Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01098
Platform bankruptcy — Gemini (2023)
ConstrainedCase description
On 19 January 2023, Genesis Global Capital filed for Chapter 11 bankruptcy protection in the Southern District of New York, listing liabilities between $1.2 billion and $11 billion and more than 100,000 creditors. Approximately 340,000 Gemini Earn users had around $900 million in assets frozen since November 2022 when Genesis halted withdrawals. The bankruptcy filing formalized the indefinite freeze, placing all Gemini Earn customers into the role of unsecured creditors in a complex reorganization proceeding.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2023 |
| 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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