Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00802
Institutional lockout — exchange custody (2020)
SurvivesCase description
FinCEN's August 2020 proposed rulemaking on convertible virtual currency mixers prompted several exchanges to pre-emptively flag all transactions that had passed through any identified mixer within the previous 12 months. Customers who had legitimately used mixers for privacy found their accounts restricted pending compliance review.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2020 |
| 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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