Outcome chronology
The public record does not establish what the hypothetical institutional customer did at noon Eastern on November 6. It does establish that FTX Trading Ltd. filed a voluntary Chapter 11 petition five days later. The petition selected USD 10 billion-to-USD 50 billion categories for both estimated assets and estimated liabilities. Those broad check-box ranges are neither audited point estimates nor evidence that assets equaled liabilities. claim.ftx.outcome.chapter11 source · ftx.outcome.petition
The new estate manager's November 17 declaration reported what he called a complete failure of corporate controls and an absence of trustworthy financial information. He described missing centralized cash control, weak governance and custody practices that included no daily blockchain-position reconciliation and an Alameda exception to parts of FTX.com's auto-liquidation protocol. His December congressional testimony emphasized that the investigation was ongoing. These are sworn and attributed early observations, not final adjudication. claim.ftx.outcome.control-findings-early source · ftx.outcome.ray-declaration source · ftx.outcome.ray-house
The December 2022 CFTC and SEC complaints alleged that customer assets reached or were used by Alameda and that Alameda received exceptional platform treatment. The allegation status at filing matters: complaints tell us what regulators asserted, not what had yet been adjudicated. claim.ftx.outcome.regulator-allegations source · ftx.outcome.cftc-complaint source · ftx.outcome.sec-complaint
The debtors' June 2023 investigative report estimated that approximately USD 8.7 billion of customer-deposited assets had been misappropriated from FTX.com by the petition date. The same report said tracing sources and uses was extremely challenging because funds were commingled and records were deficient. The estimate is an estate investigative conclusion, not an audited mark-to-market solvency calculation. claim.ftx.outcome.estate-estimate source · ftx.outcome.second-interim
A court-appointed examiner later assessed defined prior investigations. The examiner's report is an independent primary source, but it expressly says the assignment was not a de novo collapse investigation and generally did not repeat witness interviews or review primary documents already reviewed by estate counsel or government. That scope limits how much weight it can add to mechanisms outside its remit. evidence.ftx.outcome.examiner-scope source · ftx.outcome.examiner
In August 2024 a federal consent judgment recorded findings admitted by the FTX entity defendants for specified purposes. It found that customer assets were commingled and used as if they were Alameda's assets. It also recorded an Alameda “Allow Negative” flag, an exemption from automatic liquidation and a USD 65 billion borrowing limit. The limit is a configured ceiling and access privilege—not evidence that USD 65 billion was drawn. claim.ftx.outcome.consent-findings table.ftx.outcome.alameda-privilege source · ftx.outcome.cftc-consent
The criminal record is separate. A jury convicted Sam Bankman-Fried on seven fraud and conspiracy counts. The district court imposed 25 years' imprisonment and approximately USD 11 billion of forfeiture; in June 2026 the Second Circuit affirmed the judgment. The conviction and affirmance are adjudicated. Narrative summaries of trial evidence remain tied to that defendant, record and standard of review. claim.ftx.outcome.conviction-affirmed source · ftx.outcome.second-circuit
Financial and recovery bridge
The first-day declaration reproduced unaudited September 30 silo schedules but expressly disclaimed confidence. It showed USD 13.459165 billion of Alameda Silo assets and USD 4.102365 billion of related-party loans receivable. The Dotcom schedule showed USD 2.258734 billion of assets and USD 465.656 million of liabilities, while saying material customer crypto balances were not presented. The apparent excess of the displayed Dotcom assets over displayed liabilities is therefore a definition trap, not net assets. No subtraction is performed. claim.ftx.outcome.early-schedules-unreliable claim.ftx.outcome.related-party-loans table.ftx.outcome.unreliable-silo-schedules source · ftx.outcome.ray-declaration
Three later amounts must remain separate. The debtors' approximately USD 8.7 billion figure is an investigative estimate of customer-deposited assets misappropriated. The CFTC judgment's USD 8.7 billion is a restitution obligation. Its USD 4.0 billion is a disgorgement obligation. The judgment coordinates both obligations with bankruptcy credits and settlement mechanics, so adding USD 8.7 billion, USD 8.7 billion and USD 4.0 billion would double-count definitions and invent a USD 21.4 billion “loss.” claim.ftx.outcome.estate-estimate claim.ftx.outcome.remedy-definition table.ftx.outcome.loss-remedy-definitions source · ftx.outcome.second-interim source · ftx.outcome.cftc-consent
The bankruptcy court confirmed the plan in October 2024, and the plan became effective January 3, 2025. The confirmed plan defines a Customer Entitlement Claim by the petition-date value of cash or digital assets, converts digital-asset claims to cash at petition-date conversion rates and provides cash treatment for allowed Dotcom claims subject to available funds and waterfalls. A claimant can therefore receive 100% of an allowed claim plus applicable plan components without receiving the original number of crypto units or their later market value. claim.ftx.outcome.plan-basis claim.ftx.outcome.plan-effective source · ftx.outcome.confirmed-plan source · ftx.outcome.confirmation-order source · ftx.outcome.effective-notice
