Episode 1786
Who Is Responsible for Reporting Under CARF?
Offshore Tax with HTJ.tax · htjtax
November 10, 20253m 33s
Audio is streamed directly from the publisher (episodes.captivate.fm) as published in their RSS feed. Play Podcasts does not host this file. Rights-holders can request removal through the copyright & takedown page.
Show Notes
In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.
Key Takeaways:
- RCASP Defined:
- A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
- Entities Typically Considered RCASPs:
- Centralized crypto exchanges (with or without custody services)
- Crypto brokers and dealers (acting as intermediaries or counterparties)
- Token issuers (creating and issuing crypto assets)
- Crypto-asset ATM operators
- Market makers
- Software providers only if they operate an exchange; app developers alone are excluded
- Decentralized exchanges (DEXs) where the operator exercises control or governance
- DAOs (Decentralized Autonomous Organizations) without legal recognition
- Businesses reselling crypto assets to customers
- Who Is NOT an RCASP:
- Individuals or entities offering services infrequently or non-commercially
- Platforms that only list prices or facilitate information without executing transactions
- Developers or sellers of trading apps or software that are not used to execute transactions
Why It Matters:
CARF holds RCASPs directly responsible for reporting transactions to authorities. Understanding whether you qualify as an RCASP is essential, because misclassification can lead to regulatory scrutiny and penalties.