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Who Is Responsible for Reporting Under CARF?
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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.
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