A Philippine legal and compliance guide to what it means, who can issue it, how it’s obtained, what it’s worth, and what it cannot prove.
1) The core idea: a “wallet” doesn’t have a legal record—people and entities do
In Philippine practice, a request to “certify no pending cases for a cryptocurrency wallet” is usually shorthand for one (or more) of these:
- No pending criminal/civil/administrative cases against the wallet owner (individual or company);
- No derogatory records that would trigger enhanced due diligence (EDD) with a bank, exchange, remittance company, or other regulated entity;
- No pending regulatory enforcement actions affecting the owner (e.g., related to securities, consumer protection, fraud, AML);
- An affidavit/attestation by the owner that they are not involved in pending proceedings, sometimes supported by clearances.
A crypto wallet address is not a public registry entry in the Philippines. There is no single government office that can look at a wallet address and issue a universal “no pending cases” certificate about it. What can be certified is the legal standing of the person or juridical entity that controls the wallet—plus, in some cases, the status of a specific case docket in a specific court or office.
2) Common scenarios where this request appears
A. Bank or exchange onboarding / large transactions
Banks, BSP-supervised institutions, and many crypto service providers may request documents beyond standard KYC for higher-risk customers or transactions. A “no pending cases” document may be asked for:
- high-value deposits/withdrawals;
- corporate accounts with complex ownership;
- foreign counterparties that demand additional comfort;
- customers tagged as high-risk under internal policies.
B. Business partnerships and vendor due diligence
A counterparty might require “no pending case” evidence before:
- integrating a payment gateway;
- appointing a local agent/representative;
- forming a joint venture;
- placing funds under escrow or custody arrangements.
C. Court-related purposes
Sometimes the request is tied to:
- estate settlement involving digital assets;
- injunction/receivership risks in a dispute;
- proving that an address is controlled by someone not subject to restraining orders (rare, and often misunderstood).
D. Immigration, employment, licensing, and procurement spillover
Some institutions apply “no pending case” requirements as a general integrity screening measure even if crypto is incidental.
3) What “pending case” means in Philippine context
“Pending case” depends on the forum:
- Criminal: cases under the courts (e.g., theft, estafa, cybercrime) or at the prosecutor level (complaints undergoing preliminary investigation).
- Civil: money claims, contracts, specific performance, damages—usually in regular courts.
- Administrative: cases before bodies like the Ombudsman, CSC, PRC, or other regulators (or internal administrative proceedings, depending on context).
- Regulatory / enforcement: actions, show cause orders, or proceedings by agencies (varies widely).
There is no single clearance that covers all of these comprehensively across the entire country.
4) The documents people use in practice (and what each actually proves)
A. NBI Clearance (individual)
What it is: A nationwide clearance commonly used to check for criminal records and “hits” (name matches). What it proves: That, based on NBI’s database and matching process, there is no record or derogatory match (or that a match has been resolved). Limitations:
- It is not a universal certification of “no pending cases” in all courts and all offices.
- “Hits” can occur due to similar names; resolution may take time.
- It does not function as an all-in-one civil/administrative case clearance.
Best use: baseline integrity screening for individuals.
B. Police / Barangay clearances
What they are: Local clearances. What they prove: Generally, that there is no known derogatory record in the local jurisdiction issuing it. Limitations: Highly local; weak for nationwide comfort.
Best use: supplemental only.
C. Court “Certificate of No Pending Case” (per court / per jurisdiction)
Courts may issue certifications through the Office of the Clerk of Court (OCC) stating that, upon checking their records, a named person or entity has no pending case in that court (or within that station).
What it proves: Limited to that court’s records (and sometimes limited to certain case types depending on their process). Limitations:
- Not nationwide unless you obtain it from multiple courts.
- Not a substitute for prosecutor-level checks.
- Does not automatically cover administrative proceedings.
Best use: when a counterparty wants comfort tied to a specific locality (e.g., where the business operates or where disputes are likely filed).
