What happened.
OSC staff reconstructed QuadrigaCX’s activity after its collapse, using trading records, financial information, and other evidence. The report described fictitious trading, misuse of client assets, and an operation with concentrated control and inadequate books and oversight.
The difference between approximately C$215 million owed and C$46 million in identified or recovered assets was a C$169 million shortfall. This is a platform and counterparty case, not a lending-portfolio case. The report presents OSC staff’s conclusions rather than findings from a tribunal hearing or court judgment.
A counterparty’s interface is not evidence of its underlying controls. Legal identity, control, asset custody, liabilities, and independent records matter before and throughout a financial relationship.
From individual facts to a fuller picture.
- OSC staff identified concentrated control and inadequate independent records.
- The report reconstructed asset flows and the gap between client liabilities and available assets.
- Who legally owns and controls the counterparty, and what registrations apply to the proposed relationship?
- Can client-asset claims be reconciled to independent records and corresponding liabilities?
- How are withdrawal delays, related-party flows, and unresolved evidence gaps escalated?
The review questions are analytical prompts. They do not establish that particular data was available to the institution at the time, or that a different process would have changed the outcome.
A different decision starts here.
Escalate unsupported financial claims when the available records cannot establish who holds or receives the money.
Lawfully available platform financial records, permitted fiat-account transactions, account ownership evidence, and independently verified counterparty information.
01 Separate a claim from verified evidence
- Evidence to connect
- Stated balances and counterparties alongside the source records actually available to the reviewer.
- Amlok output
- An evidence inventory that distinguishes supported claims, missing records, and unresolved ownership.
Decision it could supportRequire independent evidence before relying on a platform’s financial representation.
02 Resolve the permitted fiat flows
- Evidence to connect
- Authorized bank transactions, account owners, payment references, and supported counterparty records.
- Amlok output
- Named parties and evidence-backed relationships for the financial activity within scope.
Decision it could supportInvestigate unexplained counterparties or related-party flows without treating a name match as proof of custody.
03 Escalate what remains unverified
- Evidence to connect
- The financial evidence gaps, unresolved relationships, and requirements set by the reviewing institution.
- Amlok output
- A decision package that makes the remaining uncertainty explicit.
Decision it could supportApply the institution’s evidence requirements, including specialist custody or reserve checks where needed, before accepting the exposure.
Put numbers behind the opportunity.
These scenarios apply Amlok’s supplied comparison rates to the review described above. They are projections, not measured results at QuadrigaCX. Count-based scenarios use an assumed population, not the institution’s actual records.
Named counterparty coverage
Assumed population: 1,000 eligible permitted fiat-transaction records.
More financial activity within the authorized review scope could be attributed to a named party.
Calculation & assumptions
Comparison inputs: 65% → ≈86%.
Population calculation: 1,000 × 65% = 650; 1,000 × 86% ≈ 860. Difference: ≈210 additional.
Relative change: (86 − 65) ÷ 65 × 100 ≈ +32.31%.
21 percentage points higher than the input baseline. Assumes comparable counterparty evidence is obtainable. Public case summaries do not provide the underlying transactions for this replay.
View the supplied comparison inputsGraph relationship precision
Assumed population: 1,000 accepted platform and counterparty links.
The investigation could start from a more accurate set of accepted financial relationships.
Calculation & assumptions
Comparison inputs: 80% → ≈95%.
Population calculation: 1,000 × 80% = 800; 1,000 × 95% ≈ 950. Difference: ≈150 additional.
Relative change: (95 − 80) ÷ 80 × 100 ≈ +18.75%.
15 percentage points higher than the input baseline. Holds accepted-link volume constant with independent labels. Graph precision does not establish control of cryptoassets or adequacy of reserves.
View the supplied comparison inputsFrom a projection to a validated result.
Use authorized, historically timestamped fiat records and independently verified account ownership. Compare counterparty coverage and link precision; test custody and reserves through separate specialist evidence.
These projections do not quantify the C$169 million shortfall avoided. Amlok’s financial evidence workflow is not a custody audit or proof-of-reserves system. The supplied comparison rates are approximate scenario inputs; no institution-specific replay or confidence interval is available for these estimates. The two metrics describe separate dimensions and should not be added together.
Read the source material.
OSC staff conclusions are distinguished from adjudicated findings. Amlok is not presented as a custody auditor, proof-of-reserves provider, or a system that would necessarily have prevented the collapse.
- 01OSC: QuadrigaCX review reportRegulator staff report
- 02OSC: how the QuadrigaCX review was conductedReview methodology
Amlok’s interpretation is independent of the institutions discussed. Public records are limited to their stated scope and period. Historical figures describe the source events; the separately labeled Amlok scenarios are calculated projections. Institution names and logos do not imply affiliation or endorsement.
