Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00750
The FATF 12-month review of its Travel Rule guidance was published in June 2020.
SurvivesCase description
The FATF 12-month review of its Travel Rule guidance was published in June 2020. It confirmed that the unhosted wallet rule applied globally. Exchanges that had not yet implemented Travel Rule compliance began doing so urgently. Customers who regularly used unhosted wallets for privacy found their withdrawal requests subject to new documentation requirements imposed without advance notice.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Survives |
| Documentation | Unknown |
| Year observed | 2020 |
| Country | Global |
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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