D. Prosecutor’s Office certification (rare and inconsistent)
Some parties attempt to obtain certifications related to pending complaints at the prosecutor level. Availability and form vary; many offices do not provide blanket certifications.
Best use: case-specific verification rather than general clearance.
E. Ombudsman / CSC / PRC / other administrative clearances (context-specific)
For government-related roles or regulated professions, administrative bodies may issue status certifications depending on rules and internal practice.
Best use: when the role or transaction specifically implicates government service/professional regulation.
F. SEC documents (for corporations and partnerships)
For juridical entities, due diligence often relies on:
- SEC Registration Certificate and current profile
- General Information Sheet (GIS)
- Secretary’s Certificate / Board Resolution
- Good standing / compliance-related certifications where available under SEC processes
- disclosures regarding pending cases where required in forms/filings
What it proves: Existence, authority, structure, and certain compliance facts. Limitations: SEC documents alone do not guarantee “no pending cases” in courts or other agencies.
Best use: corporate identity + authority + ownership transparency, paired with individual clearances for directors/beneficial owners.
G. Affidavit of No Pending Case (very common)
This is often the actual deliverable requested, supported by NBI and other documents.
What it proves: The affiant’s sworn statement—useful contractually and for risk allocation. Limitations: It is only as reliable as the affiant; false statements can create legal exposure but do not prevent hidden cases.
Best use: when the counterparty needs a formal representation with consequences for misrepresentation.
5) Crypto-specific reality check: custodial vs non-custodial wallets
Non-custodial wallets (self-hosted addresses)
If the wallet is self-hosted (e.g., controlled by a private key held by the user), there is no central operator who can certify anything about case status connected to that address. Any “certification” is really about:
- the identity of the controller/owner; and
- evidence that the owner controls the address (proof-of-control).
Custodial wallets (exchange accounts / hosted wallets)
If the “wallet” is an exchange account:
- The exchange can issue account statements, transaction logs, or certificates of account ownership (depending on policy), but
- It will not usually issue a government-style “no pending cases” certificate—because it’s not the authority on court records.
In both cases, the practical approach is to certify the owner’s standing and the owner-address link.
6) A workable Philippine approach that actually satisfies most counterparties
When someone asks for “Certifying No Pending Cases for a Cryptocurrency Wallet,” the most defensible package typically contains:
Identity + ownership
- Government IDs (individual) or SEC documents (company)
- For companies: proof of beneficial ownership, board authority to transact
Clearances
- NBI Clearance for key individuals (owner, directors, signatories, beneficial owners)
- Optional: court certifications for relevant jurisdictions (where the business is located, where counterparties are, or where litigation would likely be filed)
Affidavit of No Pending Case
- A sworn statement by the owner (and sometimes key officers for companies) that they have no pending criminal/civil/administrative cases that would materially affect the transaction or indicate wrongdoing.
Proof of wallet control (crypto-specific)
- A signed message from the wallet address (for chains that support message signing), or
- A “micro-transaction challenge” (send a small amount to a specified address and return it / send a specific unique amount), with screenshots + explorer links, or
- A notarized technical affidavit describing how control was verified (used in higher-stakes matters)
Source of funds / source of wealth narrative (when the real concern is AML)
- Bank statements, payslips, audited FS, tax documents, sale agreements, etc., depending on risk
This bundle aligns better with what regulated entities actually need: who, authority, integrity screening, control of the address, and AML comfort.
7) Legal and regulatory touchpoints relevant in the Philippines
A. Anti-Money Laundering framework (AMLA) and compliance expectations
Philippine AML rules drive the “why” behind these requests. Covered persons (e.g., banks and many financial institutions) must conduct customer due diligence, risk-based monitoring, and enhanced due diligence for higher-risk situations. In practice, that’s why counterparties sometimes ask for more than IDs—like affidavits and clearances.
Key point: “No pending cases” is not a universal AML requirement, but it can be a risk-based control used by institutions.
