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Life circumstances change, and your Will may need to be updated. How you do this depends on where the Will is registered:DIFC WillCan be amended at any time for a small fee of AED 575 per amendment.Allows flexibility to adjust assets, beneficiaries, or other clauses without revoking the entire Will.Mainland Courts (ADJD & Dubai Courts)Direct amendments are not allowed.To update, you must revoke the existing Will and register a new Will.It is recommended to include a clause in the new Will stating that all previous Wills are revoked for clarity.Summary: DIFC offers more convenience and flexibility, while mainland courts require full re-registration for any updates.

Preparing a Will in the UAE is a straightforward process, whether you choose DIFC, ADJD, or Dubai Courts. The key is gathering the correct documents before registration. Here’s what you need:1. Identification for All Individuals Named in the WillYou must provide ID for every person mentioned in the Will, including:Emirates IDPassportResidence visaIf someone doesn’t have an Emirates ID, a passport copy is sufficient. All documents must be clear scanned copies with all four corners visible. These can be emailed—no in-person meeting is required at this stage.2. Current Residential AddressThe testator must provide their full residential address in a single line.This appears in the Will and becomes part of the official court record.3. Asset Information (Only If Distribution Is Not Generic)Most people prefer generic distribution, such as:All assets to the spouseIf the spouse has passed, assets shared equally among childrenFor these generic clauses, no asset list is required.However, if certain assets must go to a specific beneficiary, detailed asset information must be provided.Example: If a property should pass directly to a child rather than first to the spouse, full property details are needed so the Will can specify this with backup beneficiaries.4. Remote or In-Person OptionsAll documentation can be submitted by email.Clear scanned copies are sufficient—no physical documents or in-person checks are required during the drafting phase.

A Power of Attorney (POA) is often confused with a Will, but the two serve entirely different purposes.POA vs. WillA POA is valid only during the lifetime of both the person granting it and the person receiving it.If either party passes away, the POA becomes immediately invalid. At that point, the Will takes over for probate and asset distribution.This means a POA cannot be used for post-death matters and does not replace a Will in any way.When a POA Is UsefulIn the UAE, a POA is commonly used when someone is:TravellingHospitalized or unable to moveFacing temporary or permanent mental incapacityNeeding assistance with a specific transaction (e.g., property transfer, business setup, bank matters)Once registered with the court, the appointed representative can act on behalf of the grantor strictly within the powers authorized.

A UAE Will can cover a wide range of assets, giving individuals full control over how their estate is distributed and ensuring a smooth probate process. Wills are typically drafted broadly so that both current and future assets are included without requiring frequent updates.Common Assets Included in a UAE WillIn the UAE, the assets most commonly covered include:Real estate properties – Often the primary asset for expatriates and investors, including freehold and leasehold properties.Bank accounts – Both personal and corporate accounts across any UAE bank.Company shares or business ownership – Including shares in mainland companies, free zone entities, and offshore structures.Investments and securities – Such as brokerage accounts, bonds, mutual funds, and other financial instruments.End-of-service benefits (gratuity) – A significant asset for employees that forms part of the estate upon death.A properly drafted and registered UAE Will ensures that all these assets are transferred according to the testator’s wishes, providing certainty and protection for beneficiaries.

A Power of Attorney (POA) is one of the most useful legal tools in the UAE, but it is often misunderstood. A POA does not replace a Will, and the two documents serve completely different purposes.POA vs. WillA Power of Attorney is valid only during the lifetime of both:the grantor (the person giving authority), andthe attorney/agent (the person receiving authority).If either party dies, the POA becomes automatically void.A Will, on the other hand, takes effect only after death, governing the distribution of assets and guardianship arrangements and guiding the probate process.Key point:A POA cannot be used to distribute assets or manage affairs after death. Only a Will can do that.When a POA Is Useful in the UAEPOAs are widely used by residents and non-residents for situations where someone needs to act on their behalf. Common scenarios include:Travel: Allowing a representative to manage property, banking, or legal matters while abroad.Medical situations: When someone is hospitalized or physically unable to attend appointments or manage affairs.Mental incapacity: A POA can authorize a trusted person to act if the grantor becomes temporarily or permanently incapacitated.Specific transactions: Real estate sales, company setup, bank dealings, vehicle transfers, and court appearances often rely on a POA.Once notarized and registered with the relevant UAE court or notary public, the appointed agent can act strictly within the scope of powers granted.A POA is therefore a living-authority tool, while a Will is a post-death planning tool. Both are essential, but each serves a distinct and non-overlapping role in UAE estate and personal planning.

