Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01314
Institutional lockout — FTX (2025)
ConstrainedCase description
Multiple FTX creditors in jurisdictions newly added to the list of eligible distribution countries in January 2025 found that their distribution service providers—BitGo or Kraken—had not yet completed onboarding in those countries. The creditors had technically completed all FTX portal requirements but could not receive funds because their selected DSP had not yet activated service for their jurisdiction. FTX's portal showed their requirements as complete, but the DSP's own portal showed geographic eligibility as pending. These creditors were queued for subsequent distribution dates once the DSP expanded coverage.
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
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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