AML

AML Review After Transfers Between Your Own Wallets: Documenting the Funds Trail

A laptop showing a colorful chart, bank cards and a wallet on a desk
In brief

If an exchange requests the source of funds after transfers between your own wallets, saying ‘this is my money’ does not explain the route. Show how you acquired the particular amount, which addresses it passed through and which deposit brought it onto the platform. Control of an address and the origin of the money are different questions. The Source of Funds guide explains the general approach; exchange account restrictions covers the account issue.

First clarify which link needs explaining

A transfer to your own address changes where the assets are held, but does not explain how you originally acquired them. The exchange may need purchase records, a withdrawal from the previous platform or evidence that you control an intermediate address. Preserve the exact request: the same set of files will not answer all three questions.

Kraken, for example, distinguishes the origin of a particular amount from the accumulation of wealth overall. For funds already deposited, its guidance also provides for evidence of the transfer to the platform. This is an example of one exchange's official requirements; do not apply it to every other exchange without checking.

RequestEvidence that helps answer itWhat it does not establish
Where the assets were acquiredPurchase history and payment evidenceSubsequent transfers between addresses
How the amount reached the depositTXID for each link and withdrawal historyLawful origin of the initial payment
Whether an address belongs to youA verification method agreed with the exchangeWhere the money came from

Educational example: purchase → personal wallet → deposit

The following is a fictional example of the structure, not a client story. A, B and TX-1 stand in for addresses and hashes only in this article. An actual submission needs full values, the network and agreement on which documents establish the account holder's identity.

StageAmount and routeEvidence
Purchase1,000 USDT on platform ATrade export, payment document and evidence of the source of the money
Withdrawal1,000 USDT debited, platform fee of 1 USDT, 999 USDT received at a personal addressA's withdrawal history and TX-1 on the specified network
Holding999 USDT remained at the addressAddress history for the relevant period
Deposit999 USDT from the personal address to exchange BTX-2 and B's deposit entry

The fee in this example is illustrative. If your transaction fee was paid in the network's separate native coin, do not subtract it from USDT. If there were several purchases, show separate rows and the remaining balance; do not force the figures to match by rounding. Align statement and blockchain times to one time zone while preserving the original display.

A concluding paragraph could read: ‘The requested deposit consists of funds from the purchase shown in appendix 1. The withdrawal to my address appears in appendix 2; the subsequent transfer to your platform is in row 4. There were no other incoming transfers during the period under review.’ The last statement is appropriate only after checking the history.

First steps: build a package that preserves the connections

  1. Save the request, response deadline and support case number from the official account interface.
  2. Record the disputed deposit: asset, network, address, amount and TXID.
  3. Work backward to the purchase or other actual receipt of the funds; give each transfer its own row.
  4. Match evidence to each row: a statement, platform export or transaction record.
  5. Explain fees, swaps and transfers of only part of the amount separately.
  6. Check the appendix references and submit the package through an official channel.

Keep original statements and a separate working copy. If the platform allows irrelevant information to be redacted, do not obscure details needed to match the holder, dates and amounts. The AML review documents guide covers the rest of the file package.

How to handle gaps in the history

If you cannot access an old exchange account, say so directly, attach any retained withdrawal email and the public transaction, and request an archive from the platform. A public TXID establishes movement but does not by itself establish whose name the account was registered in. Do not replace a missing statement with a document from a different purchase.

For a bridge transfer or asset swap, add a separate explanation: what was sent, what was received and where the result can be seen. If the connection has not been established, mark the row ‘needs verification’ rather than drawing an uninterrupted trail. Blockchain analytics may help with a complex route.

If the request remains unresolved because amounts cannot be reconciled or a link is missing, prepare the request text, table and list of available documents for an assessment. Do not share seed phrases, private keys or sign-in codes: they are not needed to explain the funds history.

Limitations

Risks and limitations

  • Evidence that you control an address does not replace evidence of the source of the money.
  • Requirements may differ between exchanges and their regional entities.
  • Omitted swaps, fees and time zones can create apparent discrepancies.
  • A prepared package does not guarantee that a restriction will be lifted or establish a review deadline.
Sources

Sources used

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