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$215M USDT Escaped Tether Freeze: 8,310 Blacklist Proposals Exposed the Gap
compliance insights · 10 min read

$215M USDT Escaped Tether Freeze: 8,310 Blacklist Proposals Exposed the Gap

TL;DR: A widely cited report put USDT freeze escapes at $78M. We analyzed all 8,310 executed freeze proposals on Ethereum and Tron — the real number is $215.5M. 2025 alone: $141.7M. The largest single escape: $37.3M moved in under 6 minutes. 18 escapes happened within 60 seconds of proposal submission. The freeze gap is a known, actively exploited vulnerability — and it’s getting worse.


Last May, a widely cited report put the USDT freeze escape figure at $78 million. Decrypt, CoinCentral, and dozens of other outlets ran with it. Tether’s response: the number “should be put in context of the more than $2.7 billion in USDT that Tether has successfully frozen and blocked to date.”

$78 million was never the full picture.

We analyzed every single executed addBlackList proposal on both Ethereum and Tron — 8,310 proposals from 2017 through February 14, 2026 — and cross-validated the results in both Python and Go. The real number: $215.5 million.

2.8x higher. And 2025 alone accounts for $141.7 million — more than all previous years combined.

What We Mean by “Escape”

Let’s be precise about what we’re measuring.

Tether’s USDT contract uses a multisig governance model. Freezing an address happens in two steps:

  1. Proposal submission: An addBlackList transaction is submitted to the multisig contract. Visible on-chain immediately.
  2. Proposal execution: After enough signers approve, the freeze takes effect. Only then does the address lose the ability to transfer USDT.

The gap between step 1 and step 2 — we call it the “freeze gap.” (For a detailed breakdown of this mechanism, see our previous analysis.)

Our definition of escape is strict: any USDT transfer where the from_address matches the target of a freeze proposal, occurring after the proposal was submitted but before it was executed. We exclude address-poisoning dust transfers. We count only outgoing transfers.

Out of 8,310 executed freeze proposals, 8,301 had a measurable delay between submission and execution. Nine were executed in the same block. Of those 8,301, 449 proposals (5.4%) saw at least one escape transfer during the freeze gap.

The Full Picture: $215.5 Million

EthereumTronCombined
Total escaped$83.1M$132.4M$215.5M
Proposals with escapes102347449
Escape transfers2967,2087,504
Escape rate3.7%6.2%5.4%

Tron dominates in both volume and escape count. No surprise — in 2025, Tron accounted for 84% of all freeze proposals.

How Our Numbers Compare

The $78.1M figure (ETH $28.5M + Tron $49.6M) covered November 2017 through May 2025, analyzing roughly 3,480 wallets primarily on Tron. We extend through February 2026, cover both chains comprehensively, and include all 8,310 proposals.

The gap isn’t just about the extra 9 months. Our methodology captures more escape events because we analyze every proposal individually rather than sampling wallets. The result: higher numbers across every dimension.

USDT Freeze Escapes: $78M Was Never the Full Picture

Year by Year: The Escape Trend

YearETH EscapedTron EscapedTotalEscape Rate
2021$6.15M~$4$6.15M4.6%
2022$6.32M$0.90M$7.21M2.0%
2023$6.21M$11.32M$17.54M5.7%
2024$7.92M$28.89M$36.81M5.2%
2025$56.44M$85.30M$141.75M6.2%
2026 (Jan-Feb)$0.03M$5.97M$6.00M6.5%

USDT Freeze Escapes by Year

Two things stand out.

2025 was an inflection point. $141.7 million escaped — more than all prior years ($67.7 million) combined. The escape rate climbed from ~5% to over 6%.

Tron’s escape problem grew dramatically. In 2022, Tron escapes totaled under $1 million. By 2025: $85.3 million. A roughly 95x increase in three years.

The Top Escapes

Case 1: $37.3 Million in Under 6 Minutes (Tron, June 2025)

The largest escape in our dataset. Target: TD3bLbnVvcvucnJm8uhvVYGwinUzFUFgud.

