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Dominic Volek, CA(SA), FIMC, is Group Head of Private Clients and a Member of the Executive Committee at Henley & Partners.
For thousands of years, storing wealth meant trusting a physical place with a physical address. Even as banking went digital, nothing fundamentally changed; you still needed a residential address and tax identification number just to open an account. Then, in 2009, someone using the pseudonym Satoshi Nakamoto deployed a few thousand lines of code that would render geography optional. Today, using nothing more than 12 memorized words, a person can hold a billion dollars in Bitcoin, accessible from Zurich or Zhengzhou with equal ease.
According to The Crypto Wealth Report 2025, 241,700 individuals now hold over USD 1 million in crypto assets — a 40% surge in just 12 months — with 450 centi-millionaires controlling over USD 100 million each, and 36 crypto billionaires at the apex. This new class of wealth has naturally gravitated towards investment migration programs, seeking stable, progressive jurisdictions that offer both regulatory clarity for digital assets and pathways to residence or citizenship or both.
The rapid rise of this new crypto-wealth class is now compelling governments, tax authorities, and wealth managers to confront an uncomfortable reality: while roughly USD 14.4 trillion worth of wealth crossed national borders in 2024, the entire architecture of modern finance assumes that money has a home address — but cryptocurrency doesn’t. The 145,100 Bitcoin millionaires alone (representing 60% of all crypto millionaires) increasingly pursue investment migration opportunities in jurisdictions like Malta and the UAE — nations that combine sophisticated financial infrastructure with forward-thinking digital asset frameworks. For these investors, alternative residence and citizenship programs offer legal certainty and access to innovation hubs where their crypto wealth can interface productively with traditional banking and investment systems.
Traditional offshore finance, for all its complexity, still operates within a framework of physical jurisdiction. Even the most sophisticated structures — Cayman Islands holding companies, Swiss trusts, Singapore family offices — require registration somewhere, with someone, under some flag. Switzerland remained the world’s preferred choice for offshore wealth storage, managing a combined CHF 2.1 trillion (USD 2.4 trillion) of assets belonging to wealthy foreigners. Yet cryptocurrency negates this requirement.
A Bitcoin wallet exists simultaneously everywhere and nowhere, a Schrödinger’s asset that only materializes into a specific jurisdiction when its owner chooses to convert it to fiat currency or declare it to authorities.
This brings forth a fundamental challenge to how states conceptualize capital. The principle of tax residence, refined over centuries of international agreements, assumes that wealth can be assigned a location based on where its owner resides, works, or incorporates. But what happens when wealth exists in a cryptographic dimension that transcends these categories entirely?
Some investors are experimenting with what might be called sovereign arbitrage, a strategic selection of jurisdictions based on their treatment of digital assets. Portugal’s approach to cryptocurrency taxation, where crypto holders do not pay taxes on crypto-to-crypto sales, and non-fungible crypto assets such as NFTs and long-term holdings over 365 days remain tax-free, exemplifies this competition. El Salvador initially drew global attention by adopting Bitcoin as legal tender, though changes to the law in January saw Bitcoin no longer classified as “currency” but maintained its legal tender status on a voluntary basis. The country also offers a USD 1 million Freedom Visa program, designed to attract high-net-worth investors, including those active in crypto.
Meanwhile, Dubai has been at the vanguard of crypto-friendly legislation, particularly concerning taxes and attracting foreign investments, with its Virtual Assets Regulatory Authority (VARA) offering comprehensive frameworks while maintaining zero percent taxes on capital gains and salary.
This competition is producing fascinating second-order effects. While traditional low-tax jurisdictions built their advantage on banking secrecy and corporate opacity, today’s financial centers compete on regulatory clarity and cryptocurrency-friendly legislation. Estonia, which offers e-residence to anyone globally, also pioneered crypto licensing in Europe. This initiative offers a distinct advantage to international entrepreneurs and Virtual Asset Service Providers. It lets non-residents establish and manage Estonian companies remotely, gaining access to the country’s digital infrastructure, business services, and financial institutions.
The conventional tools of asset protection, from trusts and foundations to holding companies, were designed to create legal distance between an individual and their wealth. Cryptocurrency offers something more radical: provable, mathematical distance. A properly secured Bitcoin wallet, particularly one using multi-signature technology spread across multiple jurisdictions, becomes effectively unseizable.
This capability is reshaping how the globally mobile think about political risk. Across the globe, individuals facing political or economic instability are exploring these tools — sometimes out of necessity, sometimes to evade oversight. For regulators, this blurs the line between legitimate protection and avoidance.
Governments are scrambling to adapt their frameworks to this new reality, producing a patchwork of approaches that range from embrace to prohibition. The stakes could not be higher: 590 million people globally now hold some form of cryptocurrency. The OECD’s Crypto-Asset Reporting Framework, fully launching in 2027, brings amended reporting requirements covering crypto-assets. But even this framework needs exchanges and service providers to cooperate. Yet implementing such frameworks requires cooperation from exchanges and service providers—infrastructure that decentralized protocols and peer-to-peer networks operate without, creating unprecedented regulatory complexity.
The more thoughtful regulators are beginning to recognize that heavy-handed enforcement might well accelerate the very disintermediation they seek to prevent. If declaring cryptocurrency becomes too onerous or punitive, users have unprecedented ability to simply not declare. Unlike traditional assets, which leave paper trails through banks and brokerages, cryptocurrency can be held and transferred through networks that operate indifferent to national boundaries or reporting requirements.
The transformation of cryptocurrency democratizes capabilities once reserved for the ultra-wealthy. The same tools that multi-nationals use to shift profits across borders are now available to anyone with an internet connection and basic technical literacy. This represents both an opportunity for individual empowerment and a challenge to systems of governance premised on the ability to monitor and tax economic activity. As this technology matures and becomes more accessible, we may be witnessing the rise of a ‘digital offshore’ that poses both opportunities and risks: expanding financial inclusion on one hand, while straining long-standing mechanisms of taxation and regulation on the other. Investment migration programs offer crypto investors a bridge between these worlds, providing legitimate pathways to diversify not only their portfolios but also their passports.
Henley & Partners assists international clients in obtaining residence and citizenship under the respective programs. Contact us to arrange an initial private consultation.
