November 11, 2022. That’s the day FTX filed for bankruptcy. I remember exactly where I was when I heard the news — not because I had funds on FTX, but because I had watched the same thing happen to Celsius four months earlier, and before that to a string of smaller platforms going back years.
The FTX collapse was the loudest signal that nothing in crypto is “too big to fail.” A company with a $32 billion peak valuation, backed by institutional investors, with a CEO on the cover of Forbes, collapsed in 72 hours with an $8 billion hole in customer funds.
It’s been a few years now. The trial is over. Sam Bankman-Fried is convicted. The bankruptcy proceedings are ongoing. The news cycle has moved on.
But the lessons haven’t expired. If anything, I think they’re more important to revisit in 2026 — because new investors who entered during the most recent bull run may not have been paying attention during the collapse, and the comfortable market conditions make it easy to forget how fast things can go wrong.
TLDR
- FTX had an $8 billion shortfall between what customers were owed and what existed — because user deposits were lent to Alameda Research and lost.
- In 2026, the safeguards that matter are: proof-of-reserves, regulatory oversight (especially NYDFS), and self-custody for significant holdings.
- My rule: never keep more on any exchange than I’m okay losing. Regulated exchanges for trading; hardware wallet for long-term holds.
What Actually Happened at FTX
To apply the lessons, you need to understand what actually failed — not the headline version, but the mechanics.
The short version: FTX was a crypto exchange. Its affiliated trading firm was Alameda Research. Both were controlled by Sam Bankman-Fried (SBF). FTX customer deposits — the money users thought was safely sitting in their exchange accounts — were being used to fund Alameda’s trading and investment activities. When those bets went bad, there was no money to return to customers.
The key term: commingled funds. Customer assets are supposed to be held separately from the operating assets of an exchange. FTX was using them as a slush fund.
The scale: At peak, FTX may have had $6-8 billion less in assets than it owed to customers. When a competitor (Binance) announced it was selling its FTT token (FTX’s native token), confidence evaporated. Customers rushed to withdraw. There wasn’t enough money to cover withdrawals. Withdrawals were halted. Bankruptcy followed within days.
SBF’s conviction: In November 2023, SBF was convicted on 7 counts including wire fraud, securities fraud, and conspiracy. He was sentenced to 25 years in federal prison. This wasn’t a regulatory gray area — it was fraud.
Celsius was similar in structure, different in product: Celsius marketed itself as a crypto savings account — deposit crypto, earn yield. The yield came from lending customer assets. When the collateral went bad (in the broader DeFi collapse of 2022), Celsius couldn’t return funds. It halted withdrawals in June 2022 and filed for bankruptcy in July. Roughly $4.7 billion was owed to customers.
I lost money on Celsius. I had funds in their Earn product. The promised yields felt legitimate at the time — they were paying more than anything else, which in hindsight was a warning sign, not a feature. (I covered the Celsius loss in more detail in this article.)
Why This Can Still Happen in 2026
The obvious question: has enough changed that this couldn’t happen again?
Partially. Not fully.
What has improved:
- Proof of reserves verification is now standard practice at reputable exchanges
- Regulatory scrutiny has increased significantly in the US
- The collapse of multiple major platforms (FTX, Celsius, BlockFi, Voyager) has raised the baseline awareness of counterparty risk
- Spot Bitcoin ETFs now exist, giving regulated institutional exposure without exchange custody risk
What hasn’t changed:
- Most crypto exchanges are not regulated as banks or securities firms — they hold customer funds in ways that have fewer legal protections than bank deposits
- Offshore exchanges operate with minimal oversight; some US exchanges use offshore entities for certain activities
- Proof-of-reserves systems, while better than nothing, can still be gamed (they prove a snapshot in time, not ongoing solvency)
- “Earn” products and yield-bearing crypto accounts are fundamentally the same risk structure that brought down Celsius — your principal is being lent out
The honest answer is: the risk of exchange failure hasn’t been eliminated. It’s been reduced at reputable, regulated platforms. The failure mode still exists at less regulated or less transparent operators.
What to Look For in an Exchange in 2026
This is the practical checklist I use when evaluating whether to trust an exchange with meaningful funds.
1. Regulatory Status (US Focus)
NYDFS (New York Department of Financial Services) is the gold standard for US crypto regulation. A BitLicense from the NYDFS requires extensive compliance, segregated customer funds, anti-money-laundering controls, and ongoing audits. It’s not perfect, but it’s the most rigorous US crypto regulatory framework that exists.