Time (UTC)ΔEventTransaction
Jun 5 23:06:24Proposal submitted0b2e98202e95f71e269c20b1fd96a6e8e9e062d984c4b3029d02b9826718e95b
Jun 5 23:10:06+3m 42sEscape: $37,300,258.51a5dfb473bd7df6fa4b787882a3240c9eab2842da546ae89a963002a201aacd16
Jun 5 23:12:06+5m 42sProposal executed (frozen)40ac372f926f4208b0ef676a28845b6a8a21f2eb5da0fd5d0a001ce21873d9cf

One transaction, $37.3 million, out in 3 minutes and 42 seconds. Someone was watching.

Case 2: $27.1 Million on Ethereum (July 2025)

The largest Ethereum escape. Proposal #4461 targeted 0x928b8864151ee6C1E057964460bf5c7ADDbcA97f.

Time (UTC)ΔEventTransaction
Jul 26 10:54:11Proposal submitted0xdd1516cdfd65c03b9808bf4b09521dc14187cd01597aa42735d614b98822f777 (Etherscan)
Jul 26 10:59:23+5m 12sEscape: $27,121,615.880x7848e9c1f8c3a1d775c23549ba756bd78952033bb51718c53d6c346d1ce12f76 (Etherscan)
Jul 26 11:08:11+14m 0sProposal executed (frozen)0x3e8af13de42483ea7c3f755cd36ee712019d31fe858f49b7f6ed9338f961b599 (Etherscan)

Case 3: The Serial Escaper — $15.3M Across 4 Proposals in 2 Days

Between July 28 and 29, 2025 (UTC), four Ethereum proposals targeted different addresses. Each escape: almost exactly $3.83 million. One transaction each. Response times: 12 to 24 seconds.

Proposal #4472 — Target: 0xfFc99C05f09AAF22F380D6D531EBec0489751D70

Time (UTC)ΔEventTransaction
Jul 28 19:20:47Proposal submitted0x5ecc0fc851fbb2dd6f8c6f023d3a49a6500985515c3b6b1a6ec581808ebb6051 (Etherscan)
Jul 28 19:21:11+24sEscape: $3,827,986.900xc3decff1cab66d18b47f6c04a5116a1b155efbc48e44bdbd40055fd9b9350975 (Etherscan)
Jul 28 19:22:59+2m 12sProposal executed (frozen)0xa80e1d4c6e5d7a0afcc67b9cc9097c6e628bdda51993e768ce1bae86946314ae (Etherscan)

Proposal #4477 — Target: 0x1DD5D0257c31a25Be532dc638784e53277AaBCBb

Time (UTC)ΔEventTransaction
Jul 29 13:04:11Proposal submitted0xfd7ab08b30d584eafd7e3d45f146e5281c0db410809419429a0ed794e9d5ef21 (Etherscan)
Jul 29 13:04:35+24sEscape: $3,827,956.900x629766a5b0aabb1fcb7c841b3c9c54fa8e27a84de230e6f8e77e9bc10bc15089 (Etherscan)
Jul 29 13:04:59+48sProposal executed (frozen)0x08eb0abc3afb7c35d8a873a5dcc3fa5efe61d1c84b4ff9ab9de8e1806c97b3e5 (Etherscan)

Proposal #4480 — Target: 0xb74999968A77B4b5Dbedc12f1b7eC0851934f93A

Time (UTC)ΔEventTransaction
Jul 29 19:43:11Proposal submitted0x53b323493b961c2d616031635a233f1316d46ec2f1d2720034493a8922c8cc5d (Etherscan)
Jul 29 19:43:23+12sEscape: $3,827,941.900x6949e7ad9cb3a8abc23c25afeb2cd005d5663eaf57aa475e244efd59752f2d84 (Etherscan)
Jul 29 19:44:11+1m 0sProposal executed (frozen)0xd11d26c86afc9794ffa871539a6e3fd5ebd63f0b56c7f830febed86a5c58180f (Etherscan)

