How to audit your transaction before conversion

1) Introduction — Audit first, convert once

Imagine sailing a superyacht into a narrow harbor at dusk. The vessel is sound, the view extraordinary, but the entrance is shallow and the tide is turning. A pre-conversion audit is your depth sounder: it maps the channel so your capital arrives when and where it needs to, without scraping the bottom on hidden obstacles.

Why this matters now:

• Banks and notaries operate on checklists. In Europe, regulated providers (under MiCA) and travel-rule messaging (originator/beneficiary data) have transformed “what good looks like” from opinion to published standard. Deliver the right payload and you’re waved through; miss a field and your funds are returned or held.
• Transparency has a timetable. DAC8 in the EU and the OECD’s CARF will accelerate platform and cross-border crypto reporting. The dossiers that survive disclosure tomorrow are the ones that pass fast today.
• Luxury supply is tight. In places like Saint-Barthélemy, high-value properties are scarce and decision windows are short. A 48-hour bank hold can be the difference between owning a view and watching someone else move in.

Promise of value: You’ll learn what an institution-grade pre-conversion audit covers, the pitfalls that derail closings, a precise checklist you can run internally, and how SBH Capital Partners designs a Saint-Barth structure—with on-island substance, bank-grade rails, and notary-ready files—so you go from wallet to deed without drama.

Chez SBH Capital Partners, nous aidons nos clients à transformer leurs actifs numériques en patrimoine tangible.

2) What a pre-conversion audit is (and isn’t)

A pre-conversion audit is a forward-looking compliance review that stress-tests every piece of your crypto-to-fiat-to-deed journey before any large transfer occurs. It’s not about policing—you’re building a documentary spine that aligns with bank AML/CTF, travel-rule, MiCA, notarial, and tax-residency expectations.

Scope (the four corners):

1. Identity & Beneficial Ownership (IBO)
   • Who you are (KYC), who benefits (UBO), and who executes (signatories/attorneys).
   • Cross-check passports, proof of address, source of wealth narrative, corporate registries, and consistency across all documents.
2. Asset Provenance & Path (APP)
   • Where coins came from, how they moved, how they will be converted, and how fiat lands.
   • Includes chain analytics (sanctions/mixer screening), exchange/custodian account statements, OTC conversion certificates, and SWIFT proofs of incoming EUR.
3. Counterparty & Corridor (C&C)
   • The exchanges, OTC desks, and payment partners in your flow.
   • For the EU, request MiCA authorization or transitional letters, safeguarding disclosures, and named compliance contacts.
   • Confirm the travel-rule payload can be transmitted, logged, and archived for every leg.
4. Structure, Tax & Notarial (STN)
   • Which entity acquires title (e.g., a Saint-Barth company), where it is tax-resident, and which notary will sign.
   • Prepare a notary-grade Source-of-Funds (SoF) pack and simulate residency and reporting under DAC8/CARF.

What it isn’t: an after-the-fact binder assembled the night before the deed. Audit first means no surprises later. If a bank, notary, or seller can ask for it, pre-build it—and keep it in the appendix.

Metaphor: The asset is your cathedral; the pre-conversion audit is the scaffolding that lets you build safely and beautifully, in public view, without a single cracked stone.

3) The stakes & typical failure modes (the things that cost you the deal)

Even sophisticated buyers stumble on the same traps. Eliminate these before you move a satoshi.

1) The travel-rule gap

• Crypto transfers reach the bank without originator/beneficiary data, or with mismatched info. Result: detect → hold → return.
• Fix: pick rails that embed the travel-rule payload, and archive provider attestations/logs for each transfer.

**2) MiCA status: “we’re reputable” vs. paper **

• A provider “well known in the industry” still needs authorization or transitional eligibility in writing, plus safeguarding details.
• Fix: obtain letters on letterhead, add named compliance contacts for callbacks.

3) Self-hosted wallet opacity

• Banks and notaries ask: can you prove you control the sending address?
• Fix: produce signed-message proofs, multi-sig policies, and chain-analytics showing clean provenance (no sanctioned entities, no tainted mixers).

4) Notary-grade SoF missing

• A bank credit proves little to a notary; French notaries are AML-subject public officers who must verify source of funds and may report to authorities if the file is inconsistent.
• Fix: compile exchange/custodian statements, OTC conversion certificates (pair, size, timestamp, rate, counterparty), SWIFT MTs, and a Funds-Mapping Memo telling a linear story wallet → provider → bank → deed.

5) Residency by label, not by facts

• Claiming “the company is resident in X” while decisions happen elsewhere.
• Fix: in Saint-Barth, anchor registered office, local accounting, local bank account, and on-island gérance. La gérance locale garantit la résidence fiscale de la société et la conformité internationale.

6) DAC8/CARF mismatch risk

• Tomorrow’s reporting will surface inconsistencies you didn’t plan for.
• Fix: store and reconcile transactions in data structures that mirror DAC8/CARF fields (asset type, gross proceeds, wallet IDs where relevant, valuations, timestamps).

7) Tokenization before title

• Issuing tokens or promises on an asset you don’t legally own yet invites legal-finality risk.
• Fix: title first in a substance-rich AHC, tokenization (equity/debt) after under supervised regimes.

8) Time & volatility tax

• Every extra day in review is basis risk, hedge bleed, and seller anxiety.
• Fix: pre-conversion audit compresses settlement time and makes you the certainty premium buyer.

4) Solutions & strategies — The institutional pre-conversion checklist

Use this as your internal playbook. Tick every box before you press “convert.”

