Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00814
Institutional lockout — exchange custody (2020)
SurvivesCase description
The EU's 5AMLD transposition deadline of January 2020 had passed and EU member states began enforcement. Exchanges in France, Germany, and the Netherlands received their first enforcement actions for incomplete customer identification. Affected customers found their accounts suspended during the remediation period, typically 14–30 days.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2020 |
| 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.