CARF, MiCa and TFR - International Reporting Obligations by PwC Switzerland

Discover international reporting obligations for crypto assets and services, including CARF, MiCA, and TFR, and learn how to navigate the complexities of regulatory requirements in Switzerland and beyond.

Key takeaways
  • International reporting obligations are required for crypto assets and services, with Switzerland having its own CARF regulation.
  • MICA (Markets in Crypto Assets) applies to services in Switzerland for persons in Switzerland, but not necessarily for services in the EU.
  • TFR (Transfer of Funds Regulation) is another international reporting obligation for Switzerland, requiring reports for crypto transactions.
  • The travel rule is used to identify cryptos, distinguishing between reportable and non-reportable assets.
  • Stablecoins are a type of token with a stable value in relation to a single fiat currency.
  • Crypto asset service providers must follow specific regulations, such as those for custody, brokerage, and trading.
  • EEA (European Economic Area) countries are implementing CARF, with Switzerland not being a member.
  • Switzerland has its own regulations, but CARF is being implemented by other EU countries.
  • There is a requirement to define and report on crypto assets, including exchanges, custody, and trading.
  • Crypto assets are defined as those with a value, paid for with cryptocurrencies.
  • Only certain types of tokens, such as those backed by a single fiat currency or a basket of currencies, are in scope for reporting.
  • CARF and MICA are international reporting obligations, with TFR adding an additional layer of regulatory requirements.
  • Service providers must collect and report information on crypto transactions, with a focus on distinguishing reportable from non-reportable assets.
  • E-money tokens are those backed by a fiat currency, while asset reference tokens are those with a stable value.
  • The FINMA guidelines provide clarification on the implementation of CARF and TFR.
  • Switzerland has announced its intention to implement CARF, but the extent of its implementation is still unclear.