Anonymity-enhancing assets or unattributed transfers are barred outright, or barred for regulated firms.
What OECD CARF actually says
The quiet instrument that will do the most to end pseudonymity at the intermediary layer, and it arrives before the AML rules do. Providers must collect self-certifications of identity and tax residence and report exchanges and transfers, including transfers to unhosted wallets, with no minimum on either. First exchanges begin in 2027 on 2026 data across 46 jurisdictions. The privacy architecture sits in the agreement rather than the reporting: Section 5 subjects exchanged data to confidentiality rules and to personal-data safeguards the sending authority can specify, and Section 7(5) lets a competent authority suspend exchange immediately where those safeguards are breached. Data protection is an enforceable precondition to receiving data, which is more than most AML instruments offer.
The instruments that matter
- Published 10 October 2022, finalised with the amended CRS June 2023
- providers collect self-certifications of identity and tax residence and report exchanges, transfers including to unhosted wallets, and retail payments above USD 50,000
- CARF-MCAA
- earliest signature 21 October 2024, main ceremony 26 November 2024; 56 signatories as of 3 March 2026 against 76 committed jurisdictions
- First exchanges 2027
- 46 jurisdictions exchange in 2027 on 2026 data, 29 in 2028, the United States in 2029
- Amended CRS
- brings e-money providers and central bank digital currencies into the depository account definition
What this means for confidential transactions
Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.
Related entries
- Basel Committee, SCO60Global · Bank capital · the sharpest traceability rule anywhere
- Egmont GroupGlobal · How financial intelligence crosses borders
- FATFGlobal · The source of almost every travel rule on earth
- BIS Innovation HubGlobal · Central bank prototypes that build privacy on purpose
- Convention 108+Global · The only binding international data protection treaty
- Financial Stability BoardGlobal · Financial stability · and explicitly not the privacy body
Compliant by default.
See how selective disclosure satisfies a supervisor without publishing your book to the world.