Gemini operates under NYDFS oversight and holds a BitLicense. This is a meaningful differentiator — it means regulators have the ability to step in if something goes wrong, and the exchange has had to meet specific standards to operate.
Coinbase is a publicly traded company (NASDAQ: COIN) with SEC reporting requirements, audited financials, and extensive regulatory compliance infrastructure. Publicly traded status creates accountability that private companies don’t have.
Kraken, while not NYDFS-licensed, is one of the most established exchanges with a strong track record since 2011 and extensive regulatory compliance across jurisdictions.
Red flag: offshore exchanges with limited regulatory presence and no clear home jurisdiction. The exchange has to be accountable to someone.
2. Proof of Reserves
Proof of reserves is a cryptographic method where an exchange can demonstrate it holds at least as many assets as it owes to customers. The gold standard is Merkle tree verification — users can independently verify their own funds are included in the reserve proof.
What to look for:
- Published proof-of-reserves reports (monthly or quarterly)
- Third-party auditing of reserves
- Merkle tree verification that allows individual users to verify their inclusion
Gemini publishes monthly proof-of-reserves and has SOC 2 Type 2 certification (a security/operations audit standard). This is the level of transparency I want to see.
Limitation: Proof of reserves shows assets at a point in time. It doesn’t prove the exchange isn’t leveraged or that liabilities are accurately reported. It’s a necessary but not sufficient safeguard.
3. Publicly Traded or Audited Financials
A publicly traded exchange has to publish audited financials quarterly. You can see the actual balance sheet, revenue, and liabilities. This is a level of transparency that private companies don’t have.
Coinbase’s financials are public. You can look at their actual balance sheet. You can see that customer crypto assets are held separately from company assets. This accountability structure materially reduces the risk of FTX-style commingling — it would show up in audits.
4. History of Customer Fund Handling
Length of operation matters. Coinbase has operated since 2012. Kraken since 2011. Gemini since 2015. None of these exchanges have commingled customer funds or halted withdrawals in ways that resulted in customer losses.
Track record isn’t a guarantee of future behavior. But it’s evidence. FTX was founded in 2019 and collapsed in 2022. Three years of operation with increasingly large customer funds. Established exchanges have been tested across multiple crypto cycles.
5. Insurance Coverage
The FDIC insures US dollar cash balances held at US banks. Cash held on crypto exchanges in bank accounts is typically FDIC-insured (for the fiat portion). The crypto itself is not FDIC-insured.
Some exchanges carry private insurance on crypto assets held in custody. Coinbase Custody claims up to $320 million in crime insurance through Lloyd’s of London. Gemini has insurance for digital assets held in online hot wallets.
This insurance is better than nothing, but it’s limited relative to the total value of customer assets held. For amounts above your comfort level, self-custody is the real solution.
Self-Custody: When to Move to a Hardware Wallet
The safest place for your crypto is a hardware wallet you control. Not an exchange. Not a software wallet on your phone. A physical device that requires physical confirmation for transactions.
I covered hardware wallets in detail in this article, but here’s the threshold I use:
Move to cold storage when:
- You have more on an exchange than you’d be comfortable losing in a platform failure
- You’re holding long-term (years) and don’t need to trade the position
- Your crypto has grown to a meaningful percentage of your net worth
It’s fine to leave on an exchange when:
- It’s your active trading position
- The amount is small relative to your total holdings
- You’re using it for staking or other exchange-native features
My personal rule: I keep a small trading float on exchanges for active buys and tactical trades. Anything meant to sit for years lives in hardware custody. The exact threshold for “meaningful amount” varies by person — for me, it’s roughly anything I couldn’t be at peace losing if an exchange failed tomorrow.
The FTX lesson: withdrawals were halted with almost no warning. The people who had funds on Celsius or FTX didn’t have time to withdraw once the runs started. The window from “concerning news” to “withdrawals suspended” was measured in days, not weeks.
Position Sizing on Exchanges
Even with the best regulated exchange, the correct answer to “how much should I keep on any exchange?” is: as little as your trading activity requires.
The practical framework:
- Long-term holdings (>1 year time horizon): hardware wallet
- Active trading float: on exchange, size it to what you actually need for near-term trading
- Never: 100% of your crypto on any single platform
Diversifying exchange risk is underrated. If you use two or three regulated exchanges and keep amounts manageable on each, a single-platform failure is painful but not catastrophic. The people who lost everything on FTX or Celsius often had concentrated exposure — their entire crypto position on one platform.
