The introduction of Central Bank Digital Currencies (CBDCs), particularly the digital euro, presents significant regulatory challenges, especially regarding Anti-Money Laundering (AML) compliance in the European Union. While European AML laws have adapted to new technologies like crypto-assets, they lack specific provisions for CBDCs. Internationally, policy-makers note similarities between CBDCs and traditional cash, but emphasise that AML risks depend on the CBDC’s design. The EU AML framework, through various directives, follows a risk-based approach, allowing Member States to impose stricter AML measures, including cash transaction limits. The Proposal for the Digital Euro Regulation (DigEuro-Reg) distinguishes between online and offline digital euro uses. Online uses will follow the same AML rules as private electronic payments, while offline uses, being more cash-like, could face stricter AML measures. Despite these provisions, questions remain about the coordination between the AML Regulation and the DigEuro-Reg, particularly regarding the extension of cash limits to the digital euro. These uncertainties suggest the need for further legislative clarification to ensure comprehensive regulation.

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Anti-Money Laundering (AML) Implications of Central Bank Digital Currencies (CBDC)

  • Andrea Minto

摘要

The introduction of Central Bank Digital Currencies (CBDCs), particularly the digital euro, presents significant regulatory challenges, especially regarding Anti-Money Laundering (AML) compliance in the European Union. While European AML laws have adapted to new technologies like crypto-assets, they lack specific provisions for CBDCs. Internationally, policy-makers note similarities between CBDCs and traditional cash, but emphasise that AML risks depend on the CBDC’s design. The EU AML framework, through various directives, follows a risk-based approach, allowing Member States to impose stricter AML measures, including cash transaction limits. The Proposal for the Digital Euro Regulation (DigEuro-Reg) distinguishes between online and offline digital euro uses. Online uses will follow the same AML rules as private electronic payments, while offline uses, being more cash-like, could face stricter AML measures. Despite these provisions, questions remain about the coordination between the AML Regulation and the DigEuro-Reg, particularly regarding the extension of cash limits to the digital euro. These uncertainties suggest the need for further legislative clarification to ensure comprehensive regulation.