Crypto Millionaires Face a New Source-of-Wealth Test
Crypto wealth can be visible onchain and still fail a traditional source-of-wealth review because transaction history does not automatically prove who originally controlled the money.
Key Takeaways
- Henley estimates 135,694 crypto millionaires worldwide.
- HMRC recorded 240 seven-figure crypto gains.
- Wallet records cannot prove complete financial provenance.
- Trustees examine ownership, origin and risk.
- Tax filings document only part of history.
Henley estimates 135,694 crypto millionaires worldwide
Between 132,000 and 154,000 people hold cryptocurrency worth at least $1 million, according to the Crypto Wealth Report 2026. Its central estimate is 135,694.
The report also estimates that 92,272 people have at least $1 million in Bitcoin exposure, including qualifying ETF holdings under its methodology. Further up the scale, it counts approximately 290 crypto investors with portfolios exceeding $100 million and 23 crypto billionaires.
These figures are modeled estimates, not a registry of verified individuals. Henley’s methodology combines blockchain data, exchange information, ETF ownership estimates and assumptions about wealth distribution. It also changed for the 2026 edition, making the results unsuitable for direct comparison with the 241,700 crypto millionaires estimated in 2025.
The latest report nevertheless illustrates how many people may now hold portfolios large enough to seek trusts, private banking, estate planning and other services designed for high-net-worth clients.
UK tax data shows where realized gains are concentrated
The Henley estimate covers crypto millionaires worldwide. Data from HM Revenue and Customs narrows the focus to UK taxpayers and answers a different question: who reported realizing gains at that scale?
HM Revenue and Customs recorded 17,600 UK taxpayers with cryptoasset gains in the 2024-25 tax year. They reported approximately $18.7 billion (£13.8 billion) in disposal proceeds and $1.87 billion (£1.38 billion) in gains.
Within that group, 240 taxpayers declared gains exceeding approximately $1.36 million (£1 million). Together, they accounted for about $972 million (£717 million), or roughly 52% of all crypto gains reported by the 17,600 taxpayers.
In other words, about 1.4% of those reporting crypto gains generated more than half of the total. Transactions of that size can attract closer source-of-wealth checks when the proceeds are transferred to private banks, placed in trusts or used for major property purchases.
The 240 taxpayers are not an estimate of Britain’s entire crypto-millionaire population. HMRC counted gains from disposals during one tax year. Someone holding $1.36 million (£1 million) in unsold crypto would not appear in that group, while someone who realized a seven-figure gain might no longer hold a portfolio of the same value.
Dollar equivalents are approximate and use an exchange rate of £1 to $1.355 at the time of writing.
A seven-figure portfolio faces another test
A portfolio valuation establishes what the assets may be worth at a particular time. Moving that wealth into a traditional structure requires evidence showing how it was acquired and who controlled it along the way.
The Financial Times reported that some trust companies have declined clients with crypto-derived fortunes when they could not establish a satisfactory source-of-wealth history. Concerns cited by lawyers and trustees included missing transaction records, uncertain token provenance, volatility and the trustee’s long-term responsibility to beneficiaries.
A public wallet with a large balance does not resolve those questions. It may prove that assets exist at a particular address, but not that the applicant owns the address or earned the original money legitimately.
A blockchain records movement, not identity
Public blockchains show when assets moved, which addresses were involved and how much was transferred. They do not automatically connect those addresses to legal identities, bank accounts or the economic reason for each transaction.
Consider an investor who bought Bitcoin through a regulated exchange in 2017, moved it into self-custody and later used decentralized exchanges, cross-chain bridges and staking protocols. If that person eventually sends stablecoins to an exchange and withdraws pounds, the first bank transfer and final withdrawal provide only the beginning and end of the history.
A source-of-wealth review may also require evidence connecting the intermediate wallets, swaps and protocol activity to the same owner. Missing exchange exports or unidentified addresses can leave gaps even when every transfer remains publicly visible.
