CustodyStress
Archive › Vendor lockout
Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00313

Institutional lockout — exchange custody (2016)

Survives
Case description
The US Treasury's FinCEN published updated guidance in February 2016 explicitly classifying Bitcoin mixers as money service businesses. Several privacy-focused services that had been used to receive BTC payments had their linked exchange accounts flagged. Customers who had used these services saw their exchange withdrawals held pending compliance review.
Custody context
Stress conditionVendor lockout
Custody systemExchange custody
OutcomeSurvives
DocumentationUnknown
Year observed2016
CountryUnited States
Structural dependencies observed
Legal process requiredInstitutional cooperation required
Outcome interpretation
Access remained possible under the reported conditions.
Source
Publicly Reported
Evidence type
News article
Evidence link
https://masterthecrypto.com/bitcoin-scams/
Related cases involving vendor lockout
FTX announced a third distribution of approximately $1.6 billion on September 30, 2025.
Exchange custody · 2025 Survives
A US federal judge issued a temporary restraining order on approximately March 5, 2026
Exchange custody · 2025 Indeterminate
Binance announced new identity verification requirements for all users as part of
Exchange custody · 2025 Constrained
170 cases involve vendor lockout 512 cases involve exchange custody View archive statistics →
This archive documents observed custody survivability failures. It does not attempt to document all Bitcoin losses or security incidents. Submit a case
← All cases
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.
Terms guide
Outcome terms
Survives
Access remained possible under the reported conditions.
Constrained
Access remained possible, but only with delay, dependence, or significant difficulty.
Blocked
Access was not possible under the reported conditions.
Indeterminate
There was not enough information to determine the outcome.
Structural terms
Single-person knowledge
Recovery depended on information or capability held by one individual who was unavailable.
Institutional dependence
Recovery depended on a third-party institution or service that was inaccessible or uncooperative.
Documentation gap
Recovery depended on instructions that were missing, incomplete, or unclear.
Authority mismatch
The person with legal authority to act did not have operational access, or vice versa.
Original text
Rate this translation
Your feedback will be used to help improve Google Translate