Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01044
Institutional lockout — Gemini (2022)
ConstrainedCase description
Gemini's approximately 350,000 Earn customers discovered in November 2022 that their assets—estimated at approximately $1 billion—were locked inside Genesis and inaccessible. Gemini had marketed the Earn product without making clear that assets were transferred to Genesis, a separate unregulated lending entity. The New York Department of Financial Services subsequently brought enforcement action against Gemini for misleading customers about the nature of the Earn product.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2022 |
| Country | United States |
Structural dependencies observed
What this illustrates
Getting access back required help from an institution — and that help wasn't available. Whether full access was ultimately possible is unclear, but significant delay or outside intervention was involved.
Outcome interpretation
Access remained possible, but only with delay, dependence, or significant difficulty.
Source
Publicly Reported
Evidence type
News article
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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