Given the very early stages of the Crypto-Asset Reporting Framework (CARF) initiative, EACB comments focus on the draft amendments to the Common Reporting Standard (CRS) for the automatic exchange of financial account information between countries.
The proposed changes to the CRS would affect for instance the appropriate threshold for inclusion of e-money products. These proposed new reporting rules would also introduce changes in the practical functioning of the CRS, including how to report an account that used to have a valid self-certification but then had a change of circumstances; how to report type of account if different types were held under the same account number; whether joint account indicators would apply to trusts; and potential duplicated reporting under the amended CRS and the CARF.
EACB considers that the threshold value only for e-money is not justified and demands that - similar to FATCA - banks be given the option of introducing a threshold for conventional amounts of money in order to establish a level playing field.