Crypto Millionaires Hit a Wall With Offshore Trustees

Offshore trust companies are turning away crypto millionaires who want to park digital-asset wealth in traditional estate structures, even as HMRC data published on 27 August shows 240 UK taxpayers declared capital gains exceeding £1 million each from crypto in the 2024-25 tax year. The trustees’ reluctance, reported by the Financial Times, centres on an inability to verify how the money was made.

240 Millionaires, £717 Million, and a Paper Trail Problem

The 240 individuals accounted for £717 million in declared crypto gains, roughly 52% of the £1.38 billion reported by all 17,600 UK taxpayers who filed crypto capital gains that year.Total disposal proceeds reached £13.8 billion. HMRC said it had generated an additional £168 million in capital gains tax through compliance and education efforts in 2024-25, and the agency is now implementing the Cryptoasset Reporting Framework (CARF) from January 2026, with service-provider data expected to flow from 2027.James Murray MP, Financial Secretary to the Treasury, said in the HMRC release that "taxes are due on cryptoasset gains just like any other gains, and we want to make sure people making gains from crypto know about what taxes they owe."

Why Trustees Are Saying No

The trust industry’s hesitation is not about the size of crypto fortunes but about the documentation behind them. Charlie Tee, a partner at law firm Withers, told the Financial Times that only a small number of trustees he had encountered were comfortable holding cryptocurrency. Ronald Graham, a partner at Winston Taylor, and Claire Randall, a partner at Farrer & Co, echoed similar concerns about the difficulty of satisfying source-of-wealth requirements.The core issue is fiduciary, and a trustee accepting assets into a structure assumes long-term responsibility for custody, valuation, and legal compliance. Wallet addresses prove that assets exist, but not that the applicant owns them or earned the underlying capital legitimately. Exchange exports are often incomplete, and cross-chain swaps can break an audit trail entirely.Andrew Horbury, chief executive of UAE-based Cavenwell Group, told the FT that some firms have declined clients outright, citing missing transaction records, uncertain token provenance, and the trustee’s long-term responsibility to beneficiaries. The collapse of FTX in 2022 reinforced that caution: a trustee holding client crypto on a failed exchange faces personal liability questions that traditional asset custody does not raise.

A Compliance Gap at the Worst Moment

The Henley & Partners Crypto Wealth Report 2026 estimates 135,694 crypto millionaires globally in 2026, and demand for offshore structures is rising as jurisdictions tighten reporting rules. HMRC has sent 81,000 warning letters to crypto investors suspected of underpaying tax, and providers who fail CARF reporting face penalties of up to £300 per user.The gap leaves crypto millionaires in a structural bind: they have liquid, taxable wealth and a growing need for succession planning, but the professionals who typically handle that work are not yet willing to take it on. Until trustees can verify provenance as confidently as they can for a share portfolio, much of crypto’s newest wealth will sit outside the estate-planning system it is trying to enter.