Proposal #4482 — Target: 0xe15709BfB1b3C1bD8a29Ffe87804bB6767308901

Time (UTC)ΔEventTransaction
Jul 29 19:59:11Proposal submitted0xcb4898412b6e0fede0e421e17a2f50c4f826cd98b1708ca9bc0e496cf53a1058 (Etherscan)
Jul 29 19:59:23+12sEscape: $3,827,941.900xdc9530ac9f00c3df1d1940a91f1f8106ded0c8e05d8e43ad6fd92d11303ce51d (Etherscan)
Jul 29 20:00:35+1m 24sProposal executed (frozen)0x37653d15e79ae4b53fd2280783a54f560835ba6c2eeba862a98b11297c66f327 (Etherscan)

Different destination addresses each time. But the amounts are nearly identical — decreasing by exactly $15 or $45 per hop (transaction fees). Response times of 12-24 seconds don’t leave room for manual intervention. This is a bot. One actor, cycling funds through disposable wallets, auto-firing the moment a freeze proposal appears on-chain.

Case 4: The 77-Hour Window — $12.7M (Ethereum, November 2025)

Three proposals targeting three addresses, all submitted within seconds. 77 hours before execution. Three different actors drained funds across multiple days.

Time (UTC)ΔEventTarget / AmountTransaction
Nov 28 13:26:35Proposals submitted#49080xE5264B95A492F88bEc7C9861a43B55E12488c845, #49090xF92AD00A9185cCf48364e285b875D4E84aA8C917, #49100x7c879169f739AAbFD13A1E4842ed201393311708
Nov 30 06:22+41hEscape0xF92AD00A9185cCf48364e285b875D4E84aA8C917: $1,0000xf21165664a5e4272f5e9573c9bc5dbc6abda9fe1761c8f49dbb03e3ec4b7a728 (Etherscan)
Nov 30 11:16+46hEscape0xE5264B95A492F88bEc7C9861a43B55E12488c845: $2,500,0000x2172fd369f403eec58f02d6ebf78149d1aaf6c770a8b871cfb5b83b88d903c3a (Etherscan)
Nov 30 11:40+46hEscape0xF92AD00A9185cCf48364e285b875D4E84aA8C917: $1,000,0000x37c185b8481cb15baba8b598c5c8a9e03c421a6cfca64d5c0646589ad95aab2f (Etherscan)
Nov 30 13:35+48hEscape0xF92AD00A9185cCf48364e285b875D4E84aA8C917: $3,447,3280xad7e0bba836e318cff1bf6521c0ee75def08de5f0564931e3aab0462e87db569 (Etherscan)
Dec 1 08:25+67hEscape0xE5264B95A492F88bEc7C9861a43B55E12488c845: $10,0000xed0dabb3e2407c40b300f7cc1c5625883d8ae1dcc92e0feaee8270ab861b654b (Etherscan)
Dec 1 16:18–18:46+75hEscape (15 txs)0x7c879169f739AAbFD13A1E4842ed201393311708: $4,250,0000xf3cc2bb936428ee59375c5438155549007a39ba6933e6b36c611b5796bd4b6790xad48a399173273b492d37d664d9aba2f03c2a837e21d074a58e9871be32f621a
Dec 1 18:54+77h 28m#4908 executed (frozen)0xE5264B95A492F88bEc7C9861a43B55E12488c8450xb104c1fa52acc7237f287512b4ee884770a6fca95b13f0c1a98e3d006a7cd48e (Etherscan)
Dec 1 18:54+77h 28m#4909 executed (frozen)0xF92AD00A9185cCf48364e285b875D4E84aA8C9170x9aeb50bd54487c2a4ba309acfc86ca6d163d07894a7fdb34ca8567e436227f62 (Etherscan)
Dec 1 18:56+77h 30m#4910 executed (frozen)0x7c879169f739AAbFD13A1E4842ed2013933117080x94b1f3ed6b7c402be85dc64b38815ec3d1e8c83f925b66fab877bb084cf5259c (Etherscan)

0xE5264B95A492F88bEc7C9861a43B55E12488c845 and 0xF92AD00A9185cCf48364e285b875D4E84aA8C917 share a common destination (0xD7873Ecfe0328aB85F4e4459259278929f469a64) — likely the same entity. 0x7c879169f739AAbFD13A1E4842ed201393311708 scattered $4.25M across 15 addresses ($100 to $500,000 each) over 2+ hours — classic layering behavior.

