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Account Deactivation, Deletion, and Closure Requests

Account Deactivation, Deletion, and Closure Requests

Problem

Customers contact BitGo Support requesting to delete, deactivate, or close their BitGo accounts. These requests come from individual retail users (many related to FTX claim settlements), enterprise clients wanting to remove departing employees, and organizations offboarding entirely. Customers typically expect full account deletion, but BitGo cannot permanently delete accounts due to regulatory record-retention obligations. Instead, accounts can only be deactivated (made inaccessible). A specific consent-and-verification-code workflow must be completed before deactivation can proceed.

Diagnostics

  • Identify the account type: Determine whether the request is for a personal/retail account, an FTX-related retail account, or an enterprise/institutional account. Check the enterprise ID and plan type (Starter vs. Institutional).
  • Check for remaining funds: Before proceeding with any deactivation, verify that all wallets under the user/enterprise have zero balances. If funds remain, the customer must withdraw them first — BitGo cannot perform withdrawals on behalf of clients.
  • Verify the requester's identity: Confirm the request is coming from the registered email address associated with the account. For enterprise user removals, the request should ideally come from the user's own registered email or be authorized by an enterprise admin.
  • Check FTX claim status: If the account is linked to an FTX claim, confirm with the customer whether they still need the account for pending FTX distributions before proceeding. Many customers who initially request deletion later realize they need the account for FTX settlement payouts.
  • Look for duplicate accounts: Some customers request deactivation because they created duplicate accounts (e.g., registered with two different email addresses). Confirm which account should remain active.
  • Check if the user has active wallet/enterprise associations: Use admin tools to verify if the user is associated with wallets or enterprises. Users must be removed from wallets and enterprises before or as part of the deactivation.
  • Determine if this is a user removal from an enterprise (not full account deactivation): Enterprise admins sometimes request removal of a departed employee from their enterprise and wallets, which is different from full account deactivation.

Resolution

Scenario: deactivate-delete-account-close#standard-individual-deactivation

Trigger: An individual user requests deletion or deactivation of their own BitGo account.

Signals: deactivate, delete, account deletion, close account, personal account, remove my account, no longer need account

Steps:

  1. Inform the customer that BitGo accounts cannot be permanently deleted due to compliance and regulatory obligations. Accounts can only be deactivated, meaning the account will be made inactive and no longer accessible or usable.
  2. Advise the customer to withdraw any remaining funds before deactivation, as BitGo cannot perform withdrawals on behalf of clients.
  3. Send the customer the consent verification template. The customer must reply with the exact message: "You have my consent to delete my BitGo account tied to the email address through which I am sending you this message and the verification code is [CODE]." (For deactivation-specific wording, use "deactivate" in place of "delete" as appropriate.) Generate a unique numeric verification code for the customer. Also include the following security notice in the same message: "If you have not initiated any account deletion request, please immediately reset your email login password, BitGo login password and contact BitGo Support for additional assistance."
  4. Once the customer replies with the consent message including the correct verification code, escalate to Nandish Dave (or designated admin) to perform the account deactivation.
  5. Confirm to the customer that their account has been deactivated.
  6. If the customer asks about data deletion/personal data expungement, inform them that as a South Dakota chartered trust company, BitGo is required to retain certain user data, including account information and transaction records, for a minimum of five years from the date of the last transaction or account activity. Data will be permanently deleted once the mandatory retention period has elapsed. Reassure the customer that data is securely stored in compliance with applicable data protection and privacy laws, including GDPR.

Notes: If the customer does not respond to the consent verification request, follow up twice before closing the ticket. If the customer later requests reactivation, escalate to Nandish Dave — reactivation is possible.

"As a South Dakota chartered trust company, we must comply with applicable legal and regulatory obligations, including record retention requirements. Accordingly, we are required to retain certain user data, including account information and transaction records, for a minimum of five years from the date of the last transaction or account activity." "Please note that BitGo accounts cannot be permanently deleted; they can only be deactivated. This means your account will be made inactive, and you won't be able to access it or perform transactions." "Your data will be stored for atleast an year and later it will be purged."

Scenario: deactivate-delete-account-close#ftx-retail-account-deactivation

Trigger: A customer with an FTX-related BitGo account requests deletion or deactivation, often unaware that the account may be needed for FTX claim distributions.

Signals: FTX, claim, settlement, deactivate, delete, ftx account, duplicate, FTX Recovery Trust, distribution service provider

Steps:

  1. Check whether the customer's account is linked to an FTX claim. Ask the customer if they are expecting credit from the FTX Recovery Trust plan via BitGo as the distribution service provider.
  2. If the customer confirms they no longer need the account for FTX distributions, follow the standard deactivation consent flow (see scenario #standard-individual-deactivation above).
  3. If the customer initially requested deletion but later realizes they need the account for FTX distributions, escalate to Nandish Dave for reactivation. Reactivation is possible after deactivation.
  4. If the customer's request was due to a duplicate account (e.g., they created an account before receiving the FTX claim link), advise them that having two enterprises does not impact FTX distribution. Only deactivate the duplicate if they explicitly confirm.
  5. For FTX-related retail tickets where the issue has already been resolved or is being handled by the FTX team, bulk-close after confirming with the appropriate internal contact (e.g., Michelle Liu).

Notes: Many FTX retail deactivation requests were bulk-closed as "Nandish Closing FTX Retail tickets after confirming with Michelle Liu - these issues are already resolved." Verify the current status before re-closing any reopened tickets. Customers whose KYC is still pending should be directed to complete KYC before account actions are taken. If a customer says the FTX PwC Bahamas portal shows their status as not verified, direct them to the FTX team — verification status is at the FTX portal, not BitGo's end.

