OCAPS: crypto-asset ownership certificate with proof of origin

The OCAPS (On Chain Asset Statement) proves three things in a snapshot as of the issue date: which crypto-assets you hold, that they are yours and where they come from. It is the report for notaries, inheritances, holding vehicles, custodians and platform KYC processes.

Ownership · Screening · On-chain analysis · Wallet risk

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What the OCAPS proves

It answers one question: what does this person hold, is it theirs and where does it come from? Every statement in the report rests on evidence that can be verified.

What it provesHow it is provenWhere to find it
Identity of the holderKYC and signed statements from the holder.Section 1
ScopeList of all declared wallets and platforms.Section 2
Control of each walletSatoshi Test for each address, with the full hash of the test transcribed.Section 3
No sanctionsScreening against the OFAC, EU, UN and UK lists, PEP and adverse media, with a result for each list.Section 4
Source of fundsOn-chain tracing from the money invested to the current positions, with reconciliation.Section 5
Platform riskRisk score for each platform (low, medium or medium-high) and an overall rating.Section 6
Positions and valueUnified table: address, evidence, asset, quantity and valuation, with source and time.Section 8
See the full structure Request an OCAPS It is a snapshot as of the issue date: it certifies the situation on that day and does not include periodic updates.

What is inside an OCAPS

A fixed structure of 9 to 27 pages, depending on the number of wallets and platforms. Always the same sections in the same order, so the recipient knows where to look.

Preliminaries

Cover, disclaimer and summary

Cover page, disclaimer and a five-point executive summary for readers who only read the first page.

Sections 1 to 6

The tests

Identification, scope, Satoshi Test, screening, on-chain tracing and risk scoring for each platform.

Sections 7 to 9

Methodology and conclusion

KYT methodology, asset snapshot with its total, and a legal conclusion signed by a lawyer.

What it contains, section by section

  1. Preliminaries · Cover page, disclaimer and executive summary.
  2. Section 1 · Identification of the holder (KYC) and their statements.
  3. Section 2 · Declared wallets and platforms: the scope of the report.
  4. Section 3 · Satoshi Test for each address, with the hash transcribed.
  5. Section 4 · Screening: OFAC, EU, UN, UK, PEP and adverse media.
  6. Section 5 · On-chain tracing: source of funds, activity and reconciliation.
  7. Section 6 · Risk scoring for each platform and overall rating.
  8. Section 7 · KYT methodology and tools used.
  9. Section 8 · Asset snapshot: unified table of positions with their valuation.
  10. Section 9 · Legal conclusion, with an express result and observations.

Do you also need tax, beneficial ownership or your dealings with your bank covered? That is what the OCACS is for.

The tests

Satoshi Test, screening, tracing and valuation

An OCAPS does not rely on what the holder declares, but on what can be checked. These are its four technical tests.

Satoshi Test to prove control of a walletSatoshi Test

Control of each wallet

The holder sends a minimal amount from each address, following our instructions. The hash of that transaction is transcribed in full.

  • For each address
  • Full hash
  • Date of the test
Screening against sanctions and PEP listsScreening

Sanctions, PEP and media

The holder and related persons are checked against sanctions lists, PEP databases and adverse media, with a result for each list.

  • OFAC, EU, UN, UK
  • PEP
  • Adverse media
On-chain tracing of the source of fundsTracing

From the money invested to the positions

We rebuild the path from the money contributed to the current positions and reconcile it with the platforms’ transaction histories.

  • Contributions
  • On-chain path
  • Reconciliation
OCAPS result and signatureResult

How the report ends

Result

Legal conclusion with an express result.

Observations

Any caveats, in writing.

Signature

A lawyer registered with the Bar, with an electronic signature.

When to request it

Who the OCAPS is for

Recipient
What they need to know
Why the OCAPS is enough

Notary

That the crypto-assets exist, belong to the person appearing before the notary and have a traceable origin.

Inheritance or estate

Which crypto-assets there are, in which wallets and what they are worth.

Holding vehicle or company

What is being contributed, and that the person contributing it is its owner.

Scope, control of the wallets and valuation of what is contributed.

Custodian

That the depositor controls the wallets and that the funds are not exposed to sanctions.

Satoshi Test, screening and risk for each platform.

Platform KYC or KYB

Ownership, origin and risk of the funds to be deposited.

It answers the usual customer onboarding questions.

When the OCAPS falls short

In these cases, an OCACS is the better choice:

  • A bank’s compliance department will review it.
  • The bank has already sent you a request for information or has held a transfer.
  • There is a spouse with community property (gananciales) or there are interposed companies.
  • Your wealth comes from more than what you invested in crypto: a business, an inheritance or real estate.
  • You need to prove what you have declared to the Spanish Tax Agency.

Are you going to present your crypto-assets to a notary or a platform?