You can absolutely keep your home-country Will valid while living in the UAE. In fact, many expatriates maintain a foreign Will for overseas assets while using a UAE Will for local property and guardianship. There are two recognized methods to ensure your foreign Will remains legally effective:1. DIFC Will Covering Foreign AssetsA DIFC Will can include assets located outside the UAE, provided the foreign jurisdiction accepts a DIFC-issued probate order. Because the DIFC operates under a common-law framework, it aligns naturally with countries such as:United KingdomUnited StatesSingaporeIndiaAustraliaHow it works:You register a Will in the DIFC that includes foreign assets.When you pass away, DIFC probate is initiated.The DIFC Court issues an execution approval or probate order specific to the foreign jurisdiction.That document is then used to commence local probate in the relevant country.This makes DIFC the most seamless option for individuals with cross-border estates.2. Embassy or Consulate AttestationMany embassies in the UAE allow expatriates to sign and attest a home-country Will before a consular officer.Once attested, the Will is fully valid for use in the home country’s legal system.Examples:Indian nationals typically use IVS Global (outsourced by the Indian Embassy/Consulate) to notarize and register their Wills.Other embassies offer similar attestation services depending on their national procedures.This option is ideal if you prefer to keep your Will strictly governed by your home country’s laws.Key PointBoth approaches ensure that UAE residents can secure their non-UAE assets while living abroad.The choice depends on whether you want a UAE-based Will with international reach (DIFC) or to maintain a locally recognized Will in your home country (embassy attestation).Either way, your foreign assets remain protected and legally transmissible according to your intentions.

The UAE allows a broad range of individuals to register a Will, provided they meet certain basic legal criteria. To register a Will, a person must be:At least 21 years old,Of sound mind, andActing voluntarily and without undue influence.Beyond these core requirements, eligibility depends on residency status and asset location.1. UAE ResidentsAnyone holding a UAE residence visa—regardless of nationality or religion—may register a Will in any of the recognized jurisdictions:ADJD (Abu Dhabi Judicial Department)Dubai CourtsDIFC Wills Service CentreResidents commonly register Wills to cover local real estate, bank accounts, investments, business shares, and guardianship of minor children.2. Non-Residents With UAE AssetsNon-residents who own assets in the UAE—such as property, bank accounts, or investments—may also register a Will.DIFC is the most common choice for non-residents because:The process is entirely online,Wills are drafted and probated in English, andOne Will can cover assets in multiple countries.3. Muslims and Non-MuslimsHistorically, Muslim expats faced restrictions, but since mid-2021, ADJD and Dubai Courts allow Muslim expatriates to register Wills.This is a significant development, as it enables Muslims to opt out of default Sharia inheritance rules.Non-Muslims have always been able to register Wills across all jurisdictions.4. Married Couples and ParentsCouples may register:Mirror Wills (two separate Wills with reciprocal terms), orA joint Will (allowed in DIFC).Parents can also appoint temporary and permanent guardians for children under 21—one of the most important reasons expatriate families register a Will in the UAE.SummaryYou can register a Will in the UAE if you:Are 21+,Have full mental capacity, andEither reside in the UAE or hold assets in the UAE.The system is designed to give both residents and non-residents full control over how their assets and family arrangements are handled, ensuring clarity and protection in a jurisdiction where the default rules may not reflect one’s wishes.

