Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
You've received a formal request for Source of Funds documentation on ChangeNOW. ChangeNOW is a non-custodial swap service based in Cayman Islands, regulated under Cayman Islands AML Regulations 2020. Unlike traditional exchanges, ChangeNOW can hold your funds during AML checks even though you never created an account. The service uses AML Bot + Crystal Blockchain for transaction screening. ChangeNOW holds swaps when their AML Bot flags source addresses, requiring KYC before releasing the funds — with no account creation option. 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.
ChangeNOW holds swaps when their AML Bot flags source addresses, requiring KYC before releasing the funds — with no account creation option. ChangeNOW uses a dual-screening system: AML Bot for pre-screening and Crystal Blockchain for deeper analysis. This means even low-risk flags can trigger a hold, because the two systems have different sensitivity levels and either one can block a swap. This background matters because it shapes how ChangeNOW handles compliance — and how we approach resolving your case.
The compliance framework: ChangeNOW operates under Cayman Islands AML Regulations 2020, overseen by Cayman Islands Monetary Authority (CIMA). Their compliance infrastructure uses AML Bot + Crystal Blockchain for blockchain analytics and internal for identity verification. ChangeNOW is known for custody-free swaps with no maximum limits, serving privacy-conscious users wanting instant swaps — and their compliance team is calibrated to flag deviations from typical user behavior in that segment.
What triggers source of funds request on ChangeNOW:
Real case — dual-screening system: A user swapped 2 ETH to BTC on ChangeNOW. AML Bot passed the transaction, but Crystal Blockchain flagged it as 'medium risk' because the source ETH address had interacted with a DeFi protocol that was later associated with a hack. ChangeNOW held the swap output and demanded KYC. The user had never created an account and had no support history. We documented the DeFi interaction as legitimate (the protocol was not hacked at the time of interaction) and ChangeNOW released the funds in 14 days.
What ChangeNOW requires to resolve this: Depending on the trigger, ChangeNOW may ask for government-issued photo ID (verified through internal), 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: ChangeNOW 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 ChangeNOW: ChangeNOW's dual-screening creates ambiguity about which system flagged the transaction. We request the specific risk assessment from both AML Bot and Crystal Blockchain, identify the flagging source, and prepare a rebuttal targeted at that specific system's methodology. Crystal Blockchain's risk scoring is more opaque than Chainalysis, which requires more detailed on-chain evidence.
Source of Funds Request on ChangeNOW — 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 ChangeNOW'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 Cayman Islands Monetary Authority (CIMA) obligations and Cayman Islands AML Regulations 2020. ChangeNOW'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.
ChangeNOW uses two screening systems: AML Bot (pre-screening) and Crystal Blockchain (deeper analysis). AML Bot may pass your transaction, but Crystal Blockchain can still flag it based on different risk criteria. Crystal Blockchain's methodology is less transparent than Chainalysis — they don't publicly disclose their risk scoring parameters. We request the specific risk assessment and prepare a targeted rebuttal.
Yes, under Cayman Islands AML regulations. Even non-custodial services must perform AML checks on flagged transactions. ChangeNOW's position is that holding funds for AML verification is not 'custody' — it's a compliance obligation. While this interpretation is debatable, the practical reality is that your funds are held and you need to provide documentation to get them 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 ChangeNOW requested and your situation. We respond within 6 hours.