Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01356
Institutional lockout — FTX (2025)
ConstrainedCase description
A significant fraction of FTX creditors who had completed partial onboarding steps discovered they were ineligible for the February 18, 2025 Convenience Class distribution because they had not completed all pre-distribution requirements by the January 3 record date. The requirements—KYC verification, tax form submission, and full onboarding with a distribution service provider—were each mandatory steps in sequence, and failure to complete any single step disqualified the creditor from that distribution round. Those who had completed only partial steps were placed in the queue for subsequent distributions.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2025 |
| 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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