Registering a Will in the UAE is a straightforward process, but several essential requirements must be met. The testator must be at least 21 years old, be of sound mind, and must act voluntarily, free from pressure or undue influence.UAE Wills are typically drafted in broad, comprehensive terms to cover both existing assets and any future assets acquired after the Will is signed. This ensures that newly purchased property, bank accounts, or investments are automatically included without needing frequent amendments.What a Standard UAE Will IncludesA typical Will contains three core components:Executor Clause – appoints the individual(s) responsible for managing the estate.Beneficiary Clause – specifies who will inherit the estate and in what proportions.Guardianship Clause – names permanent and temporary guardians for children under 21.Backup or substitute appointments are normally included to ensure the Will remains valid even if an executor, guardian, or beneficiary passes away before the testator.Confidentiality and RegistrationOnce registered with ADJD, Dubai Courts, or DIFC, the Will becomes a private document, and court records are not publicly accessible.DIFC Wills—while more expensive—offer key advantages:entirely English-language drafting,common-law procedures, anda more streamlined and predictable probate process.

When registering a Will in the UAE, individuals can choose from three primary jurisdictions—ADJD, Dubai Courts, and DIFC. Each offers different advantages in terms of cost, process, language, and flexibility.1. ADJD (Abu Dhabi Judicial Department)Best for: Cost efficiency, full virtual process, expat MuslimsCost: AED 950Process: Fully virtual; no in-person visit requiredLanguage: Bilingual Will (English–Arabic)Probate: Conducted in ArabicPractical note: If the family prefers not to manage the Arabic probate process, a Power of Attorney can be issued to a representative.Special update: Since mid-2021, expat Muslims are allowed to register Wills at ADJD, making it the most popular option in this group.Timing: Quick registration, though appointment availability can involve a 5–6 week wait due to high demand.2. Dubai CourtsBest for: Fastest appointment availability and walk-in registrationCost: AED 2,150 per WillProcess: Very fast; usually completed within two daysLanguage: Bilingual Will (English–Arabic)Probate: Conducted in ArabicKey advantage: Same-week appointments are usually available, unlike ADJD, which may have delays.Use case: Ideal for individuals needing quick registration or facing tight timelines.3. DIFC (Dubai International Financial Centre)Best for: English-only Wills, international assets, and common-law structureCost:AED 10,000 for a single WillAED 15,000 for a mirror Will (couple)(after the current 50% discount)Process: Fully virtual; no in-person attendance neededLanguage: Will and probate entirely in EnglishLegal system: Common-law frameworkInternational capability: Allows inclusion of assets from multiple countriesDIFC can issue an “execution approval” enabling probate in jurisdictions such as India, Singapore, Australia, the UK, and the US.Key advantage: Highest level of flexibility and simplicity for multinational families or globally diversified estates.

When a person passes away in the UAE, the procedure that follows depends heavily on whether a valid Will is in place.With a WillIf a Will exists, the process is significantly simpler and more predictable.The executor submits the Will, the death certificate, identification documents, and proof of assets to the court.After the file is opened and reviewed, the court typically issues the probate order within six to eight weeks.For Wills registered with the DIFC, the entire process can be handled virtually, and the executor may appoint a representative through a Power of Attorney.Once the court order is issued, assets are transferred directly to the named beneficiaries.This route is the fastest, most orderly, and offers the highest degree of certainty for families.Without a WillIf no Will exists, Sharia inheritance rules apply by default, which complicates and lengthens the process.The family must identify all legal heirs under Sharia principles. Priority is given to parents, spouse, and children; in the absence of male heirs in this group, siblings are included.All identification documents must be collected, and an appointment is scheduled with a judge.Two witnesses must testify to confirm the list of heirs.The court then issues a succession certificate, detailing each heir’s share.The heirs must agree either to accept their portion or formally waive it in favor of another family member.Only after this step can asset transfers begin.This process usually takes three to four months, and in some cases may extend to six months.Jurisdiction for Will RegistrationIndividuals with UAE assets or residency may register a Will in any jurisdiction within the UAE, including:DIFCAbu Dhabi Courts (ADJD)Dubai CourtsADGMWithout a Will, the court with authority is determined by either the deceased’s residence visa jurisdiction or the location of the assets.

