Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00792
Institutional lockout — exchange custody (2020)
SurvivesCase description
On 1 October 2020 the CFTC and DOJ simultaneously filed charges against BitMEX and its founders for operating an unregistered trading facility and AML violations. BitMEX experienced a mass withdrawal run in response. Customers withdrew over $200 million in BTC in the 24 hours following the announcement. However, customers who did not withdraw quickly found their accounts subject to enhanced compliance review.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2020 |
| Country | Seychelles |
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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