Confirmation of assets
Confirmation of the crypto holdings existing at a given date — for a financing enquiry or a filing, for instance. Without a full chain of origin, but quickly available.
AML
Service · Legal position 08/2026
Source of funds evidence for crypto assets
The payment has arrived, and the bank asks a single question: where did the money come from? Between that question and a frozen account there are often only days. A structured answer keeps the account. Screenshots cost time, and sometimes more than time.
The essentials
- Banks and notaries are obliged entities under the Money Laundering Act — the question is a statutory duty, not obstruction.
- What is required is an unbroken chain: first deposit, purchase, wallet and exchange movements, sale, withdrawal, use.
- A screenshot proves a balance, not an origin.
- Tax exemption after the holding period does not replace the evidence — they are two separate questions.
- Settling the tax position of earlier years belongs before submission, not after it.
Why the bank asks, and why it does not let go
Credit institutions, notaries and crypto service providers are obliged entities under the German Money Laundering Act. They must establish the origin of the assets involved, document the result, and file a suspicious activity report with the Financial Intelligence Unit where there are indications of money laundering. They are not permitted to tell the customer about that report.
Crypto assets count as a higher-risk constellation in this assessment: pseudonymous addresses, foreign trading venues, histories that become unavailable once a platform shuts down. The documentation requirements are correspondingly high — and the bank correspondingly quick to freeze an account when the answer does not convince.
Why this is urgent
The bank carries a risk of its own: failing to file a report that was required creates liability. In case of doubt it would rather freeze than investigate. If a report is filed and the Financial Intelligence Unit passes the matter on, it can become a money laundering investigation — and there, reckless conduct is already enough. With older holdings and no documentation, that is not a theoretical risk.
Who else asks
- Notaries on a property purchase, where the equity comes from crypto assets
- Trading platforms on withdrawals and when opening an account
- Insurers and asset managers before a contract or an engagement is accepted
- Tax offices in the course of establishing the facts
What is required: the closed chain
Good source of funds evidence is not a flood of data but an ordered chain of assets. The reviewer has to understand in a few minutes where the money came from and why today's payment is plausible.
Link 1
Where did the money invested come from?
Salary, sale proceeds, inheritance, a loan — evidenced by bank statements, contracts or assessments. This first link is the one most often forgotten, and the most important of them all.
Link 2
How did it become crypto?
The transfer to the exchange, the purchase confirmation, the first credit in the trading account. This is where the banking world and the crypto world join — the seam every review looks at first.
Link 3
What happened in between?
Purchases, exchanges, transfers between your own wallets, staking, DeFi. Every movement that changed the holding has to be attributable — including those that triggered no tax at all.
Link 4
How was it paid out?
The sale, the withdrawal to your own account, the amount and the date — reconciled with the credit on the bank statement.
Link 5
What is it being used for?
On a property purchase: the onward transfer to the notary's escrow account or to the seller. That closes the chain through to the purpose.
Tax documents strengthen this chain considerably, because they show that the gains were declared and assessed. They do not replace it — the bank is asking about origin, not about taxation.
Checklist: the documents you need
What to gather before you answer. The more complete the collection, the shorter the process.
Fiat side: where the money originally came from
- Bank statements for the period in which deposits were made — complete, not extracts
- Evidence of the origin of the funds: payslips, sale contracts, certificate of inheritance, loan agreement
- Transfer records to the trading platform
- Tax assessments for the years concerned
Crypto side: what happened on the platforms
- Machine-readable full exports from every exchange, covering the entire period
- Purchase and sale confirmations, where separately available
- A list of all your own wallet addresses, including retired ones
- Deposit and withdrawal history from the platforms
- Records of staking, lending, airdrops and liquidity pools
- Evidence of purchases outside exchanges, such as cash or OTC trades
Use side: where the money is going
- The platform's withdrawal record and the matching credit on the bank account
- On a property purchase: purchase contract, financing commitment, notary escrow account
- The bank's letter, with the specific question asked and the deadline set
Where there are gaps, additionally
- Addresses of the exchange that can no longer be reached, so far as known
- Old emails containing confirmations, account openings or statements
- Contemporaneous bank records from which the deposit can be inferred
- Insolvency documents where a platform has shut down
Why submissions fail in practice
Five patterns that keep recurring — all of them avoidable.
01
Screenshots instead of exports
Screen captures show a state, not a development. They also cannot be processed, and they create the impression that something is being left out.
02
The first link is missing
The crypto part is complete, but where the money for the first deposit came from remains open. That is precisely where the review starts.