Avoid Yield Traps
This deserves a direct statement because it’s the lesson Celsius teaches most clearly: if you’re earning high yield on deposited crypto, your assets are being lent out. There is counterparty risk.
8-10% APY on crypto assets isn’t magic. Celsius was generating it by lending to institutional borrowers and DeFi protocols. When those borrowers defaulted or the DeFi market collapsed, the collateral was gone. The yield was funded by risk — risk that was never clearly disclosed to users.
“Earn” products exist in 2026 in various forms. Some are better structured than Celsius was. All of them involve your assets being put to work in ways that carry risk. Before depositing into any yield-bearing crypto product, the question is not “what’s the APY?” — it’s “what happens to my principal if the borrower can’t pay back?”
For staking on-chain (like ETH staking through a validator), the risk structure is different — you’re not lending to a counterparty, you’re participating in network consensus. Staking through exchanges involves exchange custody risk. These distinctions matter.
An Exchange Safety Checklist for 2026
Before trusting an exchange with meaningful funds:
- [ ] Is the exchange regulated? By whom? (NYDFS, SEC, FinCEN, etc.)
- [ ] Does it publish proof-of-reserves? How frequently? Third-party verified?
- [ ] Is it publicly traded or audited by a recognized firm?
- [ ] How long has it operated? Has it maintained customer fund integrity through multiple market cycles?
- [ ] Are customer crypto assets held separately from operating capital?
- [ ] What’s the insurance coverage on custodied assets?
- [ ] Is the exchange offering unusually high yields on deposited crypto? (If yes: why? What’s the risk?)
- [ ] Can you independently verify your inclusion in their reserves?
Gemini checks most of these boxes for US users: NYDFS regulated, monthly proof-of-reserves, SOC 2 Type 2 audited, operates under NY state charter. It’s where I hold funds I want with stricter regulatory oversight.
For general crypto buying and trading, Coinbase and Kraken remain my primary platforms — both have strong track records and meaningful regulatory compliance.
FAQ
What exactly happened to FTX customer funds?
FTX customer deposits were transferred to Alameda Research, the trading firm also run by SBF. Alameda used those funds for trading, venture investments, and loans, many of which went bad. When the losses became apparent and a bank run started, FTX had roughly $8 billion less than it owed customers. SBF was convicted of fraud in November 2023.
Is Gemini safe after the Earn program issues?
The Gemini exchange itself operated normally through the Earn issues — the problem was with Gemini Earn (a separate yield product) and its partner Genesis, which filed for bankruptcy. The exchange custody (buying and holding crypto through Gemini’s main interface) was not affected. As of 2026, Gemini Earn has been relaunched under different terms. The exchange itself remains NYDFS-regulated.
How do I verify proof-of-reserves myself?
Most exchanges that publish Merkle tree reserves provide a user-facing tool where you can input your account details to verify your funds are included in the proof. The specific process varies by exchange. Gemini and Coinbase both have documentation on how to verify your inclusion.
What’s the difference between staking on-chain vs. staking through an exchange?
On-chain staking (like running an ETH validator or using a decentralized staking protocol) means your crypto is in a smart contract, not with a third party. Exchange-based staking means the exchange holds your crypto and participates in staking on your behalf — this introduces exchange custody risk. Not a reason to avoid exchange staking, but worth understanding.
Should I move everything to a hardware wallet?
For amounts you’re holding long-term that you won’t need to access for months or years — yes, a hardware wallet significantly reduces the risk of exchange failure. For active trading funds, exchange custody is a reasonable tradeoff for convenience. The key is not having your entire crypto portfolio on a single platform with no self-custody backup.
The FTX collapse wasn’t a fluke or a black swan. It was fraud that was made possible by structural features of the crypto market: opaque balance sheets, no proof of reserves, no meaningful regulatory oversight, and concentrated control in a single individual’s hands.
Those structural vulnerabilities still exist at some platforms in 2026. The ones that have addressed them — through regulatory oversight, auditing, and proof-of-reserves — are meaningfully safer. Not perfectly safe. Meaningfully safer.
Know what you’re trusting your exchange with. Verify when you can. Self-custody what you can’t afford to lose to a platform failure.
The market moves fast and stories get old. The lessons don’t have to.



