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CARF / OTC Desks / Reportable transactions

lili247

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As far as I understand, under CARF, crypto exchanges will essentially have to report most crypto transactions.

How is it going to work with OTC providers?

For example, suppose I use Kraken OTC to swap some BTC for ETH. Instead of depositing the BTC into my Kraken account first, I use their feature where no prior deposit is required. In this case, I simply inform them that I want to execute the trade at a specified rate, transfer the BTC to their address within the next 24 hours, and then they send the ETH to my address.

Would this type of transaction be considered a reportable crypto transaction under CARF?