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%)
Account frozen — exchange custody (2019)
Exchange custody
The SEC brought enforcement action against a Bitcoin trading scheme operator in June 2019, seeking emergency asset freeze. The court's ex parte order froze asse
Bittrex immediately suspended all New York customer account registration.
Exchange custody
Bittrex was denied a BitLicense by the New York Department of Financial Services in March 2019 for inadequate AML controls. Bittrex immediately suspended all Ne
Bitfinex and Tether were sued by the New York Attorney General in April 2019.
Exchange custody
Bitfinex and Tether were sued by the New York Attorney General in April 2019. The NYAG alleged that Tether had backstopped Bitfinex's $850 million hole using Te
The US Congress held hearings on Facebook's Libra cryptocurrency in May 2019.
Exchange custody
The US Congress held hearings on Facebook's Libra cryptocurrency in May 2019. The associated regulatory attention caused several US exchanges to reassess their
Withdrawals of affected tokens were suspended pending the resolution of the SEC actions.
Exchange custody
The SEC's November 2018 enforcement actions against two ICO projects resulted in asset freezes affecting multiple exchanges that had listed the projects' tokens
Gox trustee Nobuaki Kobayashi revealed in September 2018 that he had sold approximately
Exchange custody
Mt. Gox trustee Nobuaki Kobayashi revealed in September 2018 that he had sold approximately $400 million worth of BTC and BCH from the estate between December 2
Institutional lockout — exchange custody (2018)
Exchange custody
Following the IRS's first cryptocurrency tax guidance update in five years, published in draft form in April 2018, multiple US exchanges implemented additional
Institutional lockout — exchange custody (2018)
Exchange custody
The SEC filed emergency charges in June 2018 against a California-based Bitcoin trading scheme. Court orders froze all assets associated with the defendant incl
Institutional lockout — exchange custody (2018)
Exchange custody
The SEC issued a report in September 2018 that several token exchanges had been operating as unregistered securities exchanges. Multiple platforms suspended US
The Coincheck hack triggered an immediate FSA crackdown.
Exchange custody
The Coincheck hack triggered an immediate FSA crackdown. Japan's Financial Services Agency issued emergency on-site inspections of all licensed and operating cr
Several large European exchanges launched early implementation programmes in August
Exchange custody
The EU's Fifth Anti-Money Laundering Directive (5AMLD) was published in July 2018 with a transposition deadline of January 2020. Several large European exchange
Platform bankruptcy — exchange custody (2018)
Exchange custody
Italian police confiscated all of BitGrail's remaining cryptocurrency assets in March 2018 as part of a criminal investigation into Firano. The confiscation ord
Institutional lockout — exchange custody (2017)
Exchange custody
The CFTC filed an action in August 2017 against a Bitcoin trading scheme operator, resulting in a court-ordered asset freeze. Customer BTC held by the operator
Institutional lockout — exchange custody (2017)
Exchange custody
The CFTC's August 2017 enforcement action against a Bitcoin trading scheme resulted in an asset freeze that also affected several customers who had participated
Institutional lockout — exchange custody (2017)
Exchange custody
Japan's Payment Services Act licensing requirement for Bitcoin exchanges took effect in April 2017. In March, exchanges that had not yet completed registration
Institutional lockout — Coinbase (2017)
Exchange custody
The IRS won a court case in November 2017 requiring Coinbase to turn over records of 14,355 customers who had transacted more than $20,000 in any single year. C
The SEC issued a ruling in July 2017 that the DAO tokens constituted securities.
Exchange custody
The SEC issued a ruling in July 2017 that the DAO tokens constituted securities. Several US-based platforms that had supported DAO-related activities suspended
Institutional lockout — Cryptsy (2016)
Exchange custody
The Cryptsy receiver's investigation in early 2016 revealed that CEO Paul Vernon had allegedly moved approximately 11,000 BTC of customer funds to his personal
Although the law was not enacted, several Russian exchanges pre-emptively suspended
Exchange custody
Russia's Ministry of Finance circulated a draft law in March 2016 that would criminalise Bitcoin transactions. Although the law was not enacted, several Russian
Institutional lockout — Bitfinex (2016)
Exchange custody
Following Bitfinex's August 2016 hack, the US government opened investigations into whether the BFX token structure constituted an unregistered securities offer
Institutional lockout — exchange custody (2016)
Exchange custody
The US Treasury's FinCEN published updated guidance in February 2016 explicitly classifying Bitcoin mixers as money service businesses. Several privacy-focused
Existing New York customers found their account withdrawal and deposit functions
Exchange custody
Following the BitLicense implementation, several Bitcoin exchanges that had served New York users chose to geofence the state rather than apply for a licence. E
A Russian court upheld the 2014 ruling classifying Bitcoin use as illegal.
Exchange custody
In March 2015 a Russian court upheld the 2014 ruling classifying Bitcoin use as illegal. Several online merchants and exchanges that had been serving Russian cu
The sentencing finalised the government's forfeiture of all Bitcoin seized from
Exchange custody
On 29 May 2015 Ross Ulbricht was sentenced to life in prison for operating Silk Road. The sentencing finalised the government's forfeiture of all Bitcoin seized
Customers who attempted to withdraw THB were informed the service was suspended
Exchange custody
The Bank of Thailand issued guidance in June 2015 reiterating that Bitcoin was not legal currency and that banks should not facilitate Bitcoin-related transacti
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