Exchange & Custody Disputes. Your assets may be digital. Your rights are not.
Representation in disputes with cryptocurrency exchanges and custodians: frozen accounts, refused withdrawals, unauthorized transactions and closures without explanation.
Account restrictions and access
First, the distinction that decides everything
Two situations bring people to this page and they need opposite work.
In the first, the exchange is a real company and something has gone wrong with your account. It is frozen, restricted, under review, or closed. The balance is still there on the screen, or it was until access stopped. There is a terms-of-service agreement, a compliance department, a regulator, and a company with a registered agent, which means there is somewhere to send a demand and someone obliged to answer it.
In the second, the “exchange” was the fraud. The platform existed to display a balance that was never held, and the withdrawal was refused because there was nothing to withdraw. There is no counterparty in any meaningful sense, and the work is tracing and recovery rather than a dispute.
Those look identical from the inside. The screen shows a number and the number will not move. Telling them apart is usually the first useful thing that happens, and it is answered by records rather than by impressions: where the funds actually went on-chain, whether the entity exists in any registry, and whether the withdrawal refusal came with a demand for payment.
If a payment was demanded before the funds could be released, that is the second situation, and this page is not the one you need.
Frozen and restricted accounts
Exchanges restrict accounts for reasons that range from routine to serious, and the notice you receive rarely says which.
A hold may follow an automated compliance flag, an incomplete or re-triggered know-your-customer review, a sanctions screen, an inbound deposit the platform’s analytics scored as high-risk, a chargeback or reversal on a linked funding source, a suspected account takeover, or legal process served on the exchange by someone else. Some of those resolve with the right documentation. Some do not resolve without pressure. A few are not the exchange’s decision to make at all.
What they share is that the account holder is usually told very little, and the support channel is designed to close tickets rather than to answer questions.
The first task is establishing which category you are in, because the response is different in each and the wrong response wastes the time that matters. A hold pending documentation is a records problem. A hold following legal process is somebody else’s proceeding that you may need to appear in. A closure with funds retained is a different question again.
Escalating the dispute
Getting an account unlocked
Where the hold is one the exchange can lift, the work is largely evidentiary and procedural: assembling the documentation the compliance function actually needs, addressing the specific flag rather than the generic one, and escalating out of the support queue to a channel that is obliged to respond.
That escalation is the part individual account holders find hardest. Consumer support is not where these decisions are made, and repeated tickets rarely reach the people who make them. A demand that identifies the account, the hold, the governing terms and the obligations they create tends to land somewhere different.
Not every hold can be lifted. Where an exchange is acting on legal process, or where a sanctions match is genuine, the answer may be that the account stays restricted and the real question is what happens to the balance. That is worth establishing early rather than after months of tickets.
Disputes with a named exchange
Where a demand does not resolve it, the route is usually set by the agreement you accepted when you opened the account, and most of these agreements route disputes to arbitration rather than to court, often with a pre-arbitration notice step that has to be completed first.
That structure has consequences worth understanding before anything is filed. Timing requirements in the agreement can be short. The notice step is frequently where a matter actually resolves, because it is the first point at which a company’s legal function rather than its support function has to look at the file. And the forum, the fee structure and the available remedies are all set by a document you did not negotiate.
Reading that agreement as it applies to your specific facts is the starting point, not a formality.
Unauthorized activity and evidence
Unauthorized transactions and account takeovers
Sometimes funds leave an account through activity the account holder did not authorize: credential compromise, a SIM swap that defeated SMS-based authentication, a compromised recovery channel. The analysis then shifts. The questions become what the platform’s own security obligations were, what its records show about how the access occurred, and whether any third party’s failure contributed.
These matters live or die on records held by other people: the exchange’s access logs, the carrier’s records where a SIM swap is involved, and the on-chain record of where the funds went afterward. Requests to preserve those records are worth making early, because retention periods are finite and nobody preserves anything on your behalf.
What the on-chain record contributes
Even in a dispute with a real company, the trace matters. It establishes where funds actually went, whether they left the platform at all, whether they moved to another identifiable service, and whether the platform’s account of events is consistent with what the blockchain shows.
That analysis is done in house rather than referred out, which means it can be directed at the questions the dispute actually turns on instead of produced as a generic report.
What representation looks like
How the work begins
The first conversation is a review of what happened, what the exchange has said, and what records you hold. It is free, it is confidential, and it does not create an attorney-client relationship.
If the matter is one the firm can take, the early work is usually the governing agreement, the account records, and where relevant the trace, in that order, because the agreement determines the forum and the forum determines everything about what comes next.
Learn about attorney Agustin M. Barbara and Of Counsel D. Fernando Bobadilla.
What we cannot tell you
Whether a balance can be released depends on why it is held, and that is frequently information the account holder does not have at the outset. No firm can tell you the answer before seeing the hold notice, the agreement and the records, and any firm that offers one has skipped the part that decides it.
Some accounts stay restricted. Some agreements route to a forum where the cost of proceeding exceeds what is at stake. Both are real outcomes and both are better known early.
Representative matters
- Frozen or disabled accounts
- Blocked withdrawals
- Unauthorized transfers
- Account takeover
- Enhanced due diligence requests
- Source-of-funds documentation
- Law-enforcement related holds
- Preservation and freeze requests
- Regulatory complaints
- Platform arbitration and Terms-of-Service disputes
- Demand and escalation strategy