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Glossary

Omnibus Custody

An arrangement where a custodian pools client bitcoin in shared addresses rather than maintaining separate addresses for each client. Ownership is tracked only in the custodian's internal ledger. In insolvency, omnibus holdings may be treated as custodian assets rather than client property.

Why it matters

Omnibus custody is operationally simpler but legally riskier. When bitcoin is commingled, your ownership depends entirely on the custodian's records and solvency. In bankruptcy, omnibus holdings have historically been treated as general creditor claims rather than segregated client property.


How it works

The custodian maintains one or a few bitcoin addresses holding all client funds together. Client balances exist only in the custodian's database. Withdrawals are processed from the common pool. On-chain, there is no way to identify which bitcoin belongs to which client.


Example

An exchange holds 1,500 BTC across three addresses for 5,000 customers. The exchange's database tracks each customer's balance. When the exchange fails, customers discover they are unsecured creditors. The 1,500 BTC is divided among all creditors proportionally, not returned to original depositors.


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Further reading

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