CARF: Reporting Crypto-Asset Providers, Due Diligence and Transaction Data

Business activity and relevant assets

The infographic tests whether an individual or entity provides, as a business, services effecting exchange transactions for or on behalf of customers, including platforms, intermediaries and counterparties. It then tests relevant crypto-assets, including virtual currencies, security tokens and NFTs capable of payment or investment. CBDCs, specified electronic-money products and crypto-assets incapable of payment/investment are excluded from that definition. A person merely holding an investment is not declared a reporting service provider solely on that fact.

Singapore nexus and equal-tier jurisdictions

The hierarchy runs from tax residence, to Singapore incorporation with legal personality or income-reporting duties, to Singapore management, to regular business location or branch-effected transactions. Reporting providers with highest nexus to Singapore report here. If the same tier applies in multiple CARF partner jurisdictions, report in one and notify the others where not reporting. The infographic points to the IRAS self-review tool to apply the criteria; multiple connections do not automatically require identical reports everywhere.

Users, certification and entity look-through

Users are individual/entity customers for relevant transactions. Collect certification for new users when establishing the relationship and pre-existing users within twelve months after CARF takes effect in Singapore. Valid certification is signed/positively affirmed, dated and includes name, address, residence jurisdictions, TINs and birth date as applicable. Reasonableness requires consistency with AML/KYC and onboarding evidence.

For entity users apply look-through to reportable controlling persons, subject to excluded-person/active-entity categories, and obtain valid reasonable certifications. The infographic expressly says not to effect relevant transactions without valid reasonable certification; merely storing an unsigned form is insufficient.

Changes in circumstances

On a detected change stop relying on the old form and obtain an updated one within ninety days. If not obtained, treat the user as resident in both original indicated jurisdictions and new jurisdictions arising from the change. The ninety-day curing step is separate from the twelve-month pre-existing-user collection period.

All relevant transaction categories

Exchange transactions cover crypto/fiat acquisitions and disposals, and crypto/crypto trades split into disposal of asset A and acquisition of asset B. Transfers include reportable retail payments above US$50,000, other acquisitions such as drops/forks and other disposals. The retail-payment threshold is not a blanket exclusion for every smaller exchange or transfer. Keep transfer direction and type where known.

Every reporting field and format

Report holder/controller name, address, tax jurisdictions, TINs, birth date and controller role for entity users. Identify the reporting provider by name, address and identifying number if any. For each asset type give its full name; fiat trades’ total paid/received, units and transaction count; crypto trades’ aggregate fair value, units and count; retail payments’ fair value, units and count; transfers in/out fair value, units and count by type if known; and unknown-wallet transfers’ aggregate fair value and units.

Use OECD CARF XML. The source states IRAS was working on a simplified form for providers unable to generate XML; it does not establish that form as already available. It also supplies no calendar commencement or annual filing deadline, so this source-specific article retains the relative twelve-month rule rather than inventing dates. The complete checklist, flow and reporting panels are explained with the original PDF retained.