Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00546
Institutional lockout — exchange custody (2018)
SurvivesCase description
Following the IRS's first cryptocurrency tax guidance update in five years, published in draft form in April 2018, multiple US exchanges implemented additional reporting requirements. Customers who had not filed crypto tax returns for prior years had their accounts placed in an enhanced monitoring status with restricted withdrawal capabilities pending compliance confirmation.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2018 |
| Country | United States |
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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