From the assets to the relationship
It covers the beneficial owner, the spouse, total wealth and the purpose of the relationship with the bank.
OCACS: crypto enhanced due diligence (EDD) report for your bank
The OCACS (On Chain Asset Compliance Statement) is an enhanced due diligence (EDD) report written for your bank’s compliance analyst. It gives the analyst what they need to decide whether to open or keep the relationship: your profile, the source of your wealth and of your funds, your tax position, the risk and your expected activity.
Enhanced Due Diligence (EDD) Report · Includes a full OCAPSIs your bank reviewing your crypto funds? We’ll tell you for free if you need an OCACS
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- Enhanced due diligence
- Art. 11
- Reporting crypto held abroad
- Form 721
- Key legislation
- Law 10/2010
- Implementing regulation
- Royal Decree 304/2014
What it certifies
What the OCACS proves
It covers the same ground as the OCAPS (which crypto-assets you hold, that they are yours and where they come from) and adds what the bank needs to decide on the relationship.
| What it proves | How it is proven | Section |
|---|---|---|
| Identity, activity and beneficial ownership | Holder’s details, professional activity, marital property regime and interposed structures. | §2 |
| PEPs, sanctions and adverse media | Enhanced screening of the holder, their spouse and the beneficial owners, with results for each list and an analysis of jurisdictions. | §3 |
| Purpose of the relationship | Why you want the relationship with the bank, what activity you expect and what you do not. | §4 |
| Source of wealth | How all your wealth was generated, broken down by year, including its crypto portion. | §5 |
| Source of funds | The full chain of the specific funds, with the mechanics of how they are paid in. | §6 |
| Crypto-assets | The full OCAPS: inventory, Satoshi Test and reconciliation of KYC, personal income tax (IRPF) and blockchain. | §7 |
| Money laundering risk | Risk factors, inherent risk, mitigating measures and residual risk. | §8 |
| Tax | Personal income tax (IRPF) by year, reconciled third-party tax reports and Form 721. | §9 |
See the structure
Compare with the OCAPS
The bank still makes the decision: the OCACS gives it the information to do so without successive requests for information.
Structure
Inside an OCACS
A legal and methodological framework, twelve sections and numbered annexes: 27 to 32 pages, plus the supporting documents.
Past and future
Besides the source of all your wealth, the expected banking activity, with amounts and frequencies, and ongoing due diligence.
Three layers that match
What you declared in the KYC, what you declared to the Tax Agency and what is verified on the blockchain must tell the same story.
What it contains, section by section
- §0 · Legal framework, methodology and standard of proof.
- §1 · Executive summary: conclusion and summary by section.
- §2 · Identification, economic activity, beneficial ownership and marital property regime.
- §3 · PEPs, sanctions, jurisdictions and adverse media.
- §4 · Purpose of the relationship and expected activity, including activity that is not expected.
- §5 and §6 · Source of wealth and source of funds, separately.
- §7 · Crypto-asset traceability: the full OCAPS, with KYC, income tax (IRPF) and on-chain reconciliation.
- §8 and §9 · Money laundering risk self-assessment and tax treatment.
- §10 and §11 · Answers to red flags and future banking activity.
- §12 and annexes · Declarations, signatures of the issuer and the holder, and numbered annexes.
Already have an OCAPS? It goes in as §7 without repeating the Satoshi Test or the inventory.
Avoiding requests for information
The parts that spare you the most questions from the bank
The compliance analyst has a list of questions. The OCACS answers them before they are asked, each one with its supporting document.
§10Answers to red flags
A catalog of the red flags the analyst may see, each with its answer and the annex that supports it.
- Flag
- Answer
- Annex
§5 and §6Wealth and funds, separately
How your wealth was generated and where the specific funds come from, by year and with figures.
- Wealth
- Funds
- By year
§7.5Three-way reconciliation
What you declared in the KYC, what you declared to the Tax Agency and what the blockchain shows, cross-checked and matched.
- KYC
- Income tax
- On-chain
§11Future banking activity
The flows the account will have, with amounts and frequencies, the supporting documents for each transaction and your commitment to transparency.
This lets the bank set its monitoring without asking you for everything again.
OutcomeA single verdict
Lawfulness
Conclusion on the source of funds.
Inherent risk
Before the measures.
Residual risk
After the measures.
What we will ask you for
The OCACS documentation
Personal income tax (IRPF) returns for the last three years
Always.
They prove your income profile.
Certificate of bank holdings
Always.
Shows how much of your wealth is in crypto.
Purpose and activity forms
Always.
What the report is for, who it is addressed to and what activity you expect, with amounts and frequency.
Spouse’s ID and marital agreement
If you have a spouse or partner, or a separation of property regime.
Your spouse is included in the screening; the marital property regime defines what belongs to whom.
Deeds of companies or structures
If companies or trusts are involved.
They make it possible to determine beneficial ownership.
Statements from Wise, Revolut and similar
If you use neobanks or payment platforms.
They close the money trail.
Income tax (IRPF) returns for the years with crypto, tax report and Form 721
If you have them.
They make the tax reconciliation possible.
When not to request an OCACS
More documentation is not always better:
- For a notary or a holding vehicle, the OCAPS is enough.
- Tax and wealth data that nobody has asked for raise new questions.
- If you only need to prove ownership and value, the OCACS is more than you need.
- If you are only missing one block, such as tax or the beneficial owner, it can be added to the OCAPS.
Has your bank held a transfer or is it asking you for more documents?
We prepare the OCACS so that the compliance department has everything it needs to decide in a single document.
Frequently asked questions
OCACS: common questions
What is the OCACS?