In the UAE, having a legally registered Will is not optional — it is crucial. Without one, a person’s estate is automatically governed by Sharia inheritance rules, which impose predetermined shares for heirs regardless of the individual’s personal wishes.When someone dies without a Will in the UAE, several complications follow:Sharia rules apply by default, dictating how assets must be divided.Guardianship of minor children is not automatically given to the surviving parent; the court appoints a guardian.Asset transfers become slow and complex, requiring attestations, certified translations, and court approvals.Bank accounts may remain frozen until the legal process is completed.A registered Will solves these issues by allowing you to:Choose who inherits your assets.Appoint guardians for minor children.Specify executors and ensure the estate is managed according to your instructions.Provide your family with a clear, efficient process during an already difficult time.A UAE Will is ultimately about control, protection, and peace of mind — ensuring your wishes are respected and your family is supported.

Custodial institutions and fiduciary structures may both “hold assets,” but legally they are completely different. The distinction comes down to the relationship, the level of discretion, and who is allowed to act on behalf of the owner. Under EU regulations, this difference determines why custodians remain allowed for Russians, while fiduciary services are banned.A Simple Analogy: Safe Deposit Box vs. Personal ChefCustodial Institution = Safe Deposit Box ManagerHolds assets securely.Cannot touch, manage, or move anything without explicit instruction.Their duty is pure safekeeping.Fiduciary Structure = Personal Chef With Your Credit CardAuthorized to make decisions for your benefit.Can buy, sell, and manage assets without constant permission.Their duty is loyalty and prudent management.Custodial Institution vs. Fiduciary Structure1. Core Legal RelationshipCustodian: Principal–Agent or Bailor–Bailee. A contract for safekeeping and execution of instructions.Fiduciary: Fiduciary–Beneficiary. A relationship of trust requiring good faith.2. Key DutyCustodian: Safekeeping and exact execution of instructions.Fiduciary: Loyalty and prudence in managing assets.3. Discretion and ControlCustodian: No discretion. Cannot make independent decisions.Fiduciary: High discretion. Expected to make judgment calls.4. Primary RoleCustodian: Holder of assets; operational, mechanical role.Fiduciary: Manager of assets; judgment and strategy.5. ExamplesCustodian: Banks, brokerages, central securities depositories.Fiduciary: Trusts (trustees), estates (executors), guardianships.6. LiabilityCustodian: Negligence — loss of assets or failure to follow instructions.Fiduciary: Breach of fiduciary duty — conflicts, self-dealing, bad decisions.7. Client RelationshipCustodian: The client owns assets directly and gives instructions.Fiduciary: The fiduciary controls assets; beneficiaries benefit but often do not control.