"Please be informed this is not feasible at our end. Additionally, please note that having 2 enterprises shall not impact FTX distribution." "My account has been deactivated as per my request previously, but I just realized that I am expecting the credit from 'FTX Recovery Trust' plan as I have selected BitGo as the distribution service provider." "Please use the following link : https://www.bitgo.com/ftx/ to setup the FTX account."

Scenario: deactivate-delete-account-close#enterprise-user-removal

Trigger: An enterprise admin requests removal or deactivation of a user who has left their organization, or requests removal of themselves from a specific enterprise.

Signals: deactivate user, remove from enterprise, departed employee, left the company, remove access, enterprise ID, remove from wallets

Steps:

  1. Confirm whether the request is to (a) remove a user from the enterprise and its wallets, or (b) fully deactivate the departing user's BitGo account.
  2. BitGo cannot deactivate another user's account on behalf of an enterprise admin alone. The departing user's account itself remains on the platform. However, the user can be removed from the enterprise and all associated wallets, which removes their access.
  3. For removing a user from wallets and the enterprise: this may require a video call for identity verification and a policy unlock so the enterprise admin can remove the user themselves. Alternatively, BitGo support can perform the removal after proper verification.
  4. If the request is from a user wanting to remove themselves from a specific enterprise (e.g., removing an unwanted enterprise from their dropdown), support can remove the user from that enterprise directly upon request.
  5. Confirm completion to the requester, including which enterprise ID the user was removed from and which enterprises remain.

Notes: For enterprise user removals requested by someone other than the user themselves, the request ideally should come from the departing user's registered email. If that is not possible, verify the requesting admin's authority. BitGo cannot delete user records entirely — by law, user accounts must be retained on the platform even after access is removed.

"By law, we are required to keep the user accounts on our platform but since we have removed access of circle users - they will never be able to access their account. We could also remove all of circle users from custodial wallets and enterprises if you prefer, but we will not be able to delete the user entirely from our platform." "We are bound by SD Division banking regulations - Title 51 which requires us to maintain records of all transactions which are linked with user records." "Then we cannot deactivate their account but we can remove their access to your enterprize and wallets. This will require a video call and a policy unlock and then you will be able to remove them yourself from the wallets and enterprize."

Scenario: deactivate-delete-account-close#account-closure-with-remaining-funds

Trigger: A customer requests account closure but still has funds in their wallets.

Signals: sell bitcoins, close account, withdraw, remaining funds, balance, v1btc, transfer out

Steps:

  1. Inform the customer that BitGo is a wallet platform, not an exchange. They cannot sell crypto through BitGo. They must transfer funds to a third-party exchange to sell.
  2. BitGo cannot perform any withdrawal on behalf of clients for security purposes. Only the wallet owner can initiate withdrawals.
  3. If the customer has funds in a deprecated V1 wallet (e.g., v1btc), advise them to move funds from the V1 wallet to a V2 wallet first, then transfer out from V2 to an external exchange. Direct them to the V1 wallet migration guidance.
  4. Once all funds are withdrawn and wallet balances are zero, proceed with the standard deactivation consent flow.

Notes: Check if the customer is using a V1 wallet — BitGo deprecated V1 wallets. If the customer reports that "Preview Withdrawal" does nothing, this may indicate they are using a V1 wallet. Verify the wallet type in admin tools.

"BitGo is not an exchange platform but a wallet platform, you may sell your BTC using a 3rd party exchange platform. What we can suggest is to transfer out your remaining funds to an exchange platform and from there you can sell your BTC to other crypto coins." "We are not able to perform any withdrawal on behalf of any of our clients for security purposes. Only the wallet owner who can perform any withdrawal task."

Scenario: deactivate-delete-account-close#data-deletion-gdpr-request

Trigger: A customer specifically requests deletion of all personal data and information, invoking privacy rights or GDPR.

Signals: delete personal data, GDPR, expunge, digital footprint, data deletion, privacy

Steps:

  1. Acknowledge the data deletion request.
  2. Send the customer the consent and verification code template. Some agents use an expanded template that includes fields for the customer to fill in their name and email, along with the consent statement and verification code. Also include the following security notice: "If you have not initiated any account deletion request, please immediately reset your email login password, BitGo login password and contact BitGo Support for additional assistance."
  3. Inform the customer that as a South Dakota chartered trust company, BitGo must retain certain user data for a minimum of five years from the date of the last transaction or account activity, per regulatory obligations.
  4. Proceed with account deactivation upon receiving consent.
  5. Inform the customer that their data is securely stored and protected in compliance with all applicable data protection and privacy laws, including GDPR, and will be permanently deleted once the mandatory retention period has elapsed.

Notes: There is a slight inconsistency in tickets regarding the retention period: one ticket states "atleast an year" while another states "a minimum of five years." The five-year figure is grounded in the more detailed regulatory explanation (SD Division banking regulations - Title 51) and should be treated as the authoritative guidance.

"Please reply using this template below... 'You have my consent to delete my BitGo account tied to the email address through which I am sending you this message and the verification code is 950886'." "Therefore, we are unable to delete your account information at this time. However, we can deactivate your account immediately to ensure it is no longer accessible or used... Rest assured that your data is securely stored and protected in compliance with all applicable data protection and privacy laws, including GDPR. Your data will be permanently deleted once the mandatory retention period has elapsed."

Related

  • v1-wallet-migration — Customers requesting account closure may have funds stuck in deprecated V1 wallets that need migration before deactivation
  • ftx-claim-account-setup — FTX claimants often confuse account setup with account deletion; related onboarding and KYC issues overlap
  • enterprise-user-management — Enterprise admin workflows for adding/removing users from wallets and enterprises