Last spring, Wyoming unexpectedly found itself at the center of a global crypto controversy. Tasked with returning more than $270 million to claimants — from places as far away as Kazakhstan — the state quickly learned how complicated unclaimed property becomes when digital assets and cross-border ownership collide.
What unfolded in Wyoming isn’t just a story about crypto. It’s a real-time example of how difficult it can be to comply with escheatment laws, even for the state to enforce.
When Crypto Tripled a State’s Fund Overnight
In the spring of 2024, Coinbase closed a quarter-million customer accounts across 139 countries. Acting through a newly formed Wyoming corporation, the company liquidated bitcoin and other cryptocurrencies into cash and turned roughly $270 million over to the state.
For Wyoming, that meant sudden responsibility for returning millions in converted crypto to rightful owners — many outside U.S. borders — making verification and payout far more complex than typical claims.
Almost overnight, the state’s unclaimed property fund tripled.
“You think you’ve seen it all,” said Jeff Robertson, who leads the State Treasurer’s Office’s Unclaimed Property Division, “and then all of a sudden, something new comes along,” he told WyoFile.
The scale and speed of the Coinbase case revealed just how uncharted this territory is and why holders should pay close attention.
Why It Matters: Lessons for Holders
The Coinbase case wasn’t just a windfall for Wyoming. It was a stress test of unclaimed property systems. For holders, it exposed three major lessons that extend far beyond crypto:
Understanding Liquidation
When assets must be liquidated before reporting, holders take on valuation risk. With volatile assets like cryptocurrency, the value on the escheatment date may look nothing like the value when a claim is filed. That gap can lead to disputes and reputational damage.
Cross-Border Complexity
States sometimes deal with international claims such as foreign shareholders or retirees abroad, but rarely at the scale of 139 countries at once. Each claim adds layers of documentation, language differences, and fraud prevention. Wyoming even had to roll out a multilingual chatbot to manage inquiries. A reminder that large-scale global claims require new solutions. For holders, the administrative burden can grow quickly.
High-Dollar Claims = High Stakes
The larger the dollars, the greater the liability if reporting isn’t accurate or due diligence falls short. High-value claims invite more scrutiny, and mistakes can quickly escalate into financial and reputational risk.
That is why compliance strategy cannot remain static. Even companies with established processes need to continually adapt as asset types, customer bases, and reporting requirements change — because each shift brings new risks.
Plus, these risks don’t play out the same way everywhere. Each state enforces its own rules, which adds another layer of complexity for holders.
Every State Has Its Quirks
Wyoming’s crypto case may be unique, but it’s not the only example of states wrestling with unusual property types.
Delaware has earned a reputation for aggressive enforcement, sending Voluntary Disclosure Agreement invitations that often serve as a precursor to audits if companies don’t respond.
New York has issued specific guidance for items like gift cards, where reporting rules differ from traditional cash or securities.
And Texas presents a different kind of challenge. As the nation’s largest energy-producing state, it requires holders to report mineral proceeds and royalties as unclaimed property. These property types aren’t as common elsewhere, but in Texas they represent a significant share of what gets reported, adding complexity for companies operating in oil and gas or related industries.
No two states take the same approach, and digital assets are widening those differences. For multi-state holders, that patchwork means added risk and reinforces the importance of knowing the details before reporting.
Beyond the Headlines: Why This Matters for Holders
Wyoming’s $270 million crypto case isn’t just a one-off story. It’s a preview of where unclaimed property is headed. As asset classes diversify and ownership stretches across borders, compliance becomes increasingly complex. Even states can stumble when new asset types collide with old rules.
For holders, the lesson is clear: strategies that worked a decade ago aren’t enough today. A check-the-box approach to compliance leaves companies vulnerable to disputes, reputational risk, and costly errors. Staying ahead requires proactive due diligence, adaptable processes, and the right expertise — partnering with compliance specialists to reduce risk before situations escalate into public headlines.
If you want to strengthen your compliance approach and avoid making headlines for the wrong reasons, contact us or explore our solutions for unclaimed property consulting, outsourcing, and compliance software like UPNavigator®.