Cryptocurrency millionaires face new source of wealth review

Core Points

Henley estimates that there are 135,694 cryptocurrency millionaires worldwide.

The UK Revenue and Customs Service (HMRC) recorded 240 seven-digit cryptocurrency gains cases.

Wallet records cannot prove the legitimacy of the complete source of funds.

The trustee needs to review the ownership, origin and potential risks of the assets.

Tax returns only record part of wealth history.

Henley estimates that there are 135,694 cryptocurrency millionaires around the world.

According to the 2026 Cryptocurrency Report, the number of people holding at least US$1 million worth of cryptocurrency ranges from 132,000 to 154,000, with a median estimate of 135,694. The report also estimates that at least 92,272 people hold Bitcoin exposure worth at least $1 million (including ETF positions that qualify under its methodology). At the higher level, there are about 290 cryptocurrency investors with portfolios exceeding $100 million, and another 23 cryptocurrency billionaires.

These numbers are model estimates and are not verified individual registrations. Henley's methodology combines blockchain data, exchange information, estimates of ETF willingness to hold, and assumptions about wealth distribution. In addition, the methodology of the 2026 version has been adjusted, making the results unsuitable for direct comparison with the estimated 241,700 cryptocurrency millionaires in 2025.

Still, the latest report illustrates how many people today may hold a portfolio large enough to seek services such as trusts, private banking, and estate planning designed specifically for high-net-worth clients.

UK tax data shows concentration of realized gains

Henley's estimates cover cryptocurrency millionaires around the world. Data from the UK Revenue and Customs (HMRC) narrows the focus to UK taxpayers and answers another question: Who reported realized gains at that scale?

During the 2024-25 tax year, HMRC recorded 17,600 UK taxpayers who owned gains from cryptocurrency assets. They reported disposal gains of approximately US$18.7 billion (£ 13.8 billion), with gains of US$1.87 billion (£ 1.38 billion). Among this group, 240 taxpayers reported gains of more than approximately $1.36 million (£ 1 million). Their total earnings were approximately US$972 million (£ 717 million), accounting for approximately 52% of the total cryptocurrency earnings reported by these 17,600 taxpayers.

In other words, approximately 1.4% of filers generate more than half of the total revenue. Transactions of this size could trigger more stringent scrutiny of funding sources when funds are transferred to private banks, placed in trusts or used for major property purchases.

These 240 taxpayers do not represent an estimate of the UK's entire cryptocurrency millionaire population. HMRC calculates disposal proceeds during a single tax year. People holding $1.36 million (£ 1 million) of unsold cryptocurrency will not appear in this group, while people who have achieved seven-figure gains may no longer have the same current portfolio value.

U.S. dollar conversion values are approximate and are calculated using the exchange rate of 1 GBP to US$1.355 at the time of writing.

Seven-digit portfolios face another test

Portfolio valuation establishes the potential value of an asset at a given time. Integrating this wealth into traditional financial structures requires evidence of how it was obtained and who controlled it in the process.

According to the Financial Times, some trust companies refuse to accept wealth derived from cryptocurrencies when certain customers are unable to establish a satisfactory funding history. Concerns cited by lawyers and trustees include missing transaction records, unclear origin of tokens, market volatility and the trustee's long-term liability to beneficiaries.

A public wallet with a huge balance will not solve these problems. It can only prove the presence of assets at a particular address, but cannot prove that the applicant legally owned the address or the funds originally received.

The blockchain records movements, not identities

The public blockchain shows when assets were moved, which addresses were involved, and how much money was transferred. They do not automatically associate those addresses with legal identity, bank accounts or financial reasons for each transaction.

Consider the situation of an investor purchasing Bitcoin through a regulated exchange in 2017, moving it to self-custody, and subsequently using a decentralized exchange, cross-chain bridges, and pledge agreements. If the person ultimately sends the stablecoin to the exchange and withdraws pounds, then the first bank transfer and final withdrawal only provide the beginning and end of history.

Funding source review may also require evidence to connect intermediate wallets, redemption activities and agreement activities to the same owner. Even if all transfers are publicly visible, missing exchange-exported documents or unidentified addresses may still leave blank.

Tax returns and withdrawal records show only certain accounts

Tax returns can prove that income has been declared and may support the acquisition costs used in the calculation. Trustees and banks will still conduct their own reviews, covering original capital, account ownership, counterparties, custody arrangements and exposure to sanctioned or illegal addresses.

Converting cryptocurrencies to pounds, dollars or euros does not change their origin. Exchange receipts confirm the source of the final payment, but if the amount does not match the customer's previously recorded revenue or assets, the bank may trace it further.

Additional issues may arise when transactions involve point-to-point transfers, privacy tools, or informal over-the-counter transactions, as fewer regular records may not identify the counterparty and purpose of the transaction. Such activities do not constitute illegal activities, but holders may need additional documents to explain these transactions.

The six types of records that cryptocurrency holders should keep

The most useful evidence is collected when the activity occurs, especially when exchanges and agreements may not retain downloadable records indefinitely.

• Original source of funds: Maintain bank transfer records and documents showing that funds came from employment, business, investment sales, loans, inheritance, or other identifiable sources.
• Exchange statement: Download deposit, withdrawal, transaction records and associate each exchange account with its verified owner.
• Wallet ownership: Maintain a list of personal addresses and indicate when each wallet was created, funded, migrated or retired. Ownership can be proved by signing messages or verifying transfers; mnemonics and private keys should not be disclosed.
• Exchange and Cross-Chain Activities: Record decentralized transactions, bridging, packaged assets, liquidity positions, and transfers between personal wallets to continue history as asset forms or networks change.
• Tax and Income Records: Retain base cost calculations, valuation sources, tax returns, and documents supporting mining, pledge, airdrop, employment, or business income.
• Inheritance and Custody Planning: Maintain a secure asset list and recovery plan. Preparing to pass Bitcoin to a beneficiary requires proof of ownership and controlled access methods.

Not all trust companies reject cryptocurrency wealth

Existing reports do not provide industry-wide rejection rates. It is based on interviews with lawyers, trustees, and wealth advisers, and therefore cannot support the broader claim that trust companies generally ban cryptocurrency derivatives of wealth.

Some providers may accept cryptocurrencies after intensified scrutiny, while others may accept documented cash gains but are reluctant to directly hold volatile tokens. Even if you have complete funding source documents, you cannot force a trustee to accept assets that exceed their custody capabilities or investment policies.

The narrower issue is that cryptocurrency cases can require years of wallet reconstruction and technical analysis. Some traditional providers may believe that the cost, uncertainty, or fiduciary risks of taking on customers outweigh their value.

Documentation determines where wealth goes

For cryptocurrency holders entering trusts, private banks or estate plans, portfolio value is only the first test. The decisive evidence is a continuous record that connects original capital, verified accounts, personal wallets, taxable transactions, and final income. Without this record, wealth visible on the chain may still be unacceptable to traditional wealth managers.

This document is for reference only and does not constitute legal, tax or financial advice. Requirements vary among agencies and jurisdictions.