CustodyStress
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Part of the CustodyStress archive of observed Bitcoin custody incidents

Vendor lockout

Cases in this category involve custody services or platforms that became inaccessible, either through insolvency, policy changes, or loss of account access.

Vendor lockout cases document the dependency risk of exchange and custodial custody. Cases range from regulatory seizure and bankruptcy to account verification failures and platform discontinuation. A recurring pattern is that users assumed institutional custody provided access redundancy; in practice, the institution itself was the single point of failure.

170 observed cases
Blocked
22 (13%)
Constrained
83 (49%)
Survives
48 (28%)
Indeterminate
17 (10%)
Court approval of the FTX reorganisation plan, international creditors across more than
Exchange custody
Constrained 2024
Following the October 2024 court approval of the FTX reorganisation plan, international creditors across more than 200 jurisdictions faced varying timelines and
The announcement—more than 14 months after FTX froze customer withdrawals in November
Exchange custody
Constrained 2024
In January 2024, FTX CEO John Jay Ray III revised the estate's recovery estimate upward, telling the Delaware bankruptcy court that he expected to be able to pa
The settlement established a victims' fund for the 29,000 New York investors who had
Exchange custody
Survives 2024
The New York Attorney General reached a $2 billion settlement with Genesis Global Capital in early 2024. The settlement established a victims' fund for the 29,0
Institutional lockout — Celsius (2024)
Exchange custody
Constrained 2024
Celsius customers who had received partial BTC and ETH distributions in January 2024 under the reorganisation plan then discovered that the equity component of
Under the plan effective January 2024, these customers were projected to recover
Exchange custody
Constrained 2024
Celsius creditors who had held assets in the platform's Earn programme were classified as unsecured creditors throughout the bankruptcy, meaning their recovery
BlockFi had filed for Chapter 11 bankruptcy in November 2022 following FTX's collapse.
Exchange custody
Constrained 2024
BlockFi creditors continued waiting for distributions through 2024. BlockFi had filed for Chapter 11 bankruptcy in November 2022 following FTX's collapse. Throu
Voyager had filed for bankruptcy in July 2022 and had an initial distribution plan
Exchange custody
Constrained 2024
Voyager Digital customers continued to experience delays in receiving distributions through 2024. Voyager had filed for bankruptcy in July 2022 and had an initi
Platform bankruptcy — FTX (2024)
Exchange custody
Constrained 2024
On 8 May 2024, FTX filed a proposed reorganisation plan offering 98% of creditors 118% of the value of their claims in cash, based on November 2022 petition-dat
The remaining 3% was expected within 12 months pending additional DCG recoveries.
Exchange custody
Survives 2024
On 21 May 2024, the US Bankruptcy Court for the Southern District of New York confirmed Genesis's reorganisation plan. By end of May 2024, approximately 97% of
Gox rehabilitation trustee Nobuaki Kobayashi announced that repayments of Bitcoin
Exchange custody
Constrained 2024
On 24 June 2024, Mt. Gox rehabilitation trustee Nobuaki Kobayashi announced that repayments of Bitcoin and Bitcoin Cash to creditors would commence in July 2024
More than 47,000 BTC valued at approximately $2.7 billion were moved from cold storage
Exchange custody
Constrained 2024
On 5 July 2024, Mt. Gox rehabilitation trustee Nobuaki Kobayashi announced that repayments of Bitcoin and Bitcoin Cash had commenced. The first distributions we
Creditors needed to have registered with the designated exchange partners, completed
Exchange custody
Constrained 2024
A significant cohort of Mt. Gox creditors who had not maintained active contact with the rehabilitation process over the preceding decade faced practical obstac
Institutional lockout — Celsius (2024)
Exchange custody
Constrained 2024
A recurring practical obstacle for Celsius distributions in 2024 was the claims portal itself. Creditors who had not logged in since 2022, whose email addresses
Platform bankruptcy — exchange custody (2024)
Exchange custody
Survives 2024
Silvergate Capital, a crypto-focused bank that had been a critical fiat on-ramp for major exchanges and institutions, filed for Chapter 7 bankruptcy in Septembe
Institutional lockout — FTX (2024)
Exchange custody
Indeterminate 2024
FTX creditors who had submitted claims but subsequently failed to pass KYC verification by the distribution agents faced a secondary blockage in late 2024 as th
Platform bankruptcy — FTX (2024)
Exchange custody
Constrained 2024
On 7 October 2024, US Bankruptcy Judge John Dorsey of the District of Delaware confirmed FTX's reorganisation plan, approving the distribution of more than $14
Sanctions lockout — FTX (2024)
Exchange custody
Indeterminate 2024
FTX creditors in jurisdictions flagged by OFAC faced a unique obstacle in the 2024 reorganisation plan: the distribution agents—BitGo, Kraken, and Payoneer—were
Institutional lockout — Coinbase (2024)
Exchange custody
Survives 2024
Following the SEC approval of spot Bitcoin ETFs in January 2024, several crypto exchanges and custodians reported record onboarding backlogs. Custodians approve
Platform bankruptcy — exchange custody (2024)
Exchange custody
Survives 2024
The January 2024 approval of spot Bitcoin ETFs in the United States led to a surge in trading volume that stressed some exchange infrastructure. Several smaller
Platform bankruptcy — Celsius (2024)
Exchange custody
Constrained 2024
On 16 January 2024, the Celsius Network bankruptcy plan became effective and distributions began to creditors who had filed claims. The plan involved returning
Gox rehabilitation trustee Nobuaki Kobayashi extended the creditor repayment deadline
Exchange custody
Indeterminate 2023
In September 2023, Mt. Gox rehabilitation trustee Nobuaki Kobayashi extended the creditor repayment deadline from 31 October 2023 to 31 October 2024, citing del
Platform bankruptcy — Gemini (2023)
Exchange custody
Constrained 2023
On 12 January 2023, the SEC charged Genesis Global Capital and Gemini Trust Company with the unregistered offer and sale of securities through the Gemini Earn p
Its collapse meant Voyager creditors—still blocked from their Bitcoin since July
Exchange custody
Constrained 2023
In January 2023, US regulators blocked the proposed $1.02 billion acquisition of Voyager's assets by Binance US, citing national security and regulatory concern
Some creditors received fiat payments via bank transfer and PayPal in December
Exchange custody
Constrained 2023
In November 2023, the Mt. Gox trustee sent an email to creditors stating that cash repayments would commence 'shortly' within the 2023 calendar year but would l
Platform bankruptcy — FTX (2023)
Exchange custody
Indeterminate 2023
FTX creditors in October 2023 faced a claims deadline for submitting proofs of claim in the bankruptcy. The process required logging into a claims portal, verif
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Other stress categories
Terms guide
Survives
Access remained possible under the reported conditions.
Constrained
Access remained possible, but only with delay, dependence, or significant difficulty.
Blocked
Access was not possible under the reported conditions.
Indeterminate
There was not enough information to determine the outcome.
Single-person knowledge
Recovery depended on information or capability held by one individual who was unavailable.
Institutional dependence
Recovery depended on a third-party institution or service that was inaccessible or uncooperative.
Documentation gap
Recovery depended on instructions that were missing, incomplete, or unclear.
Authority mismatch
The person with legal authority to act did not have operational access, or vice versa.
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