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Definition comminglingomnibus wallet riskfailure to segregate

Commingling of Client Funds

Mixing customer assets with a firm's own money, or with other customers' assets, so that ownership can no longer be cleanly separated.

Regulated brokers must keep customer property segregated from house property, with reconciliations proving that segregated assets at least equal what customers are owed. Digital-asset exchanges commonly pool deposits into omnibus wallets for operational efficiency, which is not inherently improper if internal records are accurate and reconciled, but it removes the on-chain evidence that would let a user verify their own claim. Harm occurs when pooled customer assets are used to fund house trading, to meet other customers' withdrawals, or to post collateral elsewhere. The 2022 failure of FTX is the reference case, where customer assets were not segregated from an affiliated trading firm's obligations.

In practice

Because an omnibus wallet holds one balance for many customers, an on-chain observer cannot tell whether it is fully backed, over-collateralized, or short.

The common misunderstanding

That coins deposited on an exchange remain legally yours, when pooled assets combined with terms granting the platform use rights can leave you an unsecured creditor rather than an owner.

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Related terms

Bankruptcy Claim A creditor's legal claim in a failed company's court process, which determines who gets paid, how…
Custody Risk The risk of losing access to digital assets because of how they are stored, whether by you or by a…
Insolvency When a firm's liabilities exceed its assets, or it can no longer pay what it owes as obligations…
Qualified Custodian A regulated firm, such as a bank or broker-dealer, that certain professional managers are required…
Rehypothecation When a firm holding your assets as collateral reuses them for its own borrowing or lends them…
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