The rise of digital currencies has brought about significant changes in the financial landscape. Digital currencies are forms of money that exist only in electronic form and can be used to facilitate transactions, store value, and perform other functions. Digital currencies can be classified into two main types: cryptocurrencies and Central Bank Digital Currencies (CBDCs).

Cryptocurrencies are decentralized digital currencies that operate on blockchain technology, such as Bitcoin, Ethereum, and Ripple. 

CBDCs are centralized digital currencies that are issued and controlled by the central bank of a country, such as the digital yuan, the e-krona, and the sand dollar.

CBDCs have emerged as a potential solution for governments and central banks to modernize their monetary systems, enhance financial inclusion, improve payment efficiency, and foster innovation. However, as with any financial innovation, it is crucial to consider the regulatory aspects, particularly about Anti-Money Laundering (AML) frameworks. 

AML frameworks are measures enacted to combat illicit financial activities, such as money laundering, terrorist financing, and tax evasion. AML frameworks aim to prevent and detect these activities by imposing obligations on financial institutions and other entities to implement policies and procedures to identify and verify their customers, monitor and report suspicious transactions, and maintain records and documents.

This article aims to delve into the relationship between CBDCs and the AML framework, highlighting the importance of implementing strong AML measures in the context of CBDCs. The article will begin by providing an overview of the concept and features of CBDCs and discussing the potential benefits and challenges of CBDCs for the financial system. 

It will then examine the current state of AML regulations and standards for CBDCs, and analyze the main risks and opportunities of CBDCs for AML purposes. Finally, it will provide recommendations on how to enhance the AML framework for CBDCs and explore the prospects of CBDCs and AML.


Understanding Central Bank Digital Currencies (CBDCs)


I. Definition and features of CBDCs:


CBDCs are a digital form of central bank money that can be used as a means of payment, a unit of account, and a store of value. CBDCs are issued and controlled by the central bank of a country and are backed by the full faith and credit of the government. CBDCs are different from other forms of digital currencies, such as cryptocurrencies or stablecoins, which are decentralized and operate on blockchain technology. 

CBDCs are also different from the existing forms of central bank money, such as cash or reserves, which are either physical or accessible only to a limited number of entities. CBDCs can have various features, depending on the design choices and policy objectives of the central bank. 


What are the Features of CBDCs?


Some of the possible features of CBDCs are:

• Accessibility: CBDCs can be either widely accessible to the general public or restricted to a specific group of users, such as financial institutions or corporations.

• Anonymity: CBDCs can either preserve the anonymity of the users or allow for the identification and verification of the users by the central bank or other authorities.

• Interest-bearing: CBDCs can either bear interest or be non-interest-bearing, depending on the monetary policy stance of the central bank.

• Interoperability: CBDCs can either be interoperable with other forms of money and payment systems or operate as separate and independent systems.

• Technology: CBDCs can either use a centralized or a decentralized ledger technology, or a combination of both, to record and validate transactions.


What are the Potential Benefits of CBDCs?


CBDCs can offer various potential benefits for the financial system, such as:

• Enhancing financial inclusion: CBDCs can provide access to digital money and payment services to the unbanked and underbanked segments of the population, especially in developing countries.

• Improving payment efficiency: CBDCs can reduce the cost, time, and risk of payments, especially cross-border payments, by eliminating intermediaries and frictions.

• Fostering innovation: CBDCs can stimulate the development and adoption of new technologies and business models in the financial sector, such as digital wallets, smart contracts, and programmable money.

• Strengthening monetary sovereignty: CBDCs can reinforce the role and influence of the central bank and the national currency in the domestic and international markets, especially in the face of competition from foreign or private digital currencies.


The Significance of AML Frameworks


I. Overview of Anti-Money Laundering (AML)

AML is the term used to describe the measures enacted to combat illicit financial activities, such as money laundering, terrorist financing, and tax evasion

Money laundering is the process of disguising the illicit origins of funds, making them appear legitimate and clean

Terrorist financing is the provision or collection of funds, by any means, to carry out terrorist acts. 

Tax evasion is the illegal avoidance or reduction of tax liabilities, by concealing or misreporting income or assets.

AML measures aim to prevent and detect these activities by imposing obligations on financial institutions and other entities to implement policies and procedures to:

• Identify and verify their customers, using reliable and independent sources of information, such as identity documents or biometric data.

• Monitor and report suspicious transactions, using various tools and techniques, such as risk indicators, thresholds, rules, or algorithms.

• Maintain records and documents, for a specified period, that can provide evidence and traceability of the transactions and the customers involved.

• Cooperate and coordinate with the relevant authorities, such as the Financial Intelligence Unit (FIU) or the law enforcement agencies, to facilitate the investigation and prosecution of these cases.

