Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01378
In jurisdictions that had adopted stronger Travel Rule enforcement in 2024–2025
ConstrainedCase description
A 2025 survey of mid-tier exchange users found that a significant proportion of self-reported Bitcoin holders who used custodial exchanges had not updated their KYC information in more than two years. In jurisdictions that had adopted stronger Travel Rule enforcement in 2024–2025, exchanges were required to place accounts with outdated KYC into restricted access status pending reverification. Users whose accounts entered restricted status found they could view their balance but could not withdraw until they completed updated identity verification, creating a temporary institutional custody dependency caused by regulatory compliance requirements.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Constrained |
| Documentation | Unknown |
| Year observed | 2025 |
| Country | International |
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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