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What if the most valuable risk-control tool in your portfolio wasn’t an option collar or an exotics hedge, but a documentation habit? In 2025, the investors who sail smoothly through bank onboarding, notarial escrow, and cross-border audits share one trait: they assume disclosure. Between the OECD’s automatic exchange of information, the EU’s crypto reporting and “travel rule”, and tightening beneficial-ownership regimes, the global direction of travel is clear: privacy now rides inside transparency, not outside it. Your structure wins when your story (who, what, where, why) is coherent—and when your evidence can be read by a regulator as easily as by a relationship manager. OECD
This article is your field guide to the rules that matter before you deploy capital across borders or convert digital assets into tangible wealth. We’ll translate alphabet soup—CRS, CARF, DAC8, MiCA, TFR, FATF R.24/25, CTA/BOI—into an investor’s checklist. We’ll also show how to design a bankable dossier: identity and beneficial ownership (BO), source of funds/wealth (SoF/SoW), crypto proofs, governance minutes, and decision trails that meet French notarial standards and EU expectations. Think of this as the pre-flight your team should run before take-off.
Two important caveats. First, automatic information exchange isn’t niche—it’s the default. The Common Reporting Standard (CRS) requires financial institutions in participating jurisdictions to collect and transmit account data annually; expect it to flow between the places you live, bank, or invest. Second, crypto has grown up: the Crypto-Asset Reporting Framework (CARF) and the EU’s DAC8 extend that automatic exchange to crypto transactions and holdings, while MiCA licensing and the EU Transfer of Funds Regulation (TFR) make identity data travel with transfers. If you plan as though all of this is already live for you, you’ll be pleasantly unsurprised later. eur-lex.europa.eu+4OECD+4OECD+4
The upside? When you embrace transparency by design, banks and notaries stop asking if they can trust your flows and start asking when they can close your deal. Chez SBH Capital Partners, nous aidons nos clients à transformer leurs actifs numériques en patrimoine tangible. That journey is smoother when the paperwork is as polished as the pitch.
One-line promise: if you learn the transparency rules and build your evidence before you wire, you’ll trade friction for confidence—from term sheet to title deed.
Let’s decode the core frameworks investors meet most often.
CRS (Common Reporting Standard, OECD).
CRS is the backbone of automatic exchange of financial account information: banks, custodians, certain investment entities, and insurers collect standardized data (balance, interest, dividends, proceeds) and report it annually to local authorities, which then send it to your residence jurisdiction. If you use entities or trusts, expect look-through rules to identify beneficial owners. Treat CRS as always on—assume your home authority sees your offshore accounts. OECD
CARF (Crypto-Asset Reporting Framework, OECD) and the EU’s DAC8.
CARF is CRS for crypto: it creates automatic reporting of crypto-asset transactions and holdings via obliged intermediaries (centralized exchanges, brokers/custodians, certain service providers). The OECD released schema/guidance so authorities can ingest and exchange crypto data; the Global Forum adopted implementation guidance in late 2024. In the EU, DAC8 integrates crypto into the bloc’s administrative cooperation, requiring EU-facing platforms to identify customers and report transactions to tax authorities. Translation: on-exchange and custodial activity becomes tax-visible across borders. OECD+2OECD+2
MiCA (EU Markets in Crypto-Assets) and TFR (EU Transfer of Funds Regulation).
MiCA sets a licensing and conduct regime for CASPs (crypto-asset service providers): authorization, prudential and conduct standards, white-paper rules, and supervision. If your ramp is MiCA-compliant, banks are likelier to engage. The TFR extends the classic “travel rule” to crypto transfers: originator/beneficiary information must accompany the transfer, enabling screening and sanctions/AML checks—think of it as SWIFT-style metadata for blockchain payments. When these two regimes meet, identity data is attached to movement, and the movement is handled by licensed actors. eur-lex.europa.eu+1
FATF Beneficial Ownership (Recommendations 24 & 25).
The FATF standards require countries to ensure adequate, accurate, up-to-date beneficial-ownership data for legal persons (R.24) and legal arrangements such as trusts (R.25). Expect expanding BO registers, stronger verification, and tighter access for authorities and obliged entities (banks, notaries, lawyers). For you, this means organograms, control tests, and attestations will be scrutinized—not guessed. fatf-gafi.org+2fatf-gafi.org+2
United States — Corporate Transparency Act (CTA) / FinCEN BOI.
The U.S. is rolling out (and litigating) beneficial-ownership reporting to FinCEN. As of March 26, 2025, FinCEN indicates that BOI reporting requirements are in effect again, with a new deadline of March 21, 2025, for most companies—but nuances and exemptions apply, and the legal landscape has been fluid. If you form or use U.S. entities, check FinCEN’s current BOI page before funding or filing. Assume obligations unless counsel confirms otherwise. FinCEN.gov
Metaphor: Think of global transparency like airport security. You still fly first class, but you remove the laptop and declare your liquids. The trick is to pack your bag so the scan is boring.
Friction happens at the intersection of rules and records. Here are the common choke points—and the antidotes.
1) “Who are you, really?”
Expect enhanced KYC beyond passports: proof of address, video KYC, and source-of-wealth narratives. If your wealth includes crypto, banks now ask for wallet provenance, transaction histories, and exchange/custodian attestations. Under CRS/CARF/DAC8, they know authorities will receive data; they want your file to match what a tax office will see. Align IDs and names exactly across exchanges, banks, and notarial deeds. OECD+2OECD+2
2) “Who owns this, actually?”
BO scrutiny is rising thanks to FATF R.24/25 and national rules (EU BO registers; U.S. BOI). If your organogram needs a legend, simplify it. Provide control tests (shareholding, voting, appointment rights), trust deeds where relevant, and evidence that BO data is current and accurate. Stale charts cause onboarding purgatory. fatf-gafi.org
3) “Where did the money come from?”
SoF/SoW is where files often fail. For fiat, be ready with bank statements, deal documents, and sale agreements. For crypto, save on-chain evidence (Tx hashes, wallet statements), platform ledgers, custodian letters, and conversion certificates when you ramp to fiat. Under TFR, identity metadata travels with transfers; under MiCA, providers are licensed—use those rails so your audit trail is bank-grade. eur-lex.europa.eu+1
4) “Which law applies to this gain?”
CRS/CARF/DAC8 are reporting frameworks, not tax rules—but they alert authorities where to look. The real tax result depends on taxpayer identity, residency, source, and local law. Get a jurisdiction matrix (where you live, where the entity resides, where the asset sits, where the intermediary is regulated). This matrix informs withholding, reporting, and return-filing duties.
5) “Can the notary and bank close?”
French notarial practice is meticulous from compromis to acte authentique. Files sail through when identity, BO, SoF/SoW, and crypto evidence align and when funds move via regulated, traceable rails. In our experience, the delta between delay and decree is a well-indexed dossier.
Snapshot checklist:
• CRS/CARF/DAC8 aware: plan for automatic reports.
• BO clean: organogram + control evidence compliant with FATF R.24/25. fatf-gafi.org
• MiCA/TFR rails: licensed providers; identity data travels with transfers. eur-lex.europa.eu+1
• Jurisdiction matrix: residency, source, reporting obligations mapped in advance.
Analogy: A cross-border deal is a symphony; the transparency regimes are the conductor’s cues. Miss one, and the brass section comes in early—the audience notices.
Think of this section as a repeatable SOP your team can implement for any cross-border allocation or crypto-to-real-asset move.
A) Build the “four-stack” file from day one
Discretion, compliance, and excellence in Saint-Barthélemy.
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