in the archive. 38% resulted in constrained recovery.
Custody type
69% of cases involved exchange custody, followed by hardware wallet (single key) at 8%.
Recovery path
Regulatory Intervention is the most documented recovery path (13 cases, 100% of subset). Of those with a determinate outcome, 38% resulted in recovered or constrained access.
Documentation
54% of cases had present and interpretable documentation — yet still produced a blocked or constrained outcome.
Geographic distribution
United States accounts for 38% of cases in this subset (5 of 13).
Structural dependency
77% of cases carry a legal authority required dependency tag — the most common structural factor in this subset.
8
Blocked
5
Constrained
0
Survived
0
Indeterminate
100% of determinate cases resulted in blocked or constrained access.
13 observed cases
Blocked
8 (62%)
Constrained
5 (38%)
BTC-e Exchange Seized by U.S. DOJ: 1 Million Users Lose Access (July 2017)
Exchange custody
BTC-e, founded in 2011 and headquartered in Russia, operated as an unlicensed money transmitter for six years, processing over $9 billion in cryptocurrency tran
Homeland Security Bitcoin Seizure: Unencrypted Seed Phrase Discovered During Search
Software wallet
BurtW, a BitcoinTalk forum user, revealed in April 2017 that he had been arrested and that Homeland Security conducted searches of both his home and office. Dur
Uphold Freezes 165 BTC Business Account: Inconsistent Enforcement and Unresolved Access
Exchange custody
Oleg operated Nexchange.io, a cryptocurrency exchange that used Uphold as a liquidity provider. In 2017, he executed a single trade of 165 BTC (approximately $1
CHBTC Bitcoin Withdrawal Suspension Under PBOC Regulatory Order (February–mid-2016)
Exchange custody
In late January and early February 2016, China's People's Bank (PBOC) convened meetings with major Bitcoin exchanges to mandate upgraded Know Your Customer (KYC
Poloniex Suspends New Hampshire Operations, Forces User Withdrawals by October 6, 2016
Exchange custody
In September 2016, Poloniex, a major US-based cryptocurrency exchange known for altcoin trading, announced a service suspension affecting all New Hampshire resi
OKCoin Bitcoin Withdrawal Freeze: PBOC Regulatory Action Extends 4 Months (February–June 2016)
Exchange custody
The People's Bank of China initiated regulatory inspections of OKCoin, Huobi, and BTCC in early January 2016, identifying serious compliance gaps: illegal margi
Huobi Bitcoin Withdrawal Freeze: 4-Month Regulatory Lockout (February–June 2016)
Exchange custody
Huobi, one of China's largest cryptocurrency exchanges, was subject to a January 2016 People's Bank of China (PBOC) inspection that also targeted OKCoin and BTC
BTCC and Major Chinese Exchanges Freeze Bitcoin Withdrawals Under PBOC Compliance (Feb–Jun 2016)
Exchange custody
BTCC (BTCChina), founded in 2011 and led by CEO Bobby Lee, was one of the world's oldest and largest Bitcoin exchanges. In January 2016, the People's Bank of Ch
DHS Seizure of Mt. Gox Dwolla and Wells Fargo Accounts (May 2013)
Exchange custody
On May 15, 2013, the US Department of Homeland Security, acting through Immigration and Customs Enforcement, seized approximately $2.9 million from Mt. Gox's Dw
Tax Conviction Forces $124M Bitcoin Disclosure Order, But Keys Remain Inaccessible
Hardware wallet (single key)
Richard Ahlgren III, an early Bitcoin investor, was convicted of tax evasion for underreporting capital gains from cryptocurrency sales. A Texas federal court i
Federal Seizure of James Zhong's 50,000 Bitcoin Following Theft Conviction
Unknown custody system
James Zhong was convicted and sentenced to one year in federal prison for theft of Bitcoin from seized Silk Road proceeds. Federal authorities recovered approxi
Vinny Troia: Coinbase Account Frozen Over Compliance Interpretation
Exchange custody
In 2017, Vinny Troia, a professional security consultant and white-hat hacker, purchased Bitcoin on Coinbase and found his account suspended shortly thereafter.
500 Bitcoin Lost After Police Obtained Seed Phrase
Unknown custody system
Glaidson Acácio dos Santos, a Brazilian cryptocurrency figure, lost control of 500 bitcoins after police obtained his seed phrase. The exact circumstances of th
Recovery path × stress
Password Bruteforce — Passphrase Unavailable
Exchange Support — Vendor Lockout
Estate Process — Owner Death
Technical Recovery — Device Loss
Professional Recovery Service — Passphrase Unavailable
Legal Proceedings — Vendor Lockout
Bankruptcy Claims — Vendor Lockout
Technical Recovery — Seed Unavailable
Legal Proceedings — Owner Death
All cases
Translate