Consumer complaint received 2025-08-26 00:00:00
Product: Money transfer, virtual currency, or money service — Virtual currency
Issue: Money was not available when promised — 
Company: BitGo Holdings, Inc.
State: IL

Complaint narrative:
To the Consumer Financial Protection Bureau, My name is XXXX XXXX, Founder and CEO of XXXX XXXX XXXX XXXX XXXX XXXX. We operate a compliant, XXXX on-ramp that lets customers fund their balances with cash and other rails to buy bitcoin. We maintain corporate custodial wallets with qualified providers to meet customer orders, manage liquidity, and protect operating funds. 

This complaint concerns XXXX XXXX XXXX XXXX XXXX and their freezing and continued withholding of our corporate custodial assets without a lawful or contractual basis, causing material business harm and downstream consumer risk. 

I am not attaching our counsels demand letter at this time. Instead I am providing a detailed, chronological account and will produce the letter and supporting records upon request. 

Who we are Company : XXXX XXXX XXXX XXXX XXXX XXXX  Role : XXXX cash-to-bitcoin on-ramp serving XXXX users nationwide Use of XXXX : Corporate custodial wallets and related services to receive, store, and transfer crypto needed to fulfill customer purchases and manage treasury Timeline and what happened XXXX. Onboarding and normal operations We completed XXXX onboarding, XXXX, KYB, and compliance reviews. We provided corporate documents, XXXX program materials, officer IDs, beneficial ownership info, and ongoing updates upon request. 
For a period, operations were normal. XXXX processed our transfers and withdrawals. We relied on XXXX as a qualified custodian for corporate assets used to fulfill customer orders. 
XXXX. Escalation and information requests In early XX/XX/year>, XXXX began flagging activity and requested additional documents and clarifications. We responded promptly each time. We furnished transaction detail, counterparties where applicable, explanations of our business model, compliance policies, officer information, and proof of lawful activity. 
XXXX. Account immobilization without notice Around May 1013, 2025, XXXX immobilized our corporate wallets. Outbound transfers were blocked. No lawful hold order, subpoena, or court directive was provided to us. 
We asked for the basis of the freeze and requested copies of any legal process. XXXX did not produce any legal order or clear policy justification. Explanations shifted and were inconsistent. 
XXXX. Formal demand to return our assets On XX/XX/year>, through counsel, we sent a Demand for Return of Cryptocurrency or Equivalent Funds, XXXX XXXX, Cease and Desist to XXXX legal addresses in XXXX XXXX, SD and by email. The demand set out : That BitGo was holding XXXX XXXX XXXX corporate custodial funds without a lawful basis. 
That no court order, subpoena, or regulator directive had been provided. 
That BitGo must immediately release our funds or remit an equivalent fiat amount.

That BitGo must preserve all evidence and cease actions that impair our ability to operate. 
XXXX. Ongoing withholding and harm After our demand, XXXX continued to withhold our corporate custodial assets. 
To protect our customers and meet obligations, we covered liquidity from other sources and migrated operations to alternative custody at our own expense. This created measurable damages : Emergency liquidity costs and trading slippage to fulfill orders Operational disruption and engineering work to re-route flows Legal and compliance costs responding to shifting requests Reputational damage and lost business opportunities XXXX still has not provided a lawful hold order, clear contractual basis, or a consistent, verifiable explanation. Funds remain immobilized. 

Why this is improper No lawful hold produced. XXXX has not provided a subpoena, court order, or law-enforcement hold that would justify immobilizing our corporate custodial assets. 
Contract and trust obligations. As a trust company and custodial provider, XXXX has obligations to safeguard and return a clients assets absent lawful restraint. Unilateral immobilization with no legal process and no timely notice breaches those duties. 
Unfair and abusive conduct. Freezing and withholding a corporate clients working assets without basis, after accepting and using our business for months, is an unfair and abusive practice. It imposes substantial injury not reasonably avoidable by the client and without countervailing benefits to consumers. 
Consumer risk. Our product directly serves retail users. Immobilizing our corporate custodial wallets created avoidable stress on order fulfillment and consumer confidence. We shielded our users by absorbing the costs, but that does not reduce the underlying risk XXXX created. 

What we can provide to the Bureau We can promptly produce the following upon request : The full XX/XX/year> demand letter sent to BitGo Trust Company , Inc . 
XXXX XXXX records, compliance submissions, and correspondence Detailed transaction logs, wallet addresses, and reconciliation showing the specific balances that XXXX immobilized Timestamped support tickets and emails showing our repeated requests for a lawful basis and BitGos responses Evidence of costs and damages incurred due to XXXX actions Our XXXX XXXX XXXX and proof of ongoing compliance What we are asking the CFPB to do Open a formal investigation into BitGos freezing and withholding practices as they affect covered clients and downstream consumers. 
XXXX XXXX to release our corporate custodial assets or remit equivalent funds absent a valid legal restraint, and to provide any legal process if one exists. 
Require policy and process changes so that any immobilization is supported by timely notice, verifiable legal process, clear escalation paths, and prompt return once conditions are met. 
Order restitution for demonstrable damages caused by XXXX actions. 

Contact Please acknowledge receipt and advise next steps.

Company response to consumer: Closed with explanation