Is It Possible to Avoid CARF Reporting?

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:

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• RCASP Defined:
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• 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.
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• Entities Typically Considered RCASPs:
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3. Centralized crypto exchanges (with or without custody services)
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7. Crypto brokers and dealers (acting as intermediaries or counterparties)
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11. Token issuers (creating and issuing crypto assets)
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15. Crypto-asset ATM operators
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19. Market makers
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23. Software providers only if they operate an exchange; app developers alone are excluded
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27. Decentralized exchanges (DEXs) where the operator exercises control or governance
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31. DAOs (Decentralized Autonomous Organizations) without legal recognition
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35. Businesses reselling crypto assets to customers
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• Who Is NOT an RCASP:
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• Individuals or entities offering services infrequently or non-commercially
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• Platforms that only list prices or facilitate information without executing transactions
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• Developers or sellers of trading apps or software that are not used to execute transactions
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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.