The article examines the use of ‘group requests’ by
countries to obtain information on crypto assets held by their residents
through foreign Crypto Asset Service Providers (CASPs). With information
exchanged under the OECD’s Crypto Asset Reporting Framework (CARF) set to
commence in 2027, many Global South nations remain uncommitted due to
administrative constraint. Many of these countries host significant domestic
crypto markets. The author proposes that group requests can serve as a powerful
alternative to ‘mimic’ the compliance effects of automatic exchange of
information (AEOI) under the CARF. The study outlines a practical methodology
for executing these requests. It begins by identifying how countries can
overcome the lack of comprehensive macroeconomic data on cross border crypto
activities. Countries can use the methodology developed by the Financial Action
Task Force (FATF) methodology to identify relevant CASP jurisdictions. It then
details the conditions for validity under the OECD’s ‘foreseeable relevance’
standard, ensuring requests are not dismissed as illegal ‘fishing expeditions’.
Finally, the article analyses the legal viability of basing such requests on
bilateral tax treaties, tax information exchange agreements (TIEAs), and the
Multilateral Convention (MAAC). The article concludes by providing a checklist
for a successful use by tax authorities of crypto group requests.