Crypto Millionaires Face New Source-of-Wealth Scrutiny
Key Takeaways
- •Henley estimates a global population of 135,694 crypto millionaires, but the figure is not based on a verified individual registry.
- •HMRC recorded 17,600 UK taxpayers with crypto gains in 2024-25, while 240 reported gains above £1 million and generated about 52% of the total.
- •A large blockchain balance does not by itself prove legal ownership, legitimate acquisition or a complete source-of-wealth history.
- •Banks and trust providers may require records covering capital origins, exchange activity, wallet ownership, tax reporting and transfers across networks.
- •Some institutions may accept documented crypto wealth after enhanced checks, while others may reject assets that fall outside their custody or investment policies.

Henley estimates 135,694 crypto millionaires worldwide
Between 132,000 and 154,000 people worldwide hold cryptocurrency worth at least $1 million, according to Henley’s Crypto Wealth Report 2026. The report’s central estimate is 135,694 crypto millionaires.
Henley also estimates that 92,272 people have at least $1 million in Bitcoin exposure, including qualifying exchange-traded fund holdings under its methodology. At the higher end of the scale, the report counts approximately 290 crypto investors with portfolios exceeding $100 million and 23 crypto billionaires.
These figures are modeled estimates rather than a registry of verified individuals. Henley’s methodology combines blockchain data, exchange information, estimates of ETF ownership and assumptions about wealth distribution. The methodology also changed for the 2026 edition, making the results unsuitable for direct comparison with the 241,700 crypto millionaires estimated in 2025. Details are provided in the report’s 2026 methodology.
The latest estimates nevertheless indicate 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. For those seeking to move crypto wealth into traditional financial structures, asset value is only one part of the review.
UK tax data shows where realized gains are concentrated
The Henley estimate covers crypto millionaires worldwide. Data from HM Revenue and Customs focuses on UK taxpayers and answers a different question: who reported realizing gains at that scale?
HMRC recorded 17,600 UK taxpayers with cryptoasset gains during the 2024-25 tax year. Those taxpayers reported approximately $18.7 billion (£13.8 billion) in disposal proceeds and $1.87 billion (£1.38 billion) in gains, according to HMRC statistics.
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, approximately 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 proceeds are transferred to private banks, placed in trusts or used for major property purchases. However, the 240 taxpayers do not represent 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 cryptocurrency 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 assets may be worth at a particular time. Moving that wealth into a traditional structure requires evidence showing how the assets were acquired and who controlled them throughout the relevant period.
The Financial Times reported that some trust companies have declined clients with crypto-derived fortunes when the clients could not establish a satisfactory source-of-wealth history. Lawyers and trustees cited concerns including missing transaction records, uncertain token provenance, volatility and the trustee’s long-term responsibility to beneficiaries. The report is available from the Financial Times.
A public wallet containing a large balance does not resolve those questions. It may show that assets exist at a particular address, but it does not by itself prove that the applicant owns the address or that the original funds were acquired 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 purpose of each transaction.
For example, an investor may have 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 the investor eventually sends stablecoins to an exchange and withdraws pounds, the initial bank transfer and final withdrawal show 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 on the blockchain.
Tax returns and withdrawals show only 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. Those reviews can cover the original capital, account ownership, transaction counterparties, custody arrangements and exposure to sanctioned or illicit addresses.
Converting cryptocurrency 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.
Additional questions may 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 the transaction’s purpose. Such activity does not establish wrongdoing, but the holder may need other documents to explain it.
Six types of records crypto holders should preserve
The most useful evidence is collected while activity is taking place, particularly because exchanges and protocols may not retain downloadable records indefinitely.
Original source of capital: Keep bank transfer records and documents showing whether funds came from employment, a business, an investment sale, a loan, an inheritance or another identifiable source.
Exchange statements: Download records of deposits, withdrawals and trades, along with account information connecting each exchange profile to its verified owner.
Wallet ownership: Maintain an inventory of personal addresses and record 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 remains traceable when assets change form or move to another 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
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 issue is that crypto cases may require years of wallet reconstruction and technical analysis. Some traditional providers may conclude 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.
Source: https://coindoo.com/crypto-millionaires-face-new-wealth-test/