Top Company (Custodial Institution)The company’s articles and memorandum allow its shares to transfer automatically to designated third parties (typically family members) upon the shareholder’s death.This mechanism does not create a trust, because there is no fiduciary relationship—only a custodial structure.Therefore, it does not fall under EU trust-related sanctions, which target fiduciary and trust-like arrangements.The company’s place of effective management (POEM) is in Svalbard, a CRS non-participating jurisdiction.As a result, the top company is treated as a Non-Reporting Financial Institution (FI) for CRS purposes and has no CRS reporting obligations.Bottom Company (Professionally Managed Investment Entity)Its CRS classification is driven entirely by its activities and professional management, not by the tax residency of its shareholders.Because the bottom company’s portfolio is professionally managed by a bank (a Financial Institution), it is classified as an:Investment Entity (Professionally Managed)This makes it a Financial Institution for CRS purposes, regardless of who owns it.The bottom company has one equity holder: the top company (a non-reporting custodial FI located in Svalbard).Under CRS rules:An equity interest held by a Financial Institution is not a “Financial Account”,unless the entity is an Investment Entity in a non-participating jurisdiction.Here, the shareholder is an FI in a non-participating jurisdiction, but not an Investment Entity.Therefore, the holding is not a reportable account.Conclusion – Why This Structure Breaks the Reporting ChainThe top company is a Non-Reporting FI located in a CRS non-participating jurisdiction (Svalbard).The bottom Investment Entity sees its owner as a Non-Reporting FI.Because of this, the bottom company:Does not look through the top company,Does not identify controlling persons,Does not report the ultimate Russian shareholder under CRS.The Russian resident owner is not reported because the ownership is held through a recognized FI in a CRS-non-participating jurisdiction.No Exchange on Demand (EoD) applies because the Person with Significant Control (PSC) is resident in Svalbard — a territory with no tax information exchange agreements whatsoever due to treaty...

While custodians and fiduciaries are closely related, they serve fundamentally different roles in wealth management and trust structures. Importantly: all fiduciaries are custodians in some sense, but not all custodians are fiduciaries.1. Custodial Institution (“Vault Keeper”)Role: Safeguard and protect client assets.Core Function: Holding assets securely against loss, theft, or error.Key Responsibilities:Physical and electronic safekeeping of assetsSettling trades and processing corporate actions (dividends, stock splits)Providing accurate statements and transaction recordsStandard of Care: High duty of care focused on security and accuracy.Analogy: Like a bank’s safety deposit box—keeps valuables safe, but doesn’t decide what to do with them.2. Fiduciary Service (“Trusted Advisor”)Role: Act in the client’s best interest.Core Function: Provide advice or make decisions for the sole benefit of the client.Key Responsibilities:Actively managing portfoliosExercising discretion over assetsEnsuring decisions align with the client’s objectivesStandard of Care: Fiduciary duty — the highest legal standard, encompassing:Duty of Loyalty: Client’s interests come firstDuty of Care: Prudent, informed decisionsDuty of Good Faith: Honesty and fairnessAnalogy: A financial advisor or trustee who manages your portfolio according to your goals.Custodian vs. Fiduciary – Key DifferenceCustodian: Holds and safeguards assets; client retains decision-making power.Fiduciary: Actively manages assets and makes decisions in the client’s best interest.Overlap:Firms like Fidelity or Vanguard are custodians for client accounts but act as fiduciaries when managing portfolios.A trustee is both a custodian and a fiduciary: safeguarding assets while managing them for beneficiaries’ benefit.Takeaway:Think of custodians as safe hands and fiduciaries as trusted decision-makers. The distinction is crucial for wealth planning, legal compliance, and understanding your protections and responsibilities.

In this episode, we break down the EU’s crackdown on Russian-linked trusts — now widely referred to as “zombie trusts” — following amendments to Article 5m of Council Regulation (EU) 833/2014. These rules have rendered many existing structures legally unserviceable and have effectively shut the door to new trust formation involving Russian nationals or entities.Key Points Covered:1. What Article 5m Now ProhibitsUnder the amended regulation, EU persons and service providers are barred from registering, hosting, or managing trusts where any of the following are involved:A Russian national or Russia residentA Russian legal entityAny entity owned (over 50%) by such personsAny entity controlled by such personsAnyone acting on behalf of the aboveThis covers both natural persons and corporate structures, making the rule extremely broad.2. Ban on Trust ServicesEU persons cannot:Act as trustee, nominee shareholder, director, secretary, or similarRegister a trustProvide a registered office, business address, administrative address, or management servicesFor many existing structures, this has created “zombie trusts” — trusts that still legally exist but cannot be administered or serviced inside the EU.3. What Counts as a “Similar Legal Arrangement”?The EU provides no unified definition, but any structure with:A fiduciary relationshipSeparation of legal vs. beneficial ownership…may fall under the same restriction.Guidance comes from:AML Directive (EU) 2015/849Commission reports on trust-equivalent arrangementsImportantly, Article 5m’s scope is wider than the AML definition — capturing more structures, more situations, and more service providers.4. Practical Effects on Russian ClientsNew trusts cannot be registered.Existing trusts cannot receive ongoing service (trustee, office address, administration).Many trusts are now effectively frozen unless moved outside the EU.Professional trustees in the EU are legally obligated to exit these relationships, often abruptly.5. Why the Term “Zombie Trusts”?These structures:Still exist legallyCannot operateCannot be dissolved or restructured...