AML measures are guided by the international standards set by organizations like the Financial Action Task Force (FATF), which is an intergovernmental body that develops and promotes policies and best practices to combat money laundering and related threats.


II. The role of AML in the digital era: Challenges and Risks for AML Purposes


The rise of digital currencies has brought about new challenges and risks for AML purposes, such as:

• Anonymity: Digital currencies can enable the users to transact anonymously or pseudonymously, without revealing their identity or location, making it difficult to trace and track the funds and the parties involved.

• Decentralization: Digital currencies can operate on decentralized ledger technologies, such as blockchain, which are not controlled or regulated by any central authority, making it challenging to enforce and comply with the AML obligations and standards.

• Cross-border: Digital currencies can facilitate cross-border transactions, without the need for intermediaries or intermediation, making it complex to coordinate and cooperate among different jurisdictions and authorities.

• Innovation: Digital currencies can foster innovation and experimentation in the financial sector, creating new products and services that may not fit into the existing AML frameworks and categories.

Therefore, it is crucial to implement robust AML measures in the context of digital currencies, to address these challenges and risks, and to ensure the integrity and stability of the financial system.

Read our Ultimate Guide to KYC and AML Compliance


III. AML Considerations in CBDC Implementation


• Transaction monitoring and reporting: Transaction monitoring and reporting are essential components of AML frameworks that aim to detect and deter money laundering and terrorist financing activities. Transaction monitoring refers to the process of analyzing the transactions conducted by CBDC users to identify any unusual or suspicious patterns or behaviours that may indicate illicit activities. 

Transaction reporting refers to the obligation of CBDC issuers or intermediaries to report any transactions that they suspect or know to be related to money laundering or terrorist financing to the relevant authorities, such as the FIU or law enforcement agencies

Further reading on AML Compliance Reporting

Transaction monitoring and reporting can help to provide valuable information and evidence for the investigation and prosecution of these cases, as well as to prevent the abuse of CBDCs for criminal purposes.

• Customer due diligence (CDD): CDD is the process of verifying the identity and legitimacy of CBDC users, ensuring compliance with KYC requirements. 

KYC refers to the collection and verification of information about the customers or clients of financial institutions or other entities, such as their name, address, date of birth, and source of funds. 

CDD can help to prevent the use of CBDCs by anonymous or fictitious entities, as well as to establish the relationship and risk profile of the CBDC users. CDD can also help to facilitate the transaction monitoring and reporting processes, by providing a basis for identifying and assessing suspicious activities.

• Enhanced due diligence (EDD): EDD is the process of applying additional measures to CBDC users who pose a higher risk of involvement in money laundering or terrorist financing activities, an example is individuals who come from high-risk regions or who are PEPs (politically exposed persons). 

EDD can involve obtaining more information and documentation, conducting more frequent and in-depth checks and reviews, applying more stringent controls and restrictions, and seeking senior management approval or external consultation. EDD can help to mitigate the risk of facilitating or participating in illicit activities, as well as to comply with the AML regulations and standards.

• Risk assessment and mitigation: Risk assessment and mitigation are the processes of identifying, evaluating, and addressing the potential vulnerabilities and threats that CBDCs may pose for AML purposes. 

Risk assessment involves analyzing the design and features of CBDCs, such as their accessibility, anonymity, interest-bearing, interoperability, and technology, and assessing their impact on the level and nature of money laundering and terrorist financing risks. 

Risk mitigation involves implementing appropriate measures and strategies to reduce or eliminate the identified risks, such as setting limits, imposing conditions, or applying safeguards

Risk assessment and mitigation can help to ensure the security and integrity of CBDCs, as well as to balance the trade-offs between innovation and regulation.

• International cooperation: International cooperation is vital to combat cross-border money laundering and terrorist financing activities involving CBDCs, as these activities may exploit the differences and gaps in the legal and financial systems of different countries. International cooperation can involve the exchange of information and intelligence, the provision of mutual legal assistance, the extradition of suspects or offenders, the confiscation and recovery of assets, and the harmonization and coordination of policies and standards. 

International cooperation can be facilitated by various mechanisms and platforms, such as bilateral or multilateral treaties, conventions, agreements, regional or global networks or organizations, or informal or ad hoc arrangements. International cooperation can help to enhance the effectiveness and efficiency of AML measures, as well as to promote the global adoption and acceptance of CBDCs.

You might interested in AML Screening and Monitoring Requirements 


IV. Best Practices for CBDC Implementation

• Transparency and auditability: Transparency and auditability refer to the design of CBDC systems with features that enable the disclosure and verification of the transactions and the users involved, as well as the regulatory oversight and accountability of the CBDC issuers and intermediaries. Transparency and auditability can help to ensure the compliance and alignment of CBDCs with the AML regulations and standards, as well as to prevent and detect any fraud, corruption, or misuse of CBDCs. 

