Field Manual · Revised October 2026
The Source of Funds Dossier
A Crypto Holder's Guide to Proving Legitimacy to a Spanish Bank
The Source of Funds Dossier is a 127-page operational manual for proving the origin of crypto-derived funds to a Spanish bank or notary. It documents the seven-layer dossier structure, the five-paragraph narrative declaration, the chain-analysis anatomy, and the four-rung refusal playbook. Written for crypto holders facing enhanced due diligence reviews under Ley 10/2010, with five case files and five appendices.
- Length
- 127 Pages
- Revised
- Oct 2026
- Format
- Delivery
- Instant link
Why this manual exists
Your bank did not ask where your money came from because they suspect you. They asked because SEPBLAC requires them to.
What this guide solves
The seven-layer framework. Cover, Identity, Timeline, Transaction Record, On-Chain Evidence, Fiat Trail, Narrative Declaration. Each layer answers a specific question the compliance officer is legally required to ask. Chapter 3 walks every one.
The narrative declaration. The only layer you write from scratch. Five paragraphs, ~300 words, every claim referenced to a specific document. The exact architecture that gets a file past the ninety-second first-pass decision.
The refusal playbook. When the answer is no. Four refusal categories, each with a distinct correct response. The three-rung escalation ladder. The reconstruction protocol. The alternative lender landscape.
“The harbour master does not fear the ship with clean papers.”
— Salah Nomad
Inside the manual
- 1
The Question
The moment a banker asks where your money came from. Why crypto holders fail — and it is not honesty.
- 2
The Law's Logic
What the compliance officer actually does with your file. 45 minutes, hour by hour.
- 3
The Paper Trail
The seven layers. Cover, Identity, Timeline, Transaction Record, On-Chain Evidence, Fiat Trail, Narrative.
- 4
The Five Scenarios
Long-Term Accumulator, Mixed Accumulator, DeFi Operator, Business-Origin Holder, Inheritor.
- 5
The Narrative Declaration
The five-paragraph architecture. The seven pitfalls. The bilingual attestation.
- 6
The Bank Conversation
The first ninety seconds. The three questions. The four objections.
Show the other 8 chapters
- 7
The Refusal Playbook
Four refusal categories. The escalation ladder. The reconstruction protocol.
- 8
Source of Wealth
The biographical companion document. Five sections.
- 9
The Defense File
Physical structure, folder architecture, backup discipline, retention period.
- 10
Glossary of Source of Funds
Every term a compliance officer uses, decoded.
- 11
Master Checklist — The Seven-Layer Dossier
Printable on one page.
- 12
Templates Pack
Four documents, ready to adapt.
- 13
Chain Analysis Provider Comparison
Chainalysis, Elliptic, TRM Labs, Crystal Blockchain.
- 14
Anatomy of a Chain Analysis Report
Annotated page by page.
Is it for you?
Built for
- Crypto holders facing enhanced due diligence reviews under Ley 10/2010
- Buyers funding a Spanish property acquisition with crypto-derived funds
- Professionals preparing for the day a notary asks the question
Not for
- Crypto holders with only fiat-sourced funds — the dossier is not needed
- Anyone seeking to conceal the origin of their funds
- Readers expecting legal advice
Written by Salah Nomad
Independent research with no commissions from any lawyer, agent or bank mentioned.