Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
You've seen your account restricted pending source-of-funds verification on Changelly. Changelly is a non-custodial swap service based in Lithuania, regulated under Lithuanian AML Law (transposing EU AMLD6). Unlike traditional exchanges, Changelly can hold your funds during AML checks even though you never created an account. The service uses Chainalysis for transaction screening. Changelly holds swap transactions when Chainalysis flags the source address, requiring AML verification before releasing funds — even though the user never created an account. You receive an email or in-platform notification asking you to prove where your cryptocurrency came from. The request may include demands for bank statements, pay slips, tax returns, business records, sale contracts, mining proof, or inheritance documents — depending on how you acquired your crypto.
Changelly holds swap transactions when Chainalysis flags the source address, requiring AML verification before releasing funds — even though the user never created an account. Changelly operates as a non-custodial swap service based in Lithuania, but can still hold funds during AML checks. The service integrates with major wallets like Trezor and Ledger — which means users can trigger a Changelly AML hold without ever visiting changelly.com directly. This background matters because it shapes how Changelly handles compliance — and how we approach resolving your case.
The compliance framework: Changelly operates under Lithuanian AML Law (transposing EU AMLD6), overseen by Lithuanian Financial Crime Investigation Service (FCIS). Their compliance infrastructure uses Chainalysis for blockchain analytics and Sumsub for identity verification. Changelly is known for non-custodial instant crypto swaps without account requirements, serving users who want to swap crypto without registering on an exchange — and their compliance team is calibrated to flag deviations from typical user behavior in that segment.
What triggers source of funds request on Changelly:
Real case — non-custodial fund holding: A user initiated a BTC-to-ETH swap through his Trezor wallet's built-in exchange feature. The swap was routed through Changelly, which flagged the source address via Chainalysis. The user's 0.5 BTC was held by Changelly — but he had no Changelly account, no support portal access, and only an email address. Changelly demanded full KYC for a swap the user initiated from a hardware wallet. We documented the user's ownership of the Trezor, traced the BTC source to a regulated exchange purchase, and Changelly released the ETH equivalent in 11 days.
What Changelly requires to resolve this: Depending on the trigger, Changelly may ask for government-issued photo ID (verified through Sumsub), proof of address (utility bill or bank statement within 3 months), AML compliance review (exchange statements, bank records, payslips, tax returns, or business documents), detailed transaction explanations with on-chain evidence, and in some cases a video verification interview. The challenge: Changelly rarely tells you which specific trigger caused the source of funds request, so you're guessing at what documentation to provide — and each rejected submission makes the next one harder.
Our approach is specific to Changelly: Changelly's unique challenge is that the user has no account relationship — only a transaction reference number. We prepare documentation that proves wallet ownership (signing a message from the source address), traces the source of funds, and provides KYC through Changelly's Lithuania-based compliance team. The key is proving wallet ownership cryptographically — something Changelly's compliance team accepts but rarely explains to users.
Source of Funds Request on Changelly — our strategy: We prepare a structured Source of Funds package that traces the origin of your funds through every layer: from fiat acquisition to crypto purchase to transfer to the platform. Each step is documented with primary evidence and a cover letter explaining the compliance context.
The submission that matters: Instead of submitting through Changelly's standard support channels (where you'll get automated responses or generic template replies), we prepare a professional legal submission — a structured compliance package with a cover letter from a Swiss law firm citing Lithuanian Financial Crime Investigation Service (FCIS) obligations and Lithuanian AML Law (transposing EU AMLD6). Changelly's compliance team processes legal submissions differently from regular user tickets — they're assigned to senior compliance officers, not support agents, and they bypass the automated response loop that delays most cases by weeks.
When standard compliance isn't enough: Some situations fall outside the normal compliance flow — inherited crypto holdings, accounts registered under another person's name, unprovable source of funds through conventional documentation, or cross-jurisdictional complications where your residence, the exchange's jurisdiction, and the fiat banking path all differ. If that sounds like your case, our complex cases practice handles scenarios that other firms decline.
Further reading: our guide on how to prove source of funds for crypto transactions covers the documentation and legal strategy in more depth.
We trace the origin of your funds through every layer: fiat acquisition → crypto purchase → transfer to {p_name}. {p_name}'s compliance team needs a clear chain — we build it with primary evidence at each step.
We prepare a structured Source of Funds package: bank statements showing fiat origin, exchange purchase records, on-chain transaction history, and a narrative flowchart. Each layer is documented with timestamps and transaction hashes.
We submit the package through {p_name}'s compliance team — not the standard support queue. Our cover letter references {aml_law} and explains the legitimate origin of every transaction in question.
{p_name} accepts the Source of Funds documentation and releases the hold. We confirm your withdrawal and trading functions are fully restored and advise on record-keeping for future {p_name} transactions.
This is the core Changelly problem. You initiated a swap from a wallet (Trezor, Ledger, Exodus) and Changelly flagged the source address. You have no account, no login, no support portal — only a transaction ID and an email. We help by: (1) proving wallet ownership through cryptographic signature, (2) providing source-of-funds documentation, and (3) submitting through Changelly's Lithuanian compliance team with legal cover. Without professional help, Changelly can hold funds indefinitely.
No — but they can hold them indefinitely. Changelly is a Lithuanian entity subject to EU AML regulations, which require source-of-funds verification for flagged transactions. If you refuse KYC, Changelly won't return the funds, but they also can't legally confiscate them. The funds sit in a compliance holding wallet. We help you provide the minimum documentation needed to satisfy their AML obligations and get your funds released.
Acceptable documentation depends on how you acquired your crypto. For earnings: payslips, employment contracts, tax returns. For trading profits: exchange statements showing purchase history. For business income: company registration, audited financials, invoices. For inheritance: death certificate, will, estate distribution documents. For mining: hardware receipts, mining pool records, electricity bills. The compliance team looks for a clear, documented chain from fiat origin to the current crypto balance.
DeFi yields, staking rewards, and liquidity pool returns are legitimate sources of funds — but they're harder to document than exchange purchases. We prepare on-chain evidence: transaction hashes, smart contract interactions, staking pool records, and yield farming positions. The key is showing that your DeFi activity was conducted with funds that themselves have a clear origin.
Yes. Under AML regulations applicable to the platform's jurisdiction, platforms are legally obligated to obtain Source of Funds for high-risk or high-value transactions. Failure to provide adequate documentation gives the platform the right — and in many cases the legal obligation — to close your account and potentially report you to financial authorities.
Tell us what source-of-funds documentation Changelly requested and your situation. We respond within 6 hours.