Source of funds

Why we ask at all

A desk that moves size in cash and on-chain is a target for people trying to place criminal proceeds. Refusing to look at that would not be discretion, it would be negligence — and it would end with the desk closed and every client’s access gone with it.

So we ask about the money, not about the person. Those are different questions and only one of them is any of our business.

When the question arrives

Below the band for your tier, it does not. Guests transact to €999, members to €9,999, VIP to €99,999 without being asked anything.

Above the band, and always above €100,000 on a single transaction, an operator asks once, in the chat, in plain language.

What a sufficient answer looks like

A sentence that makes the origin plausible and consistent with what we can see. Proceeds of a business sale. Salary accumulated over years. Bitcoin bought in 2017. Sale of a property. A settlement or an inheritance.

You may add a document if you want to, and some clients do because it ends the conversation faster. We read it and we do not keep it.

What is not sufficient

• Silence, a refusal to engage, or an answer that contradicts the pattern of the transaction.
• Funds you describe as belonging to someone else. Third-party funding is declined regardless of the explanation.
• A story adjusted after the first answer. We ask once and we listen carefully to the first version.

What happens to the answer

It attaches to the transaction record, not to a profile. If that record is burned, the answer goes with it, except where law obliges us to retain the minimal record described in the Privacy document.

It is read by the operator handling the request. Agents never see it — an agent knows a route, an amount and a city, and nothing else.

If we are not satisfied

The request is held rather than settled, and you are told plainly. Funds you have already sent are returned to their origin, less any unavoidable network or correspondent cost.

A hold is not a report. We are obliged to file in specific circumstances defined by law, and where we are, we cannot tell you. Where we are not, we simply decline and say so.

Splitting

Breaking one economic transaction into several to sit under a band defeats the purpose of the bands and is itself a reason to decline. The bands exist so ordinary amounts stay private, not as a threshold to engineer around.