Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01189
Platform bankruptcy — Gemini (2023)
ConstrainedCase description
On 12 January 2023, the SEC charged Genesis Global Capital and Gemini Trust Company with the unregistered offer and sale of securities through the Gemini Earn program. The charge added a regulatory enforcement layer to the existing custody blockage: customers whose assets were frozen in Genesis now faced an additional proceeding that would need to resolve before distributions could occur. The dual tracks of bankruptcy court and SEC enforcement created a more complex and slower path to recovery.
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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