The Vanuatu Financial Intelligence Unit does not care how many sats you hold. Source of funds is the anti-money-laundering (AML) core of the file: the VFIU, and the blockchain chain-analysis it relies on, want a clean audit trail from the first purchase or earnings event to your current address. That trail is the file. Below is how it works in practice, drawn from the files we actually lodge.
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Most Bitcoiners walk into a CBI conversation assuming the source-of-funds question is about whether their wealth is “real.” It is not. The VFIU has no opinion on whether Bitcoin is wealth. The question is procedural: can you tell the on-chain story end to end, with documentation at every transition, in a form an FATF-aligned compliance officer can audit without a single follow-up email.
This is not a Bitcoin-specific problem; it is the same standard a wire from a stock-options exit faces. What is Bitcoin-specific is the documentation shape. Banks issue statements; self-custody does not. The VFIU has adapted its expectations to that reality. We pre-audit your file before submission so the package answers their questions before they ask them. The source-of-funds review sits inside the wider Vanuatu CBI process, and across the path to citizenship by investment it is the part that most often decides the outcome.
The Vanuatu unit accepts exchange purchase records, custody statements from regulated providers, transaction-by-transaction wallet history, and on-chain signed-message proofs of address control. Every Bitcoin-funded file is some combination of these four primitives.
Coinbase, Kraken, Bitstamp, River, Strike, regulated regional venues. We need the original purchase date, fiat amount, fiat source (the bank wire that funded the buy), exchange-side custodian, and the withdrawal address. Most exchanges export this directly as a CSV; some require a written request. We help you pull it.
BitGo, Anchorage, Casa, Unchained, Swan, NYDFS-regulated custodians, EU MiCA-licensed venues. A monthly or quarterly statement from a regulated custodian satisfies the VFIU’s “institutional touch” expectation the same way a Schwab statement satisfies a Caribbean program. Self-custody alone is not disqualifying; it just needs to be paired with the next two primitives.
A list of every UTXO that lands at your current address, tagged by source (exchange withdrawal, mining payout, payment received, prior wallet consolidation, etc.). Tools that produce VFIU-ready exports: Sparrow, BlueWallet PRO, Specter, Casa, Unchained, or a bespoke export we generate for you from a public address list. The graph does not need to be public; it needs to be coherent.
For any address that appears in your wallet history, you sign a message proving you control the private key. The VFIU does not need the keys themselves and does not request them. They need cryptographic proof that the addresses in your file are yours. We provide a script that handles the signing flow without exposing the keys to anything other than your own hardware device.
The single most common documentation gap on a Bitcoin application: the file shows one half, exchange or self-custody, never both, and never tied together. The VFIU treats this as an incomplete trail and routes the file for enhanced review, adding weeks.
The exchange CSV proves the purchase happened. The signed message proves the destination wallet is yours. Without both halves, the on-chain story has a missing chapter.
Half one: the exchange’s CSV showing the buy, the fiat source, the date, and the withdrawal address. Half two: a signed message from that withdrawal address proving you control it. Stitch the two halves; the chain of custody is intact. We do this stitch on every file we handle.
Mining rewards are documented via mining pool statements (Foundry, Antpool, F2Pool, etc.) plus hash-rate evidence (electricity bills, hardware invoices) showing the operation existed. Solo miners document the pool-equivalent: the block templates, the hash-rate-on-network share, and the coinbase outputs at the addresses you control.
If you accepted Bitcoin for services rendered (freelancers, agencies, advisory work), the file is your invoice, the engagement contract, and the on-chain payment matching the invoiced amount. Multiple small payments aggregate cleanly via wallet history; the VFIU accepts a payment ledger keyed to invoices.
For Bitcoin acquired before exchange records existed (Mt. Gox, early peer-to-peer, faucet, etc.), the file is reconstructed from the on-chain history, bank wires that funded the original purchase if available, and a signed affidavit attesting to the acquisition. The VFIU accepts this combination for pre-2014 holdings; later holdings need a stronger paper trail.
You provide the wallet, exchange, and transaction records relevant to the funds you plan to use or convert for the file. Self-custody, exchange-held, multisig, hardware wallets, paper wallets, and Lightning channels can all be documented. We do not need keys; we need records that connect the funds to you.
We trace each UTXO backward to its original source (exchange purchase, mining reward, payment, prior wallet). We flag every gap before the VFIU does. Most applications have one or two gaps; we resolve them with you before filing.
Exchange CSVs, custody statements, mining pool records, invoices, bank wires, signed messages from each address. Cross-referenced and indexed. The VFIU reads the package once; we make sure once is enough.
The full source-of-funds package is filed alongside the citizenship application. From this point the standard 30–60 day VFIU clock starts. Applications that arrived pre-audited clear in approximately one week of active screening; the rest of the window is administrative.
Bring an address list; we tell you what the file will look like, where the gaps are, and how long the reconstruction takes. The first call is a $475 engagement via BitSettle (BTC or USDT) or $500 via Stripe; whichever you pay is credited in full toward the advisory if you retain within 90 days, separate from the $5,000 VFIU line. No obligation to proceed. The first call is with Adam.
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