In this episode, we explore how wealthy Russians are responding to the tightening global network of financial transparency — particularly the Common Reporting Standard (CRS) and the Automatic Exchange of Information (AEOI). These frameworks have dramatically reduced financial secrecy, forcing individuals to adapt quickly or risk exposure to Russian tax authorities and enforcement actions.Key Discussion Points:Formalizing Emigration:Breaking Russian tax residency is the first line of defense.Steps include spending fewer than 183 days in Russia, proving that one’s “centre of vital interests” (family, home, business) is outside Russia, and — in extreme cases — renouncing citizenship.Failure to formalize emigration leaves individuals subject to Russia’s worldwide taxation rules.Choosing “Safe” Jurisdictions:Individuals are relocating to countries perceived as low-risk or outside the CRS network.Some still pursue “quiet” jurisdictions that are less transparent, though these options increasingly carry higher compliance risks and reputational exposure.Building Complex Asset Structures:Wealth is being shielded through multi-layered arrangements — companies, trusts, and foundations spread across multiple jurisdictions.The goal is to make it difficult for any one country to reconstruct the full picture of ownership or to comply fully with data requests under Exchange on Request (EoR).Asset Diversification:Moving wealth into asset classes not yet fully captured by AEOI or CARF, such as:Real estate (although OECD’s new Framework for AEOI on immovable assets is closing this gap)Art and collectiblesPrecious metalsDigital assets, such as cryptocurrency — though CARF is expanding to cover these as well.Conclusion:For many exiled or internationally mobile Russians, AEOI represents a systemic threat — automatic visibility of their assets to Moscow. Meanwhile, EoR poses an individualized, targeted threat that can be used for political or legal retaliation.Their defensive strategy has become a race: to sever fiscal ties to Russia and restructure wealth before the state weaponizes global transparency tools.Takeaway:The age of anonymous cross-border wealth is ending. Russian nationals — like all global citizens — must adapt their financial strategies to a world where transparency is the rule, not the exception.

We examine why many wealthy Russians are especially worried about global information-exchange regimes. The Common Reporting Standard (AEOI/CRS) and Exchange-on-Request (EoR) create layered visibility that can expose residency, assets, and financial flows — with consequences ranging from tax assessments to targeted investigations. Host countries that once offered anonymity now participate in automatic reporting, and requests from foreign authorities can probe ownership, trusts, and transaction histories. For those with ties to Russia, the combination of CRS reporting and Russia’s own residency rules can create unexpected exposure and legal risk.Key Points Covered:AEOI / CRS “blast radius”: Automatic periodic sharing of account data (balances, interest, dividends, gross sale proceeds) means losing prior anonymity in many host jurisdictions (e.g., UAE, Turkey, Armenia, Georgia, Kazakhstan as they join reporting regimes).Russian residency risk: Russia’s residency tests (183+ days or “center of vital interests”) can result in host-country data being reported back to Russian authorities, potentially triggering tax or regulatory action.Exchange on Request (EoR) “targeted missile”: Narrow, case-specific information requests enable authorities to dig into beneficial ownership, trust records, and detailed transactions — a tool that can be used against high-risk individuals, including dissidents.Practical exposures: AEOI reveals account balances and income; EoR can access detailed ownership and transactional evidence useful for tax audits, currency-control probes, and other enforcement actions.Mitigation needs: Effective responses combine focused tax, legal, and privacy planning—substance, documentation, treaty analysis, and proactive compliance are central to risk management.Why It Matters:For internationally mobile individuals with ties to Russia, the convergence of automatic and request-based information exchange has dramatically reduced secrecy options and increased legal risk. Understanding how AEOI and EoR interact with domestic residency rules is essential for planning, compliance, and risk mitigation.Takeaway:Transparency regimes have enlarged the “blast radius” around cross-border wealth. Anyone with potential exposure should seek specialist tax, legal, and privacy advice immediately — not to evade law, but to align structures with reporting realities and limit unintended consequences.

