CustodyStress
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Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00536

Institutional lockout — exchange custody (2018)

Survives
Case description
The SEC issued a report in September 2018 that several token exchanges had been operating as unregistered securities exchanges. Multiple platforms suspended US customer services immediately after the report's publication while seeking legal guidance. Customers who had assets on these platforms found their accounts in view-only status for weeks.
Custody context
Stress conditionVendor lockout
Custody systemExchange custody
OutcomeSurvives
DocumentationUnknown
Year observed2018
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
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Framework references
Terms guide
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.
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
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