Part of the CustodyStress archive of observed Bitcoin custody incidents
Vendor lockout
Cases in this category involve custody services or platforms that became inaccessible, either through insolvency, policy changes, or loss of account access.
Vendor lockout cases document the dependency risk of exchange and custodial custody. Cases range from regulatory seizure and bankruptcy to account verification failures and platform discontinuation. A recurring pattern is that users assumed institutional custody provided access redundancy; in practice, the institution itself was the single point of failure.
170 observed cases
Blocked
22 (13%)
Constrained
83 (49%)
Survives
48 (28%)
Indeterminate
17 (10%)
FTX announced a third distribution of approximately $1.6 billion on September 30, 2025.
Exchange custody
FTX announced a third distribution of approximately $1.6 billion on September 30, 2025. Dotcom customer entitlement claims received an incremental 6% distributi
A US federal judge issued a temporary restraining order on approximately March 5, 2026
Exchange custody
In February 2025, Chicago-based crypto lender BlockFills suspended all client withdrawals and disclosed it had incurred approximately $75 million in losses. The
Binance announced new identity verification requirements for all users as part of
Exchange custody
In November 2025, Binance announced new identity verification requirements for all users as part of a global compliance upgrade. Users in affected jurisdictions
Institutional lockout — exchange custody (2025)
Exchange custody
A 2025 US regulatory development required cryptocurrency exchanges operating in the US to implement enhanced transaction monitoring and suspicious activity repo
In jurisdictions that had adopted stronger Travel Rule enforcement in 2024–2025
Exchange custody
A 2025 survey of mid-tier exchange users found that a significant proportion of self-reported Bitcoin holders who used custodial exchanges had not updated their
The platform, which had filed for bankruptcy in November 2022, approved a plan in late
Exchange custody
BlockFi's distribution to creditors continued throughout 2025. The platform, which had filed for bankruptcy in November 2022, approved a plan in late 2024 that
The April 2025 FTX distribution record date for mid-range creditors saw a significant
Exchange custody
The April 2025 FTX distribution record date for mid-range creditors (claims above $50,000) saw a significant group of creditors discover that their claim had be
Platform bankruptcy — exchange custody (2025)
Exchange custody
A 2025 report on dormant exchange accounts estimated that approximately $2.1 billion in cryptocurrency remained in accounts on exchanges that had undergone bank
Institutional lockout — FTX (2025)
Exchange custody
The FTX first distribution on February 18, 2025 raised a practical access issue for creditors in US states with specific abandoned property laws. Several US sta
Sanctions lockout — exchange custody (2025)
Exchange custody
Garantex, a Russia-based cryptocurrency exchange that had been sanctioned by OFAC in April 2022 for facilitating transactions for sanctioned entities, was targe
Institutional lockout — FTX (2025)
Exchange custody
A significant fraction of FTX creditors who had completed partial onboarding steps discovered they were ineligible for the February 18, 2025 Convenience Class d
The plan set January 3, 2025 as the initial record date.
Exchange custody
FTX's Chapter 11 plan became effective on January 3, 2025, initiating the first genuine access restoration for FTX customers since the exchange froze withdrawal
Institutional lockout — exchange custody (2025)
Exchange custody
A mid-tier centralised exchange that had operated since 2020 and served primarily users in Latin America announced a suspension of all withdrawal services in Ma
Institutional lockout — FTX (2025)
Exchange custody
On February 18, 2025, FTX began the first distribution under its confirmed reorganisation plan, paying approximately $800 million to 162,000 accounts in the Con
Estate access failure — Coinbase (2025)
Exchange custody
A 2025 industry survey found that cryptocurrency estate access requests had become a significant operational category for major exchanges, with Coinbase, Kraken
Institutional lockout — FTX (2025)
Exchange custody
A class of FTX creditors that remained structurally disadvantaged through all 2025 distribution rounds were those who had originally deposited Bitcoin but whose
Institutional lockout — Coinbase (2025)
Exchange custody
Bitcoin ETF custody infrastructure continued to concentrate around Coinbase Custody Trust in 2025. By mid-year, Coinbase held custody for the overwhelming major
Institutional lockout — FTX (2025)
Exchange custody
FTX announced a second major distribution of approximately $5 billion scheduled for May 30, 2025. This second phase covered non-Convenience Class creditors—prim
Institutional lockout — FTX (2025)
Exchange custody
Multiple FTX creditors in jurisdictions newly added to the list of eligible distribution countries in January 2025 found that their distribution service provide
For creditors who had been frozen since November 2022, the distribution ended
Exchange custody
Genesis Global Capital completed its debt restructuring in August 2024, distributing approximately $4 billion in digital assets and US dollars to creditors. The
Gox creditors who chose to receive their distributions through Kraken discovered
Exchange custody
Mt. Gox creditors who chose to receive their distributions through Kraken discovered that Kraken required up to 90 days from the moment Bitcoin was transferred
A mid-tier crypto exchange that had been operating since 2019 announced it was
Exchange custody
In June 2024, a mid-tier crypto exchange that had been operating since 2019 announced it was suspending withdrawal processing for all users to 'investigate susp
The announcement ended a 15-month period during which approximately 340,000 Earn users
Exchange custody
On 28 February 2024, Gemini announced it had reached a settlement in principle with Genesis and other creditors that would result in all Gemini Earn users recei
A creditor who deposited 1 BTC in October 2022—when Bitcoin was worth approximately
Exchange custody
Many FTX creditors who expected to receive 119% of their November 2022 claim values in cash described a practical access problem: their claim was denominated in
Gox trustee Kobayashi announced that most repayments to verified creditors had been
Exchange custody
On 10 October 2024, Mt. Gox trustee Kobayashi announced that most repayments to verified creditors had been completed but that approximately 34,689 BTC remained
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