Hong Kong Legislative Council passes Crypto-Asset Reporting Framework Bill / Binance says it will close affected EU accounts by end of 2026 / US Treasury sanctions 8 Canadian over-the-counter dealers
About 12 min · 6 key developments
Hong Kong legislature passes CARF bill, with registration and reporting from 2027 and cross-border exchange from 2028
Hong Kong's Legislative Council passed a bill on November 4 implementing the OECD's Crypto-Asset Reporting Framework (CARF) and the amended Common Reporting Standard (CRS). From 2027, crypto-asset service providers with a reporting nexus to Hong Kong must register with the Inland Revenue Department, collect clients' tax residency status and relevant crypto-asset transaction data, and carry out due diligence and reporting. Hong Kong plans to begin automatic exchange of crypto-asset tax information with partner jurisdictions from 2028; the amended CRS takes effect in 2028, with exchanges of relevant financial account information starting in 2029. The government said exchanges will be conducted on a reciprocal basis with safeguards for confidentiality and security, and that implementation guidance and technical support will be provided to the industry.
Business implications
Once the bill takes effect, crypto-asset service providers within CARF scope will owe registration, client tax-residency identification, due diligence and reporting duties starting in 2027, with cross-border exchange following in 2028; failure to register or report bears directly on their compliance footing for operating in Hong Kong. The amended CRS runs on a separate timetable, effective in 2028 with first exchanges in 2029, so institutions holding traditional financial accounts must prepare against a different schedule. The list of partner jurisdictions and detailed guidance have not yet been published, so firms can begin mapping their ability to collect and retain client tax-residency da
Key points
- Determine whether you are a crypto-asset service provider with a Hong Kong reporting nexus
- Check the 2027 start date for registration and due diligence duties
- Track the partner jurisdiction list and IRD implementation guidance
Binance to close affected EU accounts on 31 December 2026, charging a flat 10 USDC monthly on balances below USD 40,000
Binance plans to close affected EU accounts on 31 December 2026. From 29 November, remaining crypto assets in those accounts are charged monthly at 0.025% of the balance or 10 USDC, whichever is higher; accounts with balances below USD 40,000 pay a flat 10 USDC per month, and where the balance is lower than the monthly fee due, Binance will collect the entire balance. The affected accounts can no longer be topped up but remain able to carry out other operations. Binance is still applying for a MiCA licence in the EU.
Business implications
The parties affected are holders of EU accounts within the closure scope: until closure, their remaining assets are steadily drawn down under the monthly charging rule, and where the balance falls short of the fee, the whole balance is taken, so the net result is asset erosion over time. Because top-ups are blocked, users can only limit the loss by withdrawing or using the operations still available, not by adding funds to cover the monthly fee. Binance is still seeking a MiCA licence, so its EU operating status is not settled, and the closure and charging arrangements are unilateral platform measures rather than a regulatory sanction.
Key points
- Check whether the account falls within the affected EU account scope
- Confirm the charging base and deduction order from 29 November
- Complete asset withdrawal before the 31 December closure
ZachXBT: Canada among the three worst-regulated jurisdictions globally
On 8 November, on-chain investigator ZachXBT said in a Telegram post that Canada is one of the three worst-regulated jurisdictions in the world because its laws lack sufficient legal force, and that related abuse is rampant. He said the U.S. Department of the Treasury sanctioned eight Canadian over-the-counter brokers on 6 November, including Nia Nations (NNCE) and Million Exchange (MillionEx). ZachXBT said that five months earlier he had replied to the Treasury on X urging sanctions on Canadian Iran-facing OTC brokers abused by bad actors, and that the two firms had been used to launder crypto assets tied to recent violent home invasions and extortion cases.
Business implications
The Treasury designations bind the eight named Canadian OTC brokers and their U.S.-nexus assets and counterparties, not the Canadian OTC sector as a whole; listed parties face freezing of U.S.-held assets, and U.S. persons face restrictions on dealing with them. For brokers still converting between fiat and crypto in Canada, screening client source of funds and exposure to Iran-linked or extortion-related money has moved from industry self-discipline to a possible U.S. sanctions exposure. ZachXBT's criticism of Canadian regulatory effectiveness is his own assessment and creates no direct duty for firms operating in Canada, but the sanctions list itself is a compliance fact that can be checke
Key points
- Check whether counterparties appear on the Treasury's 6 November list of eight Canadian OTC brokers
- Review whether client source-of-funds screening covers Iran-linked and extortion or robbery case funds
Lawyer: Does exporting crypto mining machines constitute smuggling?
