Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00111
Institutional lockout — exchange custody (2014)
SurvivesCase description
German financial regulator BaFin issued clarification in March 2014 that Bitcoin exchanges serving German users required a financial services license. Several exchanges operating in Germany suspended German account services while applying for licenses, leaving German customers unable to access their accounts for weeks to months.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2014 |
| Country | Germany |
Structural dependencies observed
Outcome interpretation
Access remained possible under the reported conditions.
Source
Publicly Reported
Evidence type
News article
Evidence link
Related cases involving vendor lockout
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.
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