We prepare the OCAPS with Satoshi Test, screening, on-chain tracing and valuation, signed by a lawyer.

OCAPS: common questions

What is the OCAPS?

It is the On Chain Asset Statement: a report signed by a lawyer that proves which crypto-assets a person holds, that they are theirs and where they come from, as a snapshot at the issue date. It includes a Satoshi Test, screening, on-chain tracing, platform risk and valuation.

What is the Satoshi Test?

It is a control test: the holder sends a minimal amount from each address, following our instructions. The transaction shows that whoever makes it controls the keys to that wallet. In the OCAPS, the hash of each test is transcribed in full, address by address.

What is the difference between the OCAPS and the OCACS?

The OCAPS focuses on the assets: what there is, who it belongs to and where it comes from. The OCACS focuses on the relationship with a bank: it adds the customer profile, the source of all wealth, tax, risk and expected activity. The OCACS includes a full OCAPS.

Can I use the OCAPS with my bank?

It can form part of the documentation. But if the compliance department will review it to open or keep your account, the report designed for that decision is the OCACS.

How long is an OCAPS valid?

It certifies the situation on its issue date and does not include periodic updates. It has no legal expiry date: each recipient decides how old a report it will accept.

What do I need to provide?

Your ID, the list of wallets and platforms, your exchange transaction histories and the bank statements for the money you contributed. You also carry out the Satoshi Test for each address. Everything is handled through our portal.

Can I move from an OCAPS to an OCACS later?

Yes. The full OCAPS goes into the OCACS, so the Satoshi Test, the inventory and the reconciliation are not repeated: only the new blocks are added.

Can the OCAPS be extended without going all the way to an OCACS?

Yes, with specific modules: beneficial ownership, tax, or responding to red flags. The report is still an OCAPS, with what you have been asked for and nothing more.

What the OCAPS is based on

The report is prepared in accordance with anti-money laundering and data protection legislation, using KYT methodology.

Verifiable: every statement points to evidence: a hash, a list or a transaction history.

No adjectives: where an assessment would go, the figure goes.

Dated snapshot: the valuation is made at a single point in time, with source and time.

Law 10/2010 Anti-money laundering

The due diligence framework that notaries, banks and platforms apply when reviewing the source of funds.

GDPR Data protection

The data of the holder and related persons is processed only for the purpose of the report.

KYT On-chain analysis

Know Your Transaction: risk analysis of the addresses and transactions within the scope.

Differences between the OCAPS and the OCACS

Both share the same technical tests. What changes is the question they answer, the recipient and what they analyze. A simple rule: if a bank’s compliance department will read it, OCACS; in all other cases, OCAPS.

AspectOCAPSOCACS
QuestionWhat 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?
RecipientNotary, inheritance, holding vehicle, custodian, platform KYC.Compliance department of a financial institution.
SubjectThe assets.The business relationship.
Time frameSnapshot as of the issue date.Past and future: expected activity and ongoing due diligence.
OriginOf the funds invested in crypto.Of all wealth and of the funds, separately and by tax year.
RiskRisk score for each platform.Inherent money laundering risk, measures and residual risk.
TaxNot covered.Personal income tax (IRPF) by tax year, third-party tax reports and Form 721.
Length9 to 27 pages.27 to 32 pages, plus annexes.

Everything the OCAPS proves is included in the OCACS. More detail in OCACS: enhanced due diligence report.

Book a call

Tell us who you will submit the report to: we will tell you whether the OCAPS fits or you need an OCACS.

OCAPS: crypto-asset certificate with on-chain analysis

The OCAPS (On Chain Asset Statement) is Molina Law Boutique’s crypto-asset ownership certificate. As a snapshot at the issue date, it proves which crypto-assets a person holds, that they control them and where the funds used to acquire them came from. It is signed by a lawyer registered with the Bar and always follows the same structure, so that notaries, custodians and platforms find each piece of evidence in the same place.

What the Satoshi Test is

The Satoshi Test is the control test that many exchanges and custodians ask for: the holder sends a minimal amount from their wallet to show that they hold its keys. In the OCAPS it is done for every address within the scope, and the hash of each test is transcribed in full.

Screening and tracing

The report checks the holder and related persons against the OFAC, EU, UN and UK sanctions lists, PEP databases and adverse media. It then rebuilds the source of funds on-chain and reconciles it with the platforms’ transaction histories, using KYT methodology and in line with Law 10/2010 and the GDPR.

OCAPS or OCACS

When the recipient is a bank’s compliance department, the right report is the OCACS, which includes a full OCAPS and adds the holder’s profile, the source of all their wealth, tax, money laundering risk and expected activity. If you only need to prove the source of funds for one transaction, see also the crypto certificate.

OCAPS Crypto-asset certificate Satoshi Test Screening On-chain tracing KYT Law 10/2010

Official sources

Key legislation, linked to the official text:

Legislation and links reviewed in .