Will the U.S. Implement the Crypto-Asset Reporting Framework (CARF) by 2028?

On 28 November 2024, the Organisation for Economic Co-operation and Development (“OECD”) published a list of 63 countries and jurisdictions that have committed to implementing the Crypto-Asset Reporting Framework (“CARF”). Among them, the United States pledged to participate in the first global exchange of crypto-asset information in 2028. But is that for real? After all, the U.S. has never joined the Common Reporting Standard (“CRS”), which facilitates the global exchange of financial asset information.

Of course, this doesn’t mean the U.S. isn’t interested in gathering information about its citizens’ offshore financial assets. The fact is, the U.S. has already achieved this goal through its own legislation, the Foreign Account Tax Compliance Act (“FATCA”), which was introduced much earlier in 2010. FATCA has proven far more effective than CRS in practice. If the U.S. were to join CRS, it would merely mean sharing its data with other countries, offering little to no benefit for itself. However, FATCA only covers financial assets and does not include crypto assets.

If the U.S. were to expand FATCA’s scope to include crypto assets, it would almost certainly face global resistance, and there are numerous technical challenges that make such an approach impractical. That said, given the growing importance of crypto assets in the financial ecosystem, it’s clear that the U.S. needs to address this gap sooner or later.