Articles

by Adam Cotorceanu 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 for offences committed by the...

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...

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 type of global reporting system that already...

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 1 January 2026. Another 17 countries have committed...

The OECD’s Cryptoasset Reporting Framework By Paul Foster Millen and Peter A. Cotorceanu, 16 Oct, 2023 Why "old tricks"? Because the OECD’s cryptoasset reporting framework (CARF) is based heavily on another automatic exchange of information regime that was published almost a decade ago: the OECD’s common reporting standard (CRS). Read The Full Article

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 Meet the “new dogs”! There are packs of them. As we mentioned in our previous article in this series, “old tricks” refers to the fact that the OECD’s cryptoasset reporting framework (CARF) is based heavily on the OECD’s common reporting standard (CRS), which was published almost a decade ago. Read The Full Article

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 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” refers to the fact that the OECD’s cryptoasset reporting framework (CARF) is based heavily on its own common reporting standard (CRS), which was published over a decade ago. Read The Full Article

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 All roads lead to Rome. Not literally of course. But all cryptoasset reporting framework (CARF) due diligence obligations do literally lead to one destination: Reporting. In the immediately preceding article in this series, we covered CARF’s due diligence processes. Read The Full Article

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 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”). Read The Full Article

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".