Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00624
Withdrawals of affected tokens were suspended pending the resolution of the SEC actions.
SurvivesCase description
The SEC's November 2018 enforcement actions against two ICO projects resulted in asset freezes affecting multiple exchanges that had listed the projects' tokens. US customers who had traded these tokens had their accounts flagged for compliance review. Withdrawals of affected tokens were suspended pending the resolution of the SEC actions.
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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