My bank does not accept my substantiation of crypto assets, on what grounds is such a file rejected?

On what grounds is a file about the origin of crypto assets rejected?

A file on the origin of crypto assets is rejected on five grounds, and all five concern the verifiability of your documents rather than your honesty. Paucitas sees these five returning in almost every rejected file, separately or in combination.

1. The chain does not close: between stepping in and stepping out there is a period filled with text instead of with entries.
2. The amounts do not add up: the total in your overview does not arrive at the amount credited, not even after exchange rate differences and fees.
3. The source is an export and not a verification: a printout from a platform or portfolio app whose underlying entries have not been recalculated.
4. Control over the wallets is not substantiated: an address appears in the file, but not what shows that you had control over it.
5. An unreachable part of the history is not named: a platform that no longer exists or a closed account, where an assumption stands instead of an explicit limitation.

The fifth ground is the least understood and at the same time the easiest to repair. A limitation you name yourself is a finding; the same limitation that an assessor has to discover for themselves is a question mark over the whole file.

On the customer due diligence resting on crypto service providers and the data they record in that process, the European Banking Authority publishes; on the origin of funds in wider supervision, De Nederlandsche Bank publishes.

Which four parts does a file on the origin of assets have and which part is missing most often?

A file on the origin of crypto assets has four parts: the entry phase, the build up phase, the phase in which you held the assets and the exit phase. The part missing most often is the build up phase, and that is exactly the part connecting the other three.

• Entry: what the first purchase was paid with, with the bank entry, the salary, the sale or the gift underlying it.
• Build up: every purchase, swap, staking yield and transfer in between, closing in time and in amount.
• Holding: on which wallets and with which providers the assets stood and what shows that you had control over them.
• Exit: the sale and the entry with which the amount ends up in your account, traceable to the entries beneath it.

Whoever supplies only entry and exit supplies two end points without a route. Paucitas therefore starts with the build up phase and works from there in both directions, because that phase determines whether the amounts add up at the end.

Why does an assessor ask for a reconstruction and not for a statement?

An assessor asks for a reconstruction because they have to be able to carry their own conclusion, and they can only do that if they can walk through every step themselves. A statement asks for trust, a reconstruction asks for calculation, and only the second is transferable to the next person who picks up the file.

For the origin of crypto assets that means three things for the form of your documents. Every line has a source that can be checked independently of your explanation. Every amount can be traced to an entry with date and time. And every assumption is named as an assumption, not as a fact.

Paucitas uses no automated analysis software, in any role whatsoever. The investigation is done manually on the basis of publicly accessible block explorers. Every transaction and every transaction hash is verified one by one before it is included in a report.

What you supply concretely and in which form is set out on the question page about substantiating crypto assets for a bank. What an assessor on the other side of the table looks at is set out on the page for banks, notaries and compliance.

What can you repair yourself and when is that no longer enough?

For the origin of crypto assets you can repair three things yourself: request the bank entry underneath your first purchase, download the transaction history of your current providers and note per wallet the addresses you had control over. With that you often already have entry and holding in place.

It is no longer enough as soon as a provider has disappeared, as soon as there are years in between with only internal transfers, or as soon as the amounts still do not add up after your own count. The problem is then not that documents are missing, but that the remaining data has to be set against each other.

Data is supplied digitally or at the office. Per case a delivery list is provided which states what data is needed. Where necessary Paucitas guides the collection and delivery of that data.

Pay attention to the following, because with questions about origin in particular, data is sometimes requested that you never have to hand over in order to show ownership.

Paucitas never asks of its own accord for your recovery phrase or private key. If you need help reading out or restoring your wallet, we guide you through that completely, without us having to see that data ourselves.

• A report by Paucitas limits itself to factual observations and the investigation of those observations.
• Transactions outside the blockchain, such as cash payments or internal entries within an exchange, are not visible in blockchain data. They are only included if underlying documents are available.
• Paucitas gives no tax or legal advice.
• The report states explicitly to what extent there is still access to the wallet concerned, because that determines what can in fact be established.

That is where the limit of this work lies: Paucitas establishes what follows from the data and names explicitly what can no longer be established, but whether an assessor then accepts the file lies outside the influence of an investigator.

What does the report look like and how long does it take?

The report on the origin of crypto assets consists of a chronological overview of all entries, a closing count per period and an explicit list of what cannot be established. A report by Paucitas follows a fixed structure: occasion and description of the assignment, question, scope, starting points, data supplied, sources consulted, method in outline, verification and quality assurance, reservations and limitations, findings per element, chronological overview, analysis and coherence, conclusion, statement of independence and appendices. Not every report contains all elements.

An investigation by Paucitas takes, depending on the size of the file and the urgency, between one working day and two weeks. An urgent report can be delivered within one working day and in exceptional cases on the same day. A regular investigation is usually ready within three working days. In files with many transactions, several wallets or missing history the lead time rises to around two weeks. A surcharge applies to urgent assignments.

Paucitas works with a fixed price based on your situation. Sometimes we apply an hourly rate in consultation, but the hours are always fixed in advance, so that you never face surprises. No investigation is started before the costs have been discussed and agreed.

Paucitas usually responds within a few minutes to an hour and in almost all cases the same working day.

Which investigation belongs here you can read under source of funds. If you want to see the order of the steps before you start, that is set out in the step by step plan for a proof of origin file.

Send Paucitas your current substantiation together with the response you received. In a first assessment it is named on which of the five grounds your file is now stuck and which part of the build up phase has to be reconstructed for it.

Date of last revision: 8 September 2026.