In this episode, we explore how certain jurisdictions remain outside the reach of CARF (Crypto-Asset Reporting Framework) — and why Svalbard and UK non-resident trusts continue to offer unique confidentiality advantages.Key Insights:Svalbard’s Unique Legal ShieldUnder Article 8 of the 1925 Treaty of Svalbard, no signatory nation may receive tax benefits or preferential treatment related to Svalbard activities.This means Svalbard cannot enter into tax treaties without breaching the principle of equal treatment among its 48 signatories — a list that includes Russia, China, and North Korea.The result: Svalbard sits outside global tax-sharing agreements, including those underpinning CARF and CRS frameworks.The UK’s Non-Resident Trust AdvantageThe United Kingdom will not abolish its non-resident trust structure, a longstanding tool in international tax and estate planning.A non-resident trust is governed by UK law but has trustees based outside the UK.This allows for continued privacy and tax efficiency under UK rules — making such trusts valuable for asset protection and wealth transfer planning, even in an era of global transparency.Why It Matters:While CARF expands global financial reporting, legal structures in Svalbard and the UK illustrate how specific jurisdictions remain beyond its direct reach — offering insights into the future of confidentiality and tax-neutral planning.

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.Key Takeaways:RCASP Defined:A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.Entities Typically Considered RCASPs:Centralized crypto exchanges (with or without custody services)Crypto brokers and dealers (acting as intermediaries or counterparties)Token issuers (creating and issuing crypto assets)Crypto-asset ATM operatorsMarket makersSoftware providers only if they operate an exchange; app developers alone are excludedDecentralized exchanges (DEXs) where the operator exercises control or governanceDAOs (Decentralized Autonomous Organizations) without legal recognitionBusinesses reselling crypto assets to customersWho Is NOT an RCASP:Individuals or entities offering services infrequently or non-commerciallyPlatforms that only list prices or facilitate information without executing transactionsDevelopers or sellers of trading apps or software that are not used to execute transactionsWhy It Matters:CARF holds RCASPs directly responsible for reporting transactions to authorities. Understanding whether you qualify as an RCASP is essential, because misclassification can lead to regulatory scrutiny and penalties.

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.Key Takeaways:RCASP Defined:A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.Entities Typically Considered RCASPs:Centralized crypto exchanges (with or without custody services)Crypto brokers and dealers (acting as intermediaries or counterparties)Token issuers (creating and issuing crypto assets)Crypto-asset ATM operatorsMarket makersSoftware providers only if they operate an exchange; app developers alone are excludedDecentralized exchanges (DEXs) where the operator exercises control or governanceDAOs (Decentralized Autonomous Organizations) without legal recognitionBusinesses reselling crypto assets to customersWho Is NOT an RCASP:Individuals or entities offering services infrequently or non-commerciallyPlatforms that only list prices or facilitate information without executing transactionsDevelopers or sellers of trading apps or software that are not used to execute transactionsWhy It Matters:CARF holds RCASPs directly responsible for reporting transactions to authorities. Understanding whether you qualify as an RCASP is essential, because misclassification can lead to regulatory scrutiny and penalties.