CRS 2.0 and crypto-asset reporting: scope for LatAm HNWIs in the Gulf

The OECD updated the Common Reporting Standard to include digital assets. 2026-2027 implementation closes the last opacity band.

The CRS upgrade

The OECD published CRS 2.0 and the Crypto-Asset Reporting Framework (CARF) in 2023. More than 60 jurisdictions, including UAE, Switzerland, UK, Spain and Colombia, committed to start automatic exchanges in 2027 on FY2026 data.

What is now reported under CARF

Balances and transactions on centralised exchanges.
Wallets custodied by VASPs (Virtual Asset Service Providers).
Transfers between VASPs above USD 50k threshold.
Full KYC identification of beneficial owner.

What remains out (for now)

Pure self-custody without intermediary VASP.
DeFi without identifiable regulated counterparty.
NFTs (with utility-based exceptions).

UAE: the regulatory adjustment

VARA in Dubai and FSRA in ADGM already issued rules requiring their licensed VASPs to collect and report under CARF from FY2026. The era of "having crypto in Dubai without Bogota knowing" formally ends.

Action for LatAm HNWIs

Inventory and document source of all crypto portfolio before year-end 2025.
Migrate non-reportable funds (if decided) to legitimate self-custody, NOT hidden.
Voluntary reporting in Colombia under foreign asset declaration (form 160), the information will arrive anyway.
Consolidate in a formal structure: Foundation or Trust with transparent wealth declaration.

The message

There are no sustainable opacity strategies. There are tax efficiency strategies with full transparency, which is the only thing that survives the next five years of automatic exchange.