A) Transaction Map (1–2 pages)

• Diagram the full path: Wallet(s) → Exchange/OTC → Bank → Local Company → Notary.
• List entities, accounts, signatories, jurisdictions, currencies, contacts.
• Include a timeline with buffers and critical dates (e.g., deed, option expiry).

B) Identity & Beneficial Ownership (IBO)

• KYC pack: passports, proof of address, corporate charts, UBO declarations.
• Source of Wealth narrative (concise, verifiable), backed by liquidity events, trading records, or equity sales.
• Consistency cross-check across all documents (names, dates, addresses, registry numbers).

C) Asset Provenance & Path (APP)

• Chain-analytics: sanctions lists, mixer exposure, clustering, transaction graph.
• Exchange/custodian statements covering acquisition and holding periods.
• OTC conversion certificates (pair, size, timestamp, rate, counterparty).
• SWIFT MTs for incoming EUR into the local company bank account.
• Funds-Mapping Memo: 1–3 pages narrating the linear path in plain English.

D) Counterparty & Corridor (C&C)

• MiCA: authorization or transitional letters, safeguarding representations, physical address, regulator name.
• Travel rule: written confirmation that originator/beneficiary data will accompany every transfer; request log/attestation access.
• Named compliance contact: direct email/phone for bank callbacks.

E) Structure, Tax & Notarial (STN)

• Saint-Barth AHC (SARL/SAS/SCI depending on use), 100% owned by you or a TopCo.
• Substance: registered office, local accounting, local bank, and on-island gérance with board calendar and minutes kept on the island.
• Notary engagement letter and document list early.
• Residency memo evidencing effective management and operations consistent with local tax neutrality.
• DAC8/CARF readiness: store records in aligned data fields; schedule periodic reconciliations.

F) Risk Controls & Timing

• Tranche the conversion (e.g., 20/30/50%) to reduce market impact and operational risk.
• FX/hedge plan for BTC/ETH basis and EUR exposure during the signing window.
• Contingency rails (secondary OTC, backup bank route) pre-approved and documented.

Concrete example:
A founder intends to purchase a €12m villa via a Saint-Barth company. Before conversion, she completes IBO, APP, C&C, and STN. She secures MiCA letters from the OTC, pre-loads travel-rule data, produces chain-analytics and OTC certificates, opens a local bank account, appoints SBH as gérant, and submits a notary pack including a Funds-Mapping Memo. Conversion is split into three tranches, each with separate attestations. Result: no holds, deed signed on time.

Metaphor: This process is a pre-flight checklist. Pilots don’t improvise at V1; they standardize. So should you.

5) SBH Capital Partners — The Saint-Barth corridor, end-to-end

Chez SBH Capital Partners, nous aidons nos clients à transformer leurs actifs numériques en patrimoine tangible. Our role is to convert regulation into momentum, from wallet to deed—quietly and by the book.

We build your substance

• Incorporate a Saint-Barth Asset-Holding Company (AHC) 100% owned by you.
• Set up registered office, local accounting, local bank account.
• Act as gérant for five years, running board calendars, minutes, and decision protocols—on the island. La gérance locale garantit la résidence fiscale de la société et la conformité internationale.

We engineer bank-grade rails

• Select MiCA-aligned exchanges/OTC desks; obtain authorization/transitional letters and safeguarding notes.
• Embed the travel-rule payload for every transfer; archive logs and attestations.

We assemble the notary-grade dossier

• Build chain analytics, collect exchange/custodian statements, obtain OTC certificates, and capture SWIFT proofs into the local account.
• Draft the Funds-Mapping Memo in the notary’s language—linear, verifiable, and complete.

We future-proof your records

• Align documentation with DAC8/CARF fields and schedule reconciliations so what is reported matches your books.
• Coordinate shareholder-level advice (treaties, CFC, anti-abuse) to avoid double taxation or mis-residency claims.

We keep lifestyle and compliance aligned

• Usage policies, rental options, and asset governance that protect both enjoyment and audit-readiness.

Le modèle fiscal de Saint-Barthélemy permet une neutralité légale unique au monde. Ce type de montage n’est pas une évasion fiscale, mais une optimisation encadrée par le droit français. Our job is to evidence that neutrality through facts—not slogans.

6) Conclusion — Audit is the new alpha

A pre-conversion audit isn’t bureaucracy; it’s basis-point protection. It cuts settlement time, prevents post-conversion holds, and turns opaque provenance into a bankable narrative. When combined with a Saint-Barth structure—on-island gérance, local banking, and French notarial certainty—you don’t just buy a property; you upgrade the quality of your wealth.

If you’re preparing a transaction, start with the checklist above. Or have us run it with you. We’ll map your wallets, assemble the dossier, coordinate providers and the notary, and deliver deed-ready euros on a timeline sellers respect.

Ready to audit before you convert? Let’s build your corridor—quietly, correctly, and by the book.

FAQ — Five detailed questions

1) Which documents do banks and notaries actually expect to see?
Expect a KYC/UBO pack (ID, proof of address, corporate chart), a concise source-of-wealth narrative, exchange/custodian statements showing acquisition and holdings, chain-analytics (sanctions/mixer checks, transaction graph), OTC conversion certificates (pair, size, timestamp, rate, counterparty), and SWIFT MTs showing euros landing in the local company account. For the company, include articles, board minutes, registered office proof, and bank letters. The centerpiece is a Funds-Mapping Memo that makes the story linear.

2) Can I use a self-hosted wallet without scaring my bank?
Yes—with proofs. Provide signed messages from the sending addresses, document key management (e.g., hardware wallet, multi-sig policy), and attach chain-analytics demonstrating clean proven