Articles

The Crypto-Asset Reporting Framework (CARF) has been up and running in the UK since 1 January 2026, data collection is already underway in theory, and the first filings by UK Reporting Crypto-Asset Service Providers (RCASPs) are due by 31 May 2027. By Paul Foster Millen (2 October 2026) The dates that matter 1 January 2026 — activation date for due diligence and data collection obligations for UK RCASPs. 31 January 2027 — deadline to register with HMRC's online service and to notify users that their details will be reported via the mandatory one-time customer notification requirement. 1 January to 31...

by Paul Foster Millen and Peter A. Cotorceanu What the FATF’s Offshore VASP Report Means for CARF Compliance: A PracticalAction Plan Part 2 of 2 —first read Part 1: The FATF’s 2026 Offshore VASP Report: Key Findings Every Crypto Business Should Know. The Financial Action Task Force’s 2026 offshore VASP report doesn’t, by itself, create new legal obligations—CARF and the domestic rules implementing CARF do that. But the report significantly raises the supervisory and reputational stakes for any firm operating across borders, and it tells authorities exactly where to look next. This is Part 2 of a two-part series. Part...

by Paul Foster Millen and Peter A. Cotorceanu The FATF’s 2026 Offshore VASP Report: Key Findings EveryCrypto Business Should Know Part 1 of 2 — read Part 2: The FATF’s Offshore VASP Report: What It Means for CARF Compliance .   In March 2026, the Financial Action Task Force (FATF) published Understanding and Mitigating the Risks of Offshore Virtual Asset Service Providers — its most detailed examination to date of VASPs that incorporate in one jurisdiction but serve customers in others. The report is a turning point: it documents how cross-border crypto activity is actually being exploited, identifies structural weaknesses...

Peter A. Cotorceanu and Paul Foster Millen Introduction: CARF Has Arrived in the CaymanIslands The Cayman Islands has long been one of the world’s most important jurisdictions for crypto-asset businesses. It is home to some of the largest exchanges, institutional OTC desks, crypto-focused hedge funds, and an expanding universe of VASP-licensed firms. That status now comes with a significant new compliance obligation. On 27 November 2025, the Cayman Islands gazetted the Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025—commonly referred to as the Cayman CARF Regulations. These regulations took effect on 1 January 2026 and implement the...

by Peter A. Cotorceanu and Paul Foster Millen Introduction:The Cayman CARF Compliance Burden Is Personal For years, regulatory compliance in the Cayman Islands was treated as an institutional problem, something for the fund, the administrator, or the legal team to sort out. That era is over. The Cayman Islands' implementation of the Crypto-Asset Reporting Framework (CARF), developed by the OECD and adopted by the Cayman Islands Tax Information Authority (TIA), has fundamentally changed the stakes for individuals. Under CARF, the regulatory spotlight no longer stops at the entity level. It imposes personal liability squarely on the shoulders of the following...

In this article Paul shares his expectations on the fall-out from CARF, DAC8 and the other incoming crypto-asset reporting regimes. Grounding his views in precedents from recent tax reporting for conventional asset classes, Paul forecasts resistance from the industry and investors, leading to novel enforcement challenges faced by tax authorities when confronted by an agile and motivated target. In closing, Paul sets out a series of enhanced enforcement proposals that tax authorities might adopt to further CARF/DAC8 compliance. Reprinted from Intertax, volume no. 54, issue 3, (2026), pgs. 183-190, with permission of Kluwer Law International. The full contents of the...

Two regimes, one industry, but not the same beast. By Paul Millen The Cayman Islands has long been a pragmatic jurisdiction: it watches carefully, moves deliberately, and gets things right. As the digital asset industry matures and reporting regimes multiply, Cayman-based crypto businesses now face two distinct regulatory frameworks with overlapping but importantly different scopes: the OECD's Crypto-Asset Reporting Framework (CARF) and Cayman's own Virtual Asset (Service Providers) Act (VASP Act). Understanding where they diverge is not just a compliance exercise — it is a prerequisite for building any sensible operational strategy. Two Regimes, One Industry The VASP Act is...

by Peter A. Cotorceanu and Paul Foster Millen The world of crypto is changing fast, and one of the biggest upcoming shifts is due to CARF. If you work in compliance, finance, or the crypto industry, this framework will soon be central to your work. If you are an individual investor or simply crypto-curious, it will affect how your transactions are reported and taxed. So what exactly is CARF? Let’s make it clear. The Basics CARF stands for the Crypto-Asset Reporting Framework. It was developed by the OECD (Organisation for Economic Co-operation and Development) to bring crypto into the same...

by Paul Foster Millen and Peter A. Cotorceanu 1. What is CARF? CARF is short for the Crypto-Asset Reporting Framework, which is contained in a book published by the Organisation for Economic Development and Cooperation (OECD). The most recent version of the book, published in June 2023, is available at http://bit.ly/3TXlY87 The OECD is not a government and can’t pass laws, so the CARF book itself isn’t legally binding on anyone. Instead, the CARF book is a legal framework intended for adoption into countries’ local law. As of 17 June 2025, 52 countries had committed to implement CARF beginning on...

