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%)
Institutional lockout — exchange custody (2022)
Exchange custody
Crypto exchange AAX suspended withdrawals on 13 November 2022, initially claiming a 'system upgrade' following a third-party partner's technical failure. The ex
When Genesis froze withdrawals in November 2022, several institutional
Exchange custody
Crypto prime brokerage Genesis Trading had been a key counterparty for institutional Bitcoin holders seeking to earn yield on idle holdings. When Genesis froze
Platform bankruptcy — Voyager (2022)
Exchange custody
Voyager's bankruptcy estate entered a complex bidding process in late 2022, with Binance US initially winning a $1.02 billion acquisition bid that was later blo
Institutional custody dependency — exchange — United States 2022
Exchange custody
Celsius custody account holders who had been promised faster access saw their withdrawals delayed until late 2022, approximately 263 days after the initial free
Platform bankruptcy — BlockFi (2022)
Exchange custody
BlockFi sought bankruptcy court approval in December 2022 to resume withdrawals for customers with assets held in its BlockFi Wallet product, which was structur
Platform bankruptcy — Celsius (2022)
Exchange custody
The full scale of 2022 crypto lending insolvencies became clear by December when bankruptcy estates for Celsius, Voyager, BlockFi, and Genesis were all simultan
Institutional lockout — exchange custody (2022)
Exchange custody
CoinFLEX, a Hong Kong-registered derivatives exchange, froze withdrawals on 23 June 2022, citing a $47 million debt owed by a single large customer (later ident
Institutional lockout — exchange custody (2022)
Exchange custody
The collapse of the Terra/LUNA ecosystem in May 2022 caused cascading custody failures across multiple platforms. Exchanges that had listed LUNA froze trading a
Institutional lockout — exchange custody (2022)
Exchange custody
Crypto lender Vauld froze withdrawals, trading, and deposits on 4 July 2022, citing market conditions and the withdrawal of more than $197 million by customers
Institutional lockout — exchange custody (2021)
Exchange custody
The FinCEN December 2020 unhosted wallet rule proposal's comment period closed in January 2021 with over 7,000 objections. While the rule was never finalised, t
Institutional lockout — exchange custody (2021)
Exchange custody
The G7 published recommendations on cryptocurrency regulation in July 2021, calling for mandatory registration of cryptocurrency service providers and applicati
Platform bankruptcy — Coinbase (2021)
Exchange custody
Coinbase's Nasdaq IPO on 14 April 2021 made it a public company subject to SEC disclosure requirements. Coinbase disclosed in its S-1 filing that in a bankruptc
Institutional lockout — exchange custody (2021)
Exchange custody
On 24 September 2021 China's People's Bank of China issued a comprehensive ban on all cryptocurrency transactions, declaring all crypto-related business activit
Institutional lockout — exchange custody (2021)
Exchange custody
The SEC issued guidance in December 2021 clarifying that certain Bitcoin custody structures used by public companies required specific financial reporting treat
Several exchanges suspended all XRP trading with 72 hours notice.
Exchange custody
The SEC brought enforcement action against Ripple in November 2020 (charges formally filed in December), triggering a wave of US exchange delistings of XRP and
The QuadrigaCX CCAA proceedings entered their second year in January 2020.
Exchange custody
The QuadrigaCX CCAA proceedings entered their second year in January 2020. E&Y filed its fifth monitor's report confirming that Gerald Cotten had used customer
Institutional lockout — exchange custody (2020)
Exchange custody
China's 'Operation Clean Network' internet security campaign in July 2020 led to enhanced monitoring of all VPN traffic. Chinese Bitcoin users who relied on VPN
Institutional lockout — exchange custody (2020)
Exchange custody
The EU's 5AMLD transposition deadline of January 2020 had passed and EU member states began enforcement. Exchanges in France, Germany, and the Netherlands recei
Institutional lockout — exchange custody (2020)
Exchange custody
FinCEN's August 2020 proposed rulemaking on convertible virtual currency mixers prompted several exchanges to pre-emptively flag all transactions that had passe
Institutional lockout — exchange custody (2020)
Exchange custody
On 1 October 2020 the CFTC and DOJ simultaneously filed charges against BitMEX and its founders for operating an unregistered trading facility and AML violation
Institutional lockout — exchange custody (2020)
Exchange custody
On 16 October 2020 OKEx suspended all cryptocurrency withdrawals for five weeks after a key holder — one of several required for cold wallet transactions — was
India's Supreme Court struck down the RBI's April 2018 banking ban on 4 March 2020.
Exchange custody
India's Supreme Court struck down the RBI's April 2018 banking ban on 4 March 2020. Exchanges immediately began restoring banking relationships. However, severa
The FATF 12-month review of its Travel Rule guidance was published in June 2020.
Exchange custody
The FATF 12-month review of its Travel Rule guidance was published in June 2020. It confirmed that the unhosted wallet rule applied globally. Exchanges that had
Institutional lockout — exchange custody (2019)
Exchange custody
Chinese authorities intensified crackdowns on OTC Bitcoin trading platforms in March 2019. Dozens of P2P trading platforms were shut down and operators arrested
Institutional lockout — QuadrigaCX (2019)
Exchange custody
The Ontario Securities Commission expanded its investigation into QuadrigaCX in December 2019, seeking additional documents from Cotten's estate. The expanded i
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