Handling Pre-Existing User Accounts

Users who were onboarded before CARF implementation present unique compliance challenges. CASPs must obtain self-certifications and validate TINs for these existing users within specified timeframes.

What Are Pre-Existing Accounts?

Pre-existing accounts are those opened before CARF rules took effect in the jurisdiction. For EU DAC8, data collection begins January 1, 2026, with first reports due in 2027.

Remediation Requirements

For pre-existing accounts, CASPs must:

• Obtain self-certification
• Validate TINs
• Resolve any inconsistencies
• Complete within remediation period (typically 12-24 months)

Prioritization Strategy

Given large user bases, prioritize remediation:

1. High-value accounts: Largest transaction volumes first
2. Active users: Users who transact regularly
3. High-risk jurisdictions: Users in key reportable jurisdictions
4. Incomplete data: Accounts missing key information
5. Remaining accounts: Lower-priority users

Communication Approaches

Initial Outreach

• Email explaining new requirements
• In-app notifications
• Link to self-certification form
• Clear deadline communication

Follow-Up

• Reminder emails at intervals
• SMS notifications
• App-based prompts
• Escalating urgency messaging

Handling Non-Responsive Users

For users who don't respond:

• Implement progressive restrictions
• Limit withdrawals
• Require certification before new transactions
• Consider account suspension as last resort
• Document all outreach attempts

Conclusion

Pre-existing account remediation is resource-intensive but essential. Start early, prioritize effectively, and implement progressive measures for non-responsive users.