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 (2015)
Exchange custody
The US Department of Justice obtained a civil asset forfeiture order in April 2015 against Bitcoin held in wallets associated with a structured-finance fraud ca
Institutional lockout — exchange custody (2015)
Exchange custody
French financial regulator AMF issued a warning in July 2015 that Bitcoin investment schemes were unregulated and potentially illegal. One French exchange suspe
Institutional lockout — exchange custody (2015)
Exchange custody
New York's BitLicense regulations were finalised in August 2015 and took effect immediately. Several Bitcoin businesses that could not immediately satisfy the r
Institutional lockout — exchange custody (2015)
Exchange custody
The Reserve Bank of India issued a public advisory in August 2015 warning citizens of Bitcoin risks and noting that it had not authorised any entity to operate
Institutional lockout — exchange custody (2015)
Exchange custody
The CFTC filed its first formal enforcement action against a Bitcoin derivatives exchange in September 2015. The exchange was ordered to freeze all customer ass
This action was coordinated with Europol across 17 countries.
Exchange custody
The FBI's seizure of Silk Road 2.0 included a companion seizure of Bitcoin addresses belonging to the marketplace's administrator. This action was coordinated w
Charlie Shrem was sentenced to two years in prison in December 2014.
Exchange custody
Charlie Shrem was sentenced to two years in prison in December 2014. Following the sentencing, prosecutors also sought forfeiture of $950,000 in BTC held in Shr
Institutional lockout — exchange custody (2014)
Exchange custody
German financial regulator BaFin issued clarification in March 2014 that Bitcoin exchanges serving German users required a financial services license. Several e
A federal court in Texas granted an emergency asset freeze against Trendon Shavers
Exchange custody
In July 2013 a federal court in Texas granted an emergency asset freeze against Trendon Shavers and Bitcoin Savings and Trust following the SEC's formal complai
Gox's Wells Fargo accounts holding approximately $2.9 million in the US subsidiary
Exchange custody
The DHS seized Mt. Gox's Wells Fargo accounts holding approximately $2.9 million in the US subsidiary Mutum Sigillum LLC's name, adding to the earlier Dwolla se
On 15 May 2013 the US Department of Homeland Security issued a seizure warrant for Mt.
Exchange custody
On 15 May 2013 the US Department of Homeland Security issued a seizure warrant for Mt. Gox's Dwolla account held by subsidiary Mutum Sigillum LLC, for operating
Gox in May 2013 over a failed partnership agreement.
Exchange custody
CoinLab filed a $75 million lawsuit against Mt. Gox in May 2013 over a failed partnership agreement. The litigation created legal uncertainty around Mt. Gox's U
Account frozen — exchange custody (2013)
Exchange custody
FinCEN's March 2013 guidance on virtual currency classified Bitcoin exchanges as money services businesses. By mid-2013 multiple US Bitcoin businesses began req
Gox seizure action from May 2013, also received a NY DFS subpoena in August 2013.
Exchange custody
Dwolla, already subject to the DHS/Mt. Gox seizure action from May 2013, also received a NY DFS subpoena in August 2013. Dwolla had already lost its ability to
Following its FinCEN MSB registration in June 2013, Mt.
Exchange custody
Following its FinCEN MSB registration in June 2013, Mt. Gox was required to implement enhanced KYC and AML procedures for US customers. Customers who had previo
Institutional lockout — exchange custody (2013)
Exchange custody
Following the Silk Road seizure in October 2013, several Bitcoin exchanges including Bitstamp implemented enhanced screening of incoming BTC for potential Silk
Institutional lockout — exchange custody (2013)
Exchange custody
The SEC issued subpoenas to Bitfunder and other Bitcoin securities platforms in October 2013, demanding information on US users who had traded unregistered secu
Account frozen — exchange custody (2013)
Exchange custody
Following the Silk Road seizure, US law enforcement issued subpoenas to several US Bitcoin exchanges requesting transaction records for customers suspected of u
Institutional lockout — exchange custody (2013)
Exchange custody
Following the PBOC circular of December 2013, Chinese Bitcoin exchanges stopped accepting bank wire deposits. The circular also caused Alipay and other payment
Institutional custody dependency — exchange — United States 2012
Exchange custody
A user's bitcoin held at a US exchange was frozen as part of a broader investigation into the exchange operator's compliance with money transmission regulations
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