Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-00931
Institutional lockout — exchange custody (2021)
IndeterminateCase description
On 24 September 2021 China's People's Bank of China issued a comprehensive ban on all cryptocurrency transactions, declaring all crypto-related business activities illegal. All Chinese exchanges that had been operating in a grey zone via VPNs were required to close. Chinese nationals on foreign exchanges were required to close their accounts. The order affected millions of users.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Indeterminate |
| Documentation | Unknown |
| Year observed | 2021 |
| Country | China |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. It's not clear whether anyone ever regained access.
Outcome interpretation
Not enough information is available to determine the outcome.
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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