Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00517
Several large European exchanges launched early implementation programmes in August
SurvivesCase description
The EU's Fifth Anti-Money Laundering Directive (5AMLD) was published in July 2018 with a transposition deadline of January 2020. Several large European exchanges launched early implementation programmes in August 2018. Customers who had been operating pseudonymously had their accounts restricted to read-only until they completed real-name KYC processes.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2018 |
| Country | European Union |
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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