Old Tricks for New Dogs: The OECD’s Cryptoasset Reporting Framework By Paul Foster Millen and Peter A. Cotorceanu, 16 Oct, 2023 This article was originally published in Tax Notes International, October 16, 2023, p. 345 Read the PDF Version Why “old tricks”? Because the OECD’s cryptoasset reporting framework (CARF¹) is based heavily on another automatic exchange of information regime that was published almost a decade ago: the OECD’s common reporting standard (CRS²). Why “new dogs”? Because CARF’s due diligence and reporting obligations fall on a whole new set of players, almost none of whom have had any experience with CRS or...

An easy-to-follow deep-dive audio podcast discussion based on Old Tricks for New Dogs, Part I generated by AI (Google Notebook). Note: Although this is an AI-generated discussion, it is accurate though it sometimes struggles with how to pronounce abbreviations, especially FATCA.  

The OECD’s Cryptoasset Reporting Framework By Peter A. Cotorceanu & Paul Foster Millen, 8 Apr, 2024 This article was originally published in Tax Notes International, April 8, 2024, p. 203     Read the PDF Version Meet the “new dogs”! There are packs of them. As we mentioned in our previous article in this series,¹ “old tricks” refers to the fact that the OECD’s cryptoasset reporting framework (CARF²) is based heavily on the OECD’s common reporting standard (CRS³), which was published almost a decade ago. “New dogs” refers to the fact that CARF’s due diligence and reporting obligations fall on a whole new...

An easy-to-follow deep-dive audio podcast discussion based on Old Tricks for New Dogs, Part II generated by AI (Google Notebook). Note: Although this is an AI-generated discussion, it is accurate. This one—unlike the one for Old Tricks for New Dogs, Part I— does not struggle with how to pronounce abbreviations.  

Identifying Crypto Beneficial Owners By Paul Foster Millen & Peter A. Cotorceanu, 30 Sept, 2024 This article was originally published in  Tax Notes International, September 30, 2024, p. 2153 Read the PDF Version In our last article, you met the “new dogs”; now must be the time for the “old tricks.” As we mentioned in our first article in this series, “old tricks”¹ refers to the fact that the OECD’s cryptoasset reporting framework (CARF²) is based heavily on its own common reporting  standard (CRS³), which was published over a decade ago. “New dogs” refers to the fact that CARF’s due...

An easy-to-follow deep-dive audio podcast discussion based on Old Tricks for New Dogs, Part III generated by AI (Google Notebook). Note: Although this is an AI-generated discussion, it is accurate though, as with the audio podcast version of Part I, the male host sometimes struggles with how to pronounce abbreviations, especially FATCA but also BIAC (the OECD's Business and Industry Advisory Committee).  

CARF's Reporting Obligations By Peter A. Cotorceanu & Paul Foster Millen, 4 Nov, 2024   This article was originally published in  Tax Notes International, November 4, 2024, p. 801 Read the PDF Version All roads lead to Rome. Not literally of course. But all cryptoasset reporting framework (CARF)¹ due diligence obligations do literally lead to one destination: Reporting. In the immediately preceding article in this series,² we covered CARF’s due diligence processes. Due diligence is, of course, a fundamental part of CARF, just as it is of the automatic exchange of information regime on which CARF was modeled (the common...

Your browser doesn’t support the audio element. An easy-to-follow deep-dive audio podcast discussion based on Old Tricks for New Dogs, Part IV generated by AI (Google Notebook). Note: Although this is an AI-generated discussion, it is accurate. This one—-unlike the ones for Old Tricks for New Dogs, Parts I and III— does not struggle with how to pronounce abbreviations.  

CARF Enforcement and Compliance By Paul Foster Millen & Peter A. Cotorceanu, 9 Dec, 2024  This article was originally published in Tax Notes International, December 9, 2024, p. 1517    Read the PDF Version Over the past year, we have introduced the readers of our “Old Tricks for New Dogs” series to the compliance activities (the “old tricks”) that the incoming crypto reporting regime will impose on the regulated parties (the “new dogs”). Throughout our series on the OECD’s incoming cryptoasset reporting framework (CARF),¹ we focused on how the rules that were developed for traditional asset classes under the OECD’s common...

An easy-to-follow deep-dive audio podcast discussion based on Old Tricks for New Dogs, Part V generated by AI (Google Notebook). Note: Although this is an AI-generated discussion, it is accurate though, as with the audio podcast version of Parts I and III, the hosts struggle with how to pronounce "FATCA".