Escape Patterns

How do escapers move funds? We categorized all 449 events:

PatternEventsAmountDescription
Single transfer229 (51%)$116.6M (54%)One transaction, clean exit
Multi-transfer (2-4 txs)153 (34%)$40.2M (19%)Small number of splits
Scatter (5+ txs)67 (15%)$58.6M (27%)Many small transfers, layering

Escape Transfer Patterns

Most escapes are single-transfer events. Makes sense — if you know a freeze is coming, the fastest exit is one big transaction. The scatter pattern, though less common, averages $875K per event versus $509K for single transfers.

By Amount

BracketEventsTotal
< $1K50$12K
$1K - $10K71$275K
$10K - $100K160$6.7M
$100K - $1M133$44.1M
$1M - $10M32$88.0M
$10M+3$76.4M

Escape Amount Distribution

Extremely top-heavy. 35 events above $1M account for $164.4 million — 76% of the total. The three $10M+ escapes alone: $76.4 million.

How Fast Do Escapers React?

We measured the time between proposal submission and the first escape transfer for all 449 events:

MetricTime
Fastest3 seconds
Within 1 minute18 events
Within 5 minutes54 events
Within 15 minutes105 events
Within 1 hour204 events (45%)
Median77 minutes
75th percentile5.6 hours

Escape Reaction Times

18 escapes within 60 seconds. The fastest: 3 seconds. That’s not a human refreshing a block explorer. That’s a bot monitoring the multisig contract for submitTransaction() calls, auto-firing the moment a freeze appears.

Nearly half of all escapes (204 out of 449) started within one hour. The 77-minute median suggests many actors check their exposure regularly, even without automated tools.

Putting It in Context

Tether has pointed out — and they’re right — that freeze escapes need context. $215 million against $2.7 billion+ successfully frozen puts the escape rate at roughly 7.4% by value. Over 92% of targeted funds were successfully frozen.

The freeze gap is also an inherent trade-off. Tether’s multisig model prevents any single party from unilaterally freezing funds. PeckShield called this “an operational issue” rather than a smart contract vulnerability, suggesting that bundling freeze requests and signatures into single transactions could narrow the window.

Still. $215 million. The trend is moving in the wrong direction — 2025 set records for both total escapes and escape rate. And as the serial escaper in Case 3 shows, purpose-built tools to exploit the freeze gap already exist.

What This Means for Compliance Teams

If you rely on USDT freezes as an enforcement tool, these numbers are worth knowing.

The freeze gap is a known vulnerability. Anyone monitoring the Tether multisig can detect proposals before execution. For high-value targets, assume the target is monitoring too.

Speed matters. 45% of escapes happen in the first hour. Every delay in execution increases the risk.

Watch for patterns. Single transfers to fresh addresses. Scatter patterns across many wallets. Near-identical amounts across multiple proposals. These signal an actor gaming the system.

BlockSec’s USDT Freeze Tracker and Phalcon Compliance give compliance teams real-time visibility into freeze proposals and fund flows. When a $37 million escape can happen in under 6 minutes, you need to be watching.


Methodology

  • Data source: On-chain data from Ethereum and Tron, processed via the BlockSec USDT Freeze Dashboard.
  • Period: November 28, 2017 – February 14, 2026.
  • Scope: All 8,310 executed addBlackList proposals across both chains.
  • Escape definition: USDT transfers where from_address = proposal target address, occurring between proposal submit_time and execute_time. Address-poisoning transfers excluded.
  • Cross-validation: All results independently verified using both Python and Go, with matching outputs.
  • Limitation: Earlier versions of our Tron transfer data contained non-USDT TRC20 transfers from a legacy API endpoint. All Tron addresses have since been re-fetched using the corrected API, and the data used in this analysis reflects the cleaned dataset.
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