Canonical Statement
Beneficial ownership and control determinations in crypto contexts MUST be based on corroborated off-chain evidence and risk-based verification, not inferred from on-chain activity patterns alone.
Definition
Within this framework, wallet usage, clustering, and behavioural similarity are investigative indicators that may support hypotheses, while beneficial ownership and control determinations require corroborated evidence of legal and operational control relationships.
Why It Matters
Ownership attribution errors create serious compliance failures. Treating heuristics as determinations can misclassify counterparties and weaken defensibility of high-impact AML/CFT decisions.
Failure Mode if Ignored
Heuristic outputs are presented as ownership facts, multi-party control models are collapsed into single-owner assumptions, and evidence gaps are omitted from decision records.
Scope & Non-Claims
This entry is scoped to regulated banking environments in the EU/UK and operational interpretation for ownership/control handling in crypto contexts.
This entry does not provide legal advice, does not replace legal ownership determination, and requires human validation for final compliance determinations.
Related Concepts
- Proof of wallet control (EU) (methodology)
- Self-hosted wallet risk controls (EU) (regulatory-context)
- Documentation and audit trail (crypto compliance) (EU) (methodology)