It is the On Chain Asset Compliance Statement: an enhanced due diligence (EDD) report written for a bank’s compliance department. It brings together in one document your profile, the source of your wealth and of your funds, your crypto-assets, your tax position, the risk and the activity you will carry out with the institution.
What is enhanced due diligence?
These are the additional measures that banks and other obliged entities apply when a relationship presents a higher risk (Article 11 of Law 10/2010). Many institutions treat funds that come from crypto-assets as higher risk, which is why they ask for more documentation.
What is the difference between source of wealth and source of funds?
The source of wealth (origen del patrimonio) explains how all your wealth was generated: work, a business, inheritances, investments. The source of funds (origen de los fondos) explains where the specific funds for the transaction come from. The OCACS documents them separately and by year.
When do I need an OCACS instead of an OCAPS?
When the report will be read by a bank’s compliance department: to move crypto proceeds into the banking system, open an account or receive funds that come from crypto in Spain. For notaries, inheritances or platforms, the OCAPS is usually enough.
Is the bank required to accept it?
No. The decision is the bank’s. The OCACS gives it the information in the order and within the framework its analysis uses, so it can decide without successive requests for information.
Do I need to have declared my crypto-assets?
The OCACS reconciles what you declared to the Tax Agency with what the blockchain shows. If there are years you have not declared, it is advisable to regularize them first: read how to declare crypto from previous years.
I already have an OCAPS: can I upgrade it to an OCACS?
Yes. The full OCAPS goes in as section 7 of the OCACS, without repeating the Satoshi Test, the inventory or the reconciliation. We will only ask you for the documents for the new blocks.
Who signs the OCACS?
The issuing lawyer, with an electronic signature. The holder also signs to confirm the information and documents they have provided.
Legal framework
The framework the bank’s analyst uses
The OCACS cites the same laws and standards the compliance department applies, so the department can read it in its own language.
Standard of proof: each conclusion refers to a numbered annex.
Formal control: numbered version, full date and consecutive annexes before signing.
Reusable: it is designed as a stable document for any financial institution.
Law 10/2010 and Royal Decree 304/2014
Anti-money laundering
Due diligence, enhanced measures and ongoing monitoring of the business relationship.
Directives (EU) 2015/849 and 2018/843
EU framework
The anti-money laundering directives, which cover crypto-asset providers.
Regulations (EU) 2023/1113 and 2023/1114
Travel Rule and MiCA
Crypto-asset transfers and the regime for crypto-asset service providers in the EU.
OCACS or OCAPS
Differences between the OCACS and the OCAPS
The OCACS contains a full OCAPS and changes the recipient, the scope and the outcome. Simple rule: if a bank’s compliance department will read it, OCACS; in all other cases, OCAPS.
| Aspect | OCAPS | OCACS |
|---|---|---|
| Question | What does this person hold, is it theirs and where does it come from? | Can the bank take on or maintain the relationship with this person? |
| Recipient | Notary, inheritance, holding vehicle, custodian, platform KYC. | Compliance department of a financial institution. |
| Scope | The assets. | The business relationship. |
| Time frame | Snapshot as of the issue date. | Past and future: expected activity and ongoing due diligence. |
| Source | Of the funds invested in crypto. | Of wealth and of funds, separately and by year. |
| Screening | Sanctions (OFAC, EU, UN, United Kingdom), PEPs and adverse media on the holder and related parties. | All of the above, enhanced: PEP check against an external database, spouse and beneficial owners, with a documented report. |
| Risk | Scoring by platform. | Inherent money laundering risk, measures and residual risk. |
| Tax | Not included. | Personal income tax (IRPF) by year, third-party tax reports and Form 721. |
| Signature | Bar-registered lawyer. | Issuing lawyer, with ratification by the holder. |
| Length | 9 to 27 pages. | 27 to 32 pages, plus annexes. |
Is proving your assets enough? See the OCAPS: crypto-asset certificate.
Contact
Book a call
Tell us what your bank is asking for and what transaction you want to carry out: we will tell you whether you need an OCACS or an OCAPS is enough.
OCACS: enhanced due diligence report for crypto-assets
The OCACS (On Chain Asset Compliance Statement) is an enhanced due diligence (EDD) report prepared for the compliance department of a financial institution. Its purpose is to let the bank understand, verify and assess, in a single document, the lawful origin, ownership and traceability of the holder’s funds and crypto-assets, without successive requests for information.
Source of wealth and source of funds
The report separates the source of wealth (origen del patrimonio), that is, how all of the holder’s wealth was generated, from the source of funds (origen de los fondos) of the specific transaction. Both are documented by year and reconciled with personal income tax (IRPF) returns and with on-chain traceability.
Risk and expected activity
The OCACS includes a money laundering risk self-assessment (inherent risk, measures and residual risk), a catalog of red flags with their answers and the expected banking activity, with amounts and frequencies. It relies on Law 10/2010 and Royal Decree 304/2014, the EU anti-money laundering directives, Regulations (EU) 2023/1113 and 2023/1114, the FATF Recommendations, EBA and SEPBLAC guidance, the Wolfsberg Principles and Law 35/2006 on Personal Income Tax (IRPF).
OCACS and OCAPS
Section 7 of the OCACS is a full OCAPS: the Satoshi Test, inventory, valuation, reconciliation and screening are done once and serve both reports. If your bank has already held a transfer, also read what to do with an account blocked because of crypto.
Crypto reports
Banks
Official sources
Key legislation, linked to the official text:
- Law 10/2010 of April 28 on the prevention of money laundering and terrorist financingBOE · consolidated text
- Royal Decree 304/2014 of May 5 approving the Regulation of Law 10/2010 of April 28 on the prevention of money laundering and terrorist financingBOE · consolidated text
- Law 35/2006 of November 28 on Personal Income TaxBOE · consolidated text
Legislation and links reviewed in .