Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00376
Although the law was not enacted, several Russian exchanges pre-emptively suspended
ConstrainedCase description
Russia's Ministry of Finance circulated a draft law in March 2016 that would criminalise Bitcoin transactions. Although the law was not enacted, several Russian exchanges pre-emptively suspended operations. Russian customers who held BTC on these exchanges found their funds frozen until the regulatory outcome was clarified.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2016 |
| Country | Russia |
Structural dependencies observed
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
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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