Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01004
Platform bankruptcy — Celsius (2022)
ConstrainedCase description
The full scale of 2022 crypto lending insolvencies became clear by December when bankruptcy estates for Celsius, Voyager, BlockFi, and Genesis were all simultaneously active. Attorneys involved in all four cases noted the common pattern: terms of service that transferred asset ownership to the lender, a retail customer base unaware of this legal structure, and bankruptcy proceedings that treated customers as unsecured creditors rather than bailors. The aggregate amount of Bitcoin locked across all four estates represented one of the largest simultaneous custody stress events in the asset's history.
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.
Submit a case
← All cases
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.