Most CASPs have existing users who lack complete CARF-required information. Effective remediation strategies are essential for achieving compliance within required timeframes.

Identifying Gaps

Assess current state:

  • Users missing self-certification
  • Missing or invalid TINs
  • Incomplete identity verification
  • Missing entity classification
  • Unidentified controlling persons

Prioritization Framework

Prioritize remediation based on:

  1. Materiality: Transaction volume and value
  2. Risk: Likely reportable jurisdiction residents
  3. Activity: Recently active vs dormant
  4. Gap severity: Missing everything vs minor gaps
Data Analysis First

Before launching remediation, analyze your user base to understand the scale and nature of gaps. This informs resource allocation and timeline planning.

Remediation Approaches

Self-Service

  • Email campaigns with form links
  • In-app prompts and notifications
  • Account restrictions until complete

Assisted

  • Support team outreach
  • Video call assistance
  • Dedicated remediation team

Progressive Enforcement

  • Initial gentle reminders
  • Feature restrictions
  • Withdrawal limits
  • Account suspension
Balance User Experience

Aggressive enforcement can damage user relationships. Start with gentle approaches and escalate gradually, always providing clear paths to compliance.

Resource Planning

Plan for remediation needs:

  • Technology platform capabilities
  • Customer support capacity
  • Legal/compliance oversight
  • Timeline management

Success Metrics

Track remediation progress:

  • Completion rate by user segment
  • Time to completion
  • Response rates by channel
  • Data quality scores

Conclusion

Remediation is a significant undertaking. Start early, prioritize effectively, and allocate adequate resources to meet compliance deadlines.

Automate CARF Compliance

Self-certification, TIN validation, transaction reporting, and XML generation for 76 jurisdictions.

Expert Consulting