What does this research mean for the field?

Non-CARF countries can effectively use group requests to obtain information from foreign Crypto Asset Service Providers (CASPs) to mimic the compliance effects of automatic exchange of information under the OECD's Crypto Asset Reporting Framework (CARF). Novelty: ClaimNovelty.NOVEL_FINDING. Consensus alignment: ConsensusAlignment.ESTABLISHES_NEW_DIRECTION.

What question did this study set out to answer?

This article explores how non-CARF countries can effectively use group requests to gather crypto asset information from foreign services.

February 17, 2026

Exchange of Crypto Information in the ‘Pre-AEOI Phase’: Can Non-CARF Countries Use Group Requests to Obtain Information from Foreign CASPs?

Puntos clave

This article explores how non-CARF countries can effectively use group requests to gather crypto asset information from foreign services.
Examines administrative constraints faced by Global South nations in data collection.
Outlines a methodology leveraging FATF guidelines to identify relevant CASP jurisdictions.
Discusses legal frameworks such as bilateral tax treaties and TIEAs for valid requests.
Presents group requests as a viable alternative to automatic information exchange through CARF.
Identifies conditions where such requests would be considered legally valid under OECD standards.
Provides a checklist for tax authorities to enhance the effectiveness of crypto group requests.

Resumen

The article examines the use of ‘group requests’ by countries to obtain information on crypto assets held by their residents through foreign Crypto Asset Service Providers (CASPs). With information exchanged under the OECD’s Crypto Asset Reporting Framework (CARF) set to commence in 2027, many Global South nations remain uncommitted due to administrative constraint. Many of these countries host significant domestic crypto markets. The author proposes that group requests can serve as a powerful alternative to ‘mimic’ the compliance effects of automatic exchange of information (AEOI) under the CARF. The study outlines a practical methodology for executing these requests. It begins by identifying how countries can overcome the lack of comprehensive macroeconomic data on cross border crypto activities. Countries can use the methodology developed by the Financial Action Task Force (FATF) methodology to identify relevant CASP jurisdictions. It then details the conditions for validity under the OECD’s ‘foreseeable relevance’ standard, ensuring requests are not dismissed as illegal ‘fishing expeditions’. Finally, the article analyses the legal viability of basing such requests on bilateral tax treaties, tax information exchange agreements (TIEAs), and the Multilateral Convention (MAAC). The article concludes by providing a checklist for a successful use by tax authorities of crypto group requests.

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