Tax returns and withdrawals show part of the record
A tax return can demonstrate that gains were declared and may support the acquisition costs used in the calculation. Trustees and banks still conduct their own reviews, which can cover the original capital, account ownership, transaction counterparties, custody arrangements and exposure to sanctioned or illicit addresses.
Converting crypto into pounds, dollars or euros does not change its origin. An exchange receipt confirms where the final payment came from, but a bank may look further back when the amount does not match the customer’s previously documented income or assets.
Extra questions can arise when transactions involve peer-to-peer transfers, privacy tools or informal over-the-counter trades because fewer conventional records may identify the counterparty and purpose. Such activity does not establish wrongdoing, but the holder may need other documents to explain it.
Six records crypto holders should preserve
The most useful evidence is collected while the activity is taking place, particularly when exchanges and protocols may not retain downloadable records indefinitely.
- Original source of capital: Keep bank transfers and documents showing whether the money came from employment, a business, an investment sale, a loan, inheritance or another identifiable source.
- Exchange statements: Download deposits, withdrawals, trades and account records connecting each exchange profile to its verified owner.
- Wallet ownership: Maintain an inventory of personal addresses and note when each wallet was created, funded, migrated or retired. Ownership can be demonstrated through methods such as signed messages or verification transfers; seed phrases and private keys should not be disclosed.
- Swaps and cross-chain activity: Record decentralized trades, bridges, wrapped assets, liquidity positions and transfers between personal wallets so the history continues when assets change form or network.
- Tax and income records: Preserve cost-basis calculations, valuation sources, tax returns and evidence supporting mining, staking, airdrop, employment or business income.
- Inheritance and custody planning: Keep a secure asset inventory and recovery plan. Preparing to pass Bitcoin to beneficiaries requires evidence of ownership as well as a controlled method of access.
Not every trust company rejects crypto wealth
The available reporting does not provide an industry-wide rejection rate. It is based on interviews with lawyers, trustees and wealth advisers, so it cannot support the broader claim that trust companies generally prohibit crypto-derived fortunes.
Some providers may accept crypto after enhanced checks, while others may accept documented cash proceeds but decline to hold volatile tokens directly. Even a complete source-of-wealth file cannot require a trustee to accept an asset that falls outside its custody capabilities or investment policy.
The narrower problem is that crypto cases may demand years of wallet reconstruction and technical analysis. Some traditional providers may decide that the cost, uncertainty or fiduciary exposure outweighs the value of taking on the client.
Documentation determines where the wealth can go
For crypto holders entering trusts, private banking or estate planning, portfolio value is only the first test. The decisive evidence is a continuous record connecting the original capital, verified accounts, personal wallets, taxable transactions and final proceeds. Without that record, a visible onchain fortune can remain difficult for a traditional wealth firm to accept.
This article is for informational purposes only and does not constitute legal, tax or financial advice. Requirements vary by institution and jurisdiction.
Alex is Editor-in-Chief of Coindoo and co-founder of Millennial Media Group, with nearly a decade of experience covering financial markets - crypto first, then everything else. It started in 2016 with Bitcoin. Like most people at the time, he didn't fully understand it - so he kept digging. Blockchain, tokenomics, the projects, the cycles. That curiosity never stopped, and eventually pulled him into traditional markets too: equities, commodities, macro. Not because he left crypto behind, but because you can't properly understand one without the other. What drives him is straightforward: he wants to know why something is happening, not just that it's happening. Most market coverage stops at the headline - price up, price down, here's a chart. Alex finds that kind of reporting actively unhelpful. If you walk away from an article without understanding the mechanism behind the move, what did you actually learn? He holds a degree in Tourism from New Bulgarian University - not the most obvious path into financial markets, but markets have a way of pulling in people who are simply too curious to stay out. He has authored over 200 in-depth analyses and more than 10,000 articles across crypto and traditional finance. He still thinks every day in markets teaches him something new. That's probably why he hasn't stopped.