03
Data instead of order
Ten thousand rows without explanation is not an answer. A compliance officer has minutes, not days — the presentation decides.
04
Half an answer under time pressure
A deadline can as a rule be extended. An incomplete submission, by contrast, is hard to correct — it shapes the file.
05
The tax question ignored
Submitting evidence from which undeclared gains are apparent may trigger exactly what you were trying to avoid. Settle first, then submit.
The order decides
The point at which source of funds evidence differs from a collection of documents.
Earlier years first, then the bank
Complete source of funds evidence discloses the entire trading history. If it shows that gains went undeclared, the document meant to save your account is also the document capable of starting a tax investigation.
That is why the tax work belongs before the submission. Where years are open, the question whether a disclosure is possible and appropriate has to be answered before the papers leave the house.
A bank query is not yet discovery
A query from a bank is not by itself discovery of the offence within the meaning of section 371(2) of the Fiscal Code. The route to a voluntary disclosure is therefore not closed. The room does narrow sharply: if the query leads to a suspicious activity report, you will hear nothing about it, and the sequence of events continues without you.
- Step 1obtain an extension of the bank's deadline
- Step 2gather the data completely, crypto and fiat
- Step 3settle the tax position of the years concerned
- Step 4reconstruct open links through the blockchain
- Step 5ordered documentation for the institution asking
We handle both sides in one place: preparing the data for the evidence, and settling the tax years that become visible in the process. That is why this work sits better with a tax practice than with a pure data service.
Which form you actually need
Not every query calls for the full exercise. The right form saves time and cost.
Evidence for one payment
The chain for a specific amount: from the original deposit through to the credit that was questioned. The standard case in bank enquiries.
Full reconstruction
The entire history across all platforms, combined with settling the tax position of the years concerned. Required for property financing, large amounts and open earlier years.
Which form will suffice is something we establish in advance — where it helps, in direct contact with the institution that asked. That frequently reduces the scope considerably.
Questions and answers
At what amount does a bank start asking?
There is no fixed figure. The Money Laundering Act ties due diligence duties partly to thresholds, but banks and trading platforms in practice ask well below them — particularly on withdrawals from crypto exchanges, on first-time incoming payments, and on amounts that do not fit the previous pattern of the account.
My gains were tax free after the holding period. Do I still need evidence?
Yes. Source of funds and tax liability are two separate questions. The bank wants to know whether the money comes from lawful sources, not whether it was taxed. Tax documents strengthen the evidence considerably, but they do not replace the chain.
Is a screenshot from the exchange app enough?
No. A screenshot proves a balance, not an origin. What is required are machine-readable full exports covering the entire period, and a traceable link between wallet, exchange account, bank account and use of the funds.
What if the exchange no longer exists?
Then the position is reconstructed from the blockchain. Where a platform has shut down, the path of the coins can often be followed through the addresses, supported by contemporaneous bank records for the original deposit. The chain does not always become complete that way — but it can become solid enough for a bank to accept.
The bank has already asked. Is a voluntary disclosure now too late?
Not necessarily. A query from a bank is not by itself discovery of the offence within the meaning of section 371(2) of the Fiscal Code. It does narrow the room considerably, because a suspicious activity report to the Financial Intelligence Unit may follow and you will not be told about it. That is why the order matters: settle the earlier years first, then submit to the bank.
Do I always need full source of funds evidence?
Not in every case. Often a confirmation of assets is enough — a statement of the crypto holdings existing at a given date, for a financing enquiry for instance. Which form will suffice is something we clarify with you in advance and, where it helps, with the institution that asked.
Responsible for content: Matthias Steger, German certified tax advisor (Steuerberater), nine years as a tax auditor.
Legal position: 25 August 2026. Sources: the Money Laundering Act; section 371 of the Fiscal Code; section 261 of the Criminal Code.
Publications taken into account: published articles by colleagues informed this account, in particular Klein Steuerberatung on the documents banks and notaries require, and LHP Rechtsanwälte on source of funds and reporting duties. The assessment is our own.
This page is not advice on an individual case. Where this English text and the German version differ, the German version governs.
Legal position: 25 August 2026. Sources: the Money Laundering Act; section 371 of the Fiscal Code; section 261 of the Criminal Code.
Publications taken into account: published articles by colleagues informed this account, in particular Klein Steuerberatung on the documents banks and notaries require, and LHP Rechtsanwälte on source of funds and reporting duties. The assessment is our own.
This page is not advice on an individual case. Where this English text and the German version differ, the German version governs.