CARF builds on CRS foundations while addressing crypto-specific requirements. Understanding the relationship between these frameworks is essential for compliance planning.
Overview
CRS
Adopted in 2014 for automatic exchange of financial account information between jurisdictions. Over 100 jurisdictions participate.
CARF
Adopted in 2022 specifically for crypto-asset transactions. Designed to complement CRS.
Covered Assets
CRS
- Bank accounts
- Custodial accounts
- Investment entity equity/debt interests
- Cash value insurance contracts
CARF
- Cryptocurrencies
- Stablecoins
- Certain NFTs
- Other crypto-assets
Reporting Entities
CRS
Financial Institutions: banks, custodians, investment entities, insurance companies.
CARF
Crypto-Asset Service Providers: exchanges, brokers, ATM operators, certain wallet providers.
Information Reported
CRS
Account-level: balances, interest, dividends, gross proceeds.
CARF
Transaction-level: aggregated by type, crypto-asset classification, unit counts.
Key Differences
- Reporting granularity: CARF more transaction-focused
- Transfer tracking: CARF covers outbound transfers
- Asset valuation: CARF requires fair market value at transaction time
- Entity focus: Different reporting entity definitions
CARF and CRS work together. Traditional financial accounts fall under CRS while crypto-assets are reported under CARF.
Conclusion
CARF and CRS are complementary. Organizations subject to both should coordinate compliance programs for efficiency.
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