Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01392
Institutional lockout — exchange custody (2025)
ConstrainedCase description
A 2025 US regulatory development required cryptocurrency exchanges operating in the US to implement enhanced transaction monitoring and suspicious activity reporting for transactions above $10,000, consistent with Bank Secrecy Act requirements applicable to traditional financial institutions. Several exchanges responded by temporarily restricting large withdrawals pending system upgrades to comply with the new requirements. Users attempting to withdraw substantial Bitcoin amounts during the system upgrade windows faced temporary holds of two to five business days.
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
Evidence link
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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