B. BSP regulation of virtual asset service providers (VASPs)
BSP-supervised VASPs (and other BSP-regulated entities dealing with virtual assets) generally apply:
- KYC,
- transaction monitoring,
- governance and “fit and proper” expectations for key persons,
- risk management controls.
So for corporate crypto operations, requests for clearances often target directors, officers, signatories, and beneficial owners, not the wallet address itself.
C. Data Privacy Act (RA 10173) implications
Collecting and sharing “no pending case” documents is handling sensitive personal data. Practical implications:
- Have a lawful basis and a clear purpose.
- Limit collection to what is necessary.
- Protect documents (access control, encryption, retention limits).
- If you’re an organization, ensure proper privacy notices and data processing agreements where needed.
D. Cybercrime / evidence considerations
If the certification is used to support a dispute, remember:
- Blockchain data is public, but linking an address to a person is evidentiary work.
- Keep clean records: notarized affidavits, screenshots with timestamps, transaction hashes, and consistent identity documents can matter.
8) What a “Certificate of No Pending Case” can realistically say (and what it cannot)
It can say (properly):
- “Based on the records of this office/court as of date, the named person/entity has no pending case in this jurisdiction/office.”
It cannot honestly say (universally):
- “No pending cases anywhere in the Philippines,” unless it’s backed by a comprehensive nationwide system (which is not how these certifications function in practice).
So, if you see a draft certificate that claims universal coverage without explaining scope, treat it as a red flag.
9) Common pitfalls and red flags
- Certifying a wallet address as if it were a legal person (category error).
- Overbroad statements (“no cases nationwide, criminal/civil/admin”) without specifying sources checked.
- Relying only on barangay/police clearance for high-stakes transactions.
- No proof-of-control of the wallet address (the biggest crypto-specific gap).
- Name mismatch issues (different spelling, middle names, married names) causing false “hits” or unreliable checks.
- Counterparty asks for impossible documents (e.g., a government “wallet clearance”)—this often signals they don’t know the local system.
10) Practical drafting: sample affidavit language (adapt to the situation)
Below is a general structure parties commonly use. It should be tailored to the exact purpose and risk:
Affidavit of No Pending Case and Wallet Control (outline)
Identity of affiant (and capacity, if corporate officer)
Statement of ownership/control of the wallet address(es) or custodial account identifiers
Statement that, as of a specific date:
- no pending criminal cases filed in court to the affiant’s knowledge, and/or
- no pending civil actions that would materially affect the transaction, and/or
- no pending administrative/regulatory proceedings, as applicable
Undertaking to notify the counterparty if any case is filed/served within a defined period
Attachments:
- NBI clearance(s)
- SEC documents (if company)
- proof-of-control method and artifacts (signed message / challenge transaction references)
Notarization
Important drafting tip: Use scope and knowledge qualifiers carefully. Many counterparties accept:
- “to the best of my knowledge” for broad statements, and
- absolute statements only when tied to a specific database or office (e.g., “as per attached NBI clearance”).
11) If you’re the requesting party: how to ask without demanding the impossible
A clean request might look like:
- “Provide NBI clearance for the signatory/beneficial owner(s), plus an affidavit of no pending criminal cases and no pending regulatory actions related to fraud/financial crimes, and proof-of-control of the wallet address.”
If you also need locality comfort:
- “Provide a certificate of no pending case from the RTC/MeTC where your principal office is located (or where you reside), covering records as of a specific date.”
12) Bottom line
There is no single Philippine government-issued “no pending cases” certification for a crypto wallet address.
What’s doable (and commonly accepted) is a combination of:
- (a) clearances for the person/entity,
- (b) a scoped court/office certification where relevant,
- (c) a sworn affidavit allocating responsibility for truthfulness, and
- (d) proof-of-control connecting the owner to the wallet address.
If you tell me your use case (bank onboarding, partner due diligence, court matter, corporate licensing, estate settlement, etc.), I can give you a best-fit document set and a tighter affidavit outline that matches that purpose.