By Stanley Foodman | CEO, Foodman CPAs & Advisors
The once clear line between traditional finance and digital assets is gone.
With the global adoption of the OECD’s Crypto-Asset Reporting Framework (CARF), we are entering a new regulatory era, one where tax transparency expectations apply equally to crypto and fiat accounts. The introduction of CARF, combined with the rollout of CRS 3.0, marks a pivotal shift for financial institutions worldwide, and especially across Latin America.
This is more than a technical update. It’s a strategic call to action.
A Global Mandate for Digital Transparency
Until recently, crypto assets existed in a regulatory gray zone, recognized by tax authorities as risk but lacking standardized oversight. That ambiguity has ended.
CARF introduces a global, unified approach to crypto reporting. It mandates that financial institutions and service providers, including those facilitating exchange, custody, and wallet services, collect and report detailed information on crypto transactions and beneficial ownership.
Crypto is no longer outside the scope of international tax transparency. It’s now front and center.
Why This Matters for LATAM Institutions
Institutions across Latin America face a unique complex regulatory environment marked by local legal diversity, evolving tax regimes, and fragmented data systems. The convergence of CARF and CRS 3.0 amplifies this challenge.
Financial entities must now comply with overlapping standards for fiat and crypto assets, with increased scrutiny from regulators, correspondent banks, and international partners. The cost of delay or misalignment isn’t just financial, it’s reputational.
Key risk areas include:
- Incomplete capture of wallet ownership and sender/receiver data
- Misaligned AML/KYC and tax due diligence processes
- Gaps in cross-border policy coverage
- Limited interoperability across compliance tools and departments
In short, institutions that continue to treat crypto compliance as a siloed process risk falling behind and potentially losing access to critical global financial networks.
Strategic Priorities for Compliance Readiness
To meet new demands of crypto compliance, institutions must go beyond surface-level solutions. A true response to CARF requires structural alignment, across policy, data, staffing, and governance.
Top compliance priorities should include:
- Integrated Policy Frameworks
Expand your internal policies to treat crypto assets as part of the same risk landscape as traditional holdings. This includes wallet traceability, decentralized exchanges exposure, and automated risk scoring.
- Unified Data Architecture
Break down internal silos. Create a centralized compliance data environment where AML, tax, and digital asset reporting teams can access a consolidated view of client behaviors, across fiat and blockchain transactions.
- Enhanced Client Onboarding & Monitoring
Update onboarding processes to capture crypto wallet IDs, source of funds, blockchain transaction history, and risk triggers. Ongoing monitoring must include both on-chain and off-chain behavior.
- Staff Training & Cross-Functional Collaboration
Equip your teams to understand crypto regulations and compliance risks. Encourage collaboration between compliance officers, IT, legal, and product leads to bridge technical and regulatory knowledge gaps.
- Cross-Border Regulatory Mapping
Align your reporting framework with FATF, CARF, CRS 3.0, and relevant domestic disclosure regimes. For institutions operating in multiple jurisdictionsor serving cross-border clients, a cohesive compliance map is critical.
Compliance Leadership in a Digital Future
The institutions that will thrive in the new era aren’t just adding crypto checkboxes to their CRS tools. They’re embedding digital assets into their entire compliance DNA, governance, strategy, and infrastructure.
At Foodman CPAs & Advisors, we help financial institutions across LATAM anticipate regulatory shifts and build compliance programs that are both robust and forward-looking. From CARF readiness to multi-framework integration, we help you reduce risk, protect reputation, and meet regulatory expectations with confidence. Is your institution ready for CARF and CRS 3.0? Let’s talk about your crypto compliance strategy.
