Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01219
Sanctions lockout — FTX (2024)
IndeterminateCase description
FTX creditors in jurisdictions flagged by OFAC faced a unique obstacle in the 2024 reorganisation plan: the distribution agents—BitGo, Kraken, and Payoneer—were required to perform sanctions screening before disbursing funds. Creditors who held dual citizenship with a sanctioned country, or whose beneficial ownership chains ran through entities in sanctioned jurisdictions, found their claims placed in a separate processing queue requiring enhanced due diligence. Some international creditors discovered that the compliance requirements for receiving FTX distributions were more onerous than the compliance checks that had been in place when they deposited funds with FTX in the first place.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Indeterminate |
| Documentation | Unknown |
| Year observed | 2024 |
| Country | United States |
Structural dependencies observed
What this illustrates
Getting access back required help from an institution — and that help wasn't available. It's not clear whether anyone ever regained access.
Outcome interpretation
Not enough information is available to determine the outcome.
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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