Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00720
Institutional lockout — exchange custody (2019)
ConstrainedCase description
Chinese authorities intensified crackdowns on OTC Bitcoin trading platforms in March 2019. Dozens of P2P trading platforms were shut down and operators arrested. Chinese users who had been relying on P2P platforms as their only remaining fiat conversion channel following the 2017 exchange ban found that avenue increasingly risky and inaccessible.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2019 |
| Country | China |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. Whether full access was ultimately possible is unclear, but significant delay or outside intervention was involved.
Outcome interpretation
Access remained possible, but only with delay, dependence, or significant difficulty.
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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