In March 2026 the FTX Recovery Trust announced a scheduled approximately USD 2.2 billion fourth distribution. It stated cumulative allowed-claim percentages after that scheduled distribution of 96% for Class 5A, 100% for Class 5B, 100% for Classes 6A and 6B, and 120% for Class 7. These are estate-announced percentages of allowed claims. The 120% figure can reflect plan interest or other claim mechanics; it is not 120% of deposited token units. The captured release does not independently prove execution for every creditor. claim.ftx.outcome.distribution-announcement table.ftx.outcome.fourth-distribution table.ftx.outcome.scheduled-claim-percentages source · ftx.outcome.fourth-distribution
Causal assessment and rivals
The strongest causal account is layered. FTX.com's integrated custody and trading functions created a concentrated control surface. Alameda received exceptional code-level access. Customer assets were commingled and financed activity outside the promised custody boundary. Related-party and illiquid exposures made the obligation vulnerable to falling crypto prices and lender pressure. The leaked balance sheet, announced FTT sale and withdrawals were triggers and amplifiers; they exposed a pre-existing deficit rather than independently creating the customer-asset misuse. Bankruptcy was the resulting legal resolution path. hypothesis.ftx.outcome.control-access claim.ftx.outcome.trigger-not-cause source · ftx.cutoff.sbf-house-testimony source · ftx.outcome.cftc-consent source · ftx.outcome.second-circuit
The “run alone” rival correctly identifies macro stress and withdrawal speed, but it cannot explain admitted commingling and exceptional access. The “FTT alone” rival correctly identifies self-referential collateral and confidence feedback, but it cannot explain why customer assets were accessible to Alameda. FTT concentration is a trigger and amplifier inside the better-supported control mechanism, not a sufficient cause by itself. hypothesis.ftx.outcome.run-only hypothesis.ftx.outcome.ftt-only source · ftx.cutoff.coindesk-alameda source · ftx.cutoff.zhao-liquidation source · ftx.outcome.cftc-consent
Exact causal weights remain unknowable. The first-day schedules were unreliable, estate tracing was limited, the examiner had a defined scope, consent findings apply to specified parties and purposes, and the appellate opinion concerns one criminal defendant. None of those limits reverses the core mechanism; they constrain extrapolation and numerical precision.
Ex-ante decision quality and counterfactuals
The Part A recommendation did not require the customer to infer fraud. At the cutoff, the customer could see that the positive USD 250 million resource and segregation claims belonged to FTX US Derivatives, not FTX.com; that the FTX.com contract promised title but no independent balance reconciliation was in the packet; that a leaked affiliate snapshot was concentrated in FTT; and that a large counterparty intended to sell remaining FTT. Limiting an asymmetric custody exposure was justified even if the management rebuttal later proved correct. claim.ftx.outcome.ex-ante-process source · ftx.cutoff.sbf-house-testimony source · ftx.cutoff.ftx-us-derivatives-letter source · ftx.cutoff.coindesk-alameda source · ftx.cutoff.ellison-response source · ftx.cutoff.zhao-liquidation
The customer counterfactual is staged withdrawal and a strict operational cap before preserving any continuing venue access. It was contractually conceivable, but the record does not establish the customer's balance, queue priority, action or amount recoverable. No avoided-loss estimate is fabricated. counterfactual.ftx.outcome.customer-reduction assumption.ftx.cutoff.withdrawal-execution source · ftx.cutoff.terms
The company counterfactual is an entity-specific custody boundary: segregated customer assets, independent governance, daily wallet-to-ledger reconciliation and hard limits on affiliate access. The cutoff record shows that such safeguards were articulable and that segregation was claimed in a separately scoped clearing entity. It does not prove that implementing them would have prevented every fraud, cyber event or run. counterfactual.ftx.outcome.control-boundary assumption.ftx.outcome.control-feasibility source · ftx.cutoff.sbf-house-testimony source · ftx.cutoff.ftx-us-derivatives-letter
Candidate agent rules
- When material assets sit with an opaque centralized custodian and related-party access is not independently reconciled, cap balances at operational need and withdraw excess in verified stages. rule.ftx.custody-verification-gate
- Exclude issuer- or affiliate-created tokens from immediate liquidity until executable depth is proven; stress price, collateral and withdrawals together. rule.ftx.self-referential-collateral
- Attribute every capital, segregation, insurance and liquidity claim to the exact legal entity and product; do not move a resource across the perimeter without an enforceable guarantee. rule.ftx.entity-perimeter
These are candidate rules from one case. They require cross-case tests, counterexamples and false-positive calibration before corpus promotion.
Boundary conditions
Do not infer fraud merely from vertical integration, a related proprietary affiliate, token concentration or a large withdrawal. Do not generalize findings against specified entities or one defendant to every employee, customer, affiliate or crypto company. Do not combine petition ranges, unreliable schedules, estate estimates, legal remedies, forfeiture and distributions. Do not call a percentage of an allowed petition-date cash claim a percentage recovery of original crypto units. And do not let a later high creditor distribution erase the ex-ante distinction between asset availability at the cutoff and value recovered years later.