Lawyer Shao Shiwei argues in an analysis piece that exporting cryptocurrency mining machines does not amount to the crime of smuggling goods prohibited from import or export, because no current rule lists mining machines as prohibited export goods. Article 18 of the Circular Economy Promotion Law (as amended in 2018) bans only the production, import and sale of equipment on the elimination list, and does not cover export; the Yinfa [2026] No. 42 notice bars mining-machine manufacturers from providing domestic sales and similar services, again without addressing export. After searching publicly available customs administrative penalty decisions, the author says the only classifications involving mining machines are prohibited import goods and prohibited import solid waste, all at the import stage, and no decision treats mining machines as prohibited export goods; penalties found under the keywords "mining machine" and "export" mainly concern false declaration and failure to declare health quarantine, which are violations of customs supervision rules. On that basis the author concludes there is no normative basis for applying Article 151(3) of the Criminal Law to mining-machine expor
Business implications
The analysis addresses criminal characterization at the export stage and rests on the text of current provisions and published penalty decisions; it does not alter the prohibited-import position that multiple customs authorities have adopted at the import stage. Mining-machine manufacturers and exporters remain bound by industrial policy on domestic sales and by customs rules on export declaration and health quarantine filing, so the absence of a smuggling offense does not remove declaration duties.
Key points
- Check whether the machines for export fall within the elimination category of the Industrial Structure Adjustment Guidance Catalogue and customs' prohibited-import scope
- Declare product name and use truthfully at export and complete health quarantine filing as required
Analyst Assesses Impact of a Warren-Led Senate Banking Committee on Crypto Legislation and Regulation
Analyst qinbafrank published an assessment of what could follow if anti-crypto Senator Elizabeth Warren became chair of the Senate Banking Committee. Warren has advocated extending anti-money-laundering obligations to wallets, miners and validators, preventing banks from bringing crypto risk into the traditional deposit-and-lending system, and opposing attempts to use tokenization to circumvent securities law. In the analyst's view, legislation that would tighten crypto regulation across the board still faces the Senate's 60-vote filibuster threshold, and even if both chambers passed it, Trump could veto it, so hardline proposals are unlikely to become law directly. Warren could escalate questions about Trump's crypto business into sustained investigations and hold密集 hearings targeting the SEC, the CFTC and crypto firms. Over the next two years the SEC and CFTC chairs will still be Republicans, who can continue advancing crypto policy within existing statutory authority, such as the September exemption for tokenized equity trading and the recent request for comment on a derivatives framework; Warren's oversight cannot automatically invalidate those policies but may slow them or nar
Business implications
This assessment concerns the US Senate Banking Committee's oversight powers and legislative agenda rather than any rule already in force: a committee chair can launch hearings and investigations and slow agency nominations, but tightening legislation must still clear the 60-vote threshold and survive a presidential veto. For firms issuing, trading or custodying assets in the United States, what actually changes obligations is the exemptions and frameworks the SEC and CFTC advance under existing statutory authority; committee pressure mainly shows up as procedural delay and the risk of narrower exemptions. Until those texts are formally issued, firms should not reshape compliance arrangements
Key points
- Track the final text and effective date of the SEC's tokenized equity trading exemption and the derivatives framework request for comment
- Watch whether Senate Banking Committee hearings and investigations target specific business models
- Monitor how SEC and CFTC commissioner nominations move through the committee
Tether to Contribute About $32.1 Million in Juventus Capital Increase, Abstains on Financial Statement Approval
Tether, which holds roughly 11.5% of Juventus, will take part in Exor's capital increase of about $279 million (€250 million) and contribute about $32.1 million (€28.8 million) in proportion to its stake. At the shareholders' meeting on November 3, Tether voted in favour of the capital increase but abstained on all other proposals at the annual general meeting, including approval of annual financial statements showing a loss of about $73.5 million (€66 million), the appointment of board members and a management incentive plan.
Business implications
By subscribing in proportion to its stake, Tether takes on a cash obligation tied directly to its 11.5% holding as a minority shareholder funding Juventus's capital replenishment. For crypto companies considering minority positions in listed European sports clubs, subscribing to a capital increase and voting on governance are separate decisions: backing the raise does not amount to endorsing a loss-making financial statement, board appointments or an incentive plan, and abstention is not a veto. If the size or terms of the raise change, the subscription amount and dilution outcome would need to be recalculated against the final terms.
Key points
- Check the pro-rata subscription terms and payment schedule in the capital increase
- Confirm whether the abstained items affect board seats or governance rights