CustodyStress
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Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01047

Institutional lockout — exchange custody (2022)

Survives
Case description
Crypto lending platform Nexo announced in October 2022 that it was winding down its US operations following regulatory pressure from multiple state attorneys general. US customers had to withdraw their assets within a specified window or face an extended claims process. Customers who did not act promptly—due to unfamiliarity with the deadline, being abroad, or other circumstances—found themselves navigating a time-pressured institutional process to recover assets from a platform that had been operating normally days before.
Custody context
Stress conditionVendor lockout
Custody systemExchange custody
OutcomeSurvives
DocumentationUnknown
Year observed2022
CountryInternational
Structural dependencies observed
Institutional cooperation required
Outcome interpretation
Access remained possible under the reported conditions.
Source
Publicly Reported
Evidence type
News article
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Framework references
Terms guide
Survives
Access remained possible under the reported conditions.
Constrained
Access remained possible, but only with delay, dependence, or significant difficulty.
Blocked
Access was not possible under the reported conditions.
Indeterminate
There was not enough information to determine the outcome.
Single-person knowledge
Recovery depended on information or capability held by one individual who was unavailable.
Institutional dependence
Recovery depended on a third-party institution or service that was inaccessible or uncooperative.
Documentation gap
Recovery depended on instructions that were missing, incomplete, or unclear.
Authority mismatch
The person with legal authority to act did not have operational access, or vice versa.