Transparency and auditability can be achieved by providing access and visibility to the relevant authorities and stakeholders, such as the central bank, the FIU, the law enforcement agencies, the auditors, and the public, to the CBDC transactions and users, as well as by establishing clear and consistent rules and procedures for the issuance and management of CBDCs.

• Technological solutions: Technological solutions refer to the potential use of advanced technologies, such as blockchain and DLT, in enhancing the AML capabilities within CBDC systems. 


Blockchain and DLT are technologies that enable the creation and maintenance of distributed and decentralized ledgers, which are records of transactions that are shared and synchronized among multiple nodes or participants. 


What are the Advantages of Blockchain and DLT for AML purposes?

Blockchain and DLT can offer various advantages for AML purposes, such as:

1. Immutable and tamper-proof: Blockchain and DLT can ensure the immutability and integrity of the CBDC transactions, as they are validated and recorded by a consensus mechanism, and cannot be altered or deleted without leaving a trace.

2. Traceable and transparent: Blockchain and DLT can enable the traceability and transparency of the CBDC transactions, as they are stored and visible on a public or permissioned ledger, and can be linked and tracked across the network.

3. Secure and resilient: Blockchain and DLT can enhance the security and resilience of the CBDC systems, as they are encrypted and distributed among multiple nodes or participants, and can withstand cyberattacks or system failures.

Read Blockchain Technology on AML Compliance

• Capacity building and awareness: Capacity building and awareness refer to the provision of training and resources to the financial institutions, regulators, and law enforcement agencies, to effectively combat financial crimes related to CBDCs. 

Capacity building and awareness can help to improve the knowledge and skills of the relevant actors, such as the CBDC issuers or intermediaries, the Financial Intelligence Unit (FIU), the law enforcement agencies, the judges, and the prosecutors, to understand and address the challenges and risks of CBDCs for AML purposes, as well as to adopt and apply the best practices and standards for CBDC implementation. 

Capacity building and awareness can also help to raise the awareness and understanding of the public and the stakeholders, such as the media, civil society, the private sector, and academia, about the benefits and implications of CBDCs for the financial system and society.


V. Regulatory Challenges and Future Considerations


• Regulatory coordination: One of the main challenges for CBDC implementation is the lack of regulatory coordination and harmonization among different jurisdictions and authorities. As CBDCs can facilitate cross-border transactions and payments, it is important to ensure consistent and coherent AML standards and requirements across countries and regions, to avoid regulatory arbitrage, fragmentation, or duplication. 

Regulatory coordination can involve establishing common rules and principles, sharing best practices and experiences, and creating platforms and mechanisms for dialogue and cooperation. Regulatory coordination can help to enhance the effectiveness and efficiency of AML measures, as well as to promote the global adoption and acceptance of CBDCs.

• Privacy concerns: Another challenge for CBDC implementation is the balance between privacy and AML requirements in CBDC systems. Privacy refers to the right and expectation of CBDC users to protect their data and information from unauthorized access or disclosure. AML requirements refer to the obligations of CBDC issuers or intermediaries to collect, verify, and report the data and information of CBDC users and transactions, to prevent and detect illicit activities. 

Privacy and AML requirements may conflict or compete with each other, as privacy may limit the availability and accessibility of data and information, while AML may require the disclosure and sharing of data and information. Therefore, it is essential to find an optimal balance between privacy and AML requirements, considering the need to protect user data while preventing illicit activities. This can be achieved by adopting a risk-based approach, applying proportionate and differentiated measures, and ensuring data security and protection.

• Technological innovation and adaptation: A final challenge for CBDC implementation is the need for continuous monitoring and adaptation of AML frameworks to keep pace with technological advancements and evolving risks. Technological innovation can create new opportunities and challenges for AML purposes, such as the use of blockchain and DLT, artificial intelligence, and biometrics. 

These technologies can enhance the AML capabilities within CBDC systems, such as improving transaction monitoring and reporting, customer due diligence, and risk assessment and mitigation. However, these technologies can also pose new risks and threats for AML purposes, such as enabling new forms of money laundering and terrorist financing or compromising data security and privacy. Therefore, it is vital to monitor and adapt the AML frameworks to the changing technological landscape, by updating the rules and standards, incorporating the best practices and solutions, and addressing the gaps and weaknesses.


Final Thoughts


As CBDCs gain traction in the financial world, it is crucial to establish a strong relationship between CBDCs and the AML framework. Implementing robust AML measures will not only help combat illicit financial activities but also foster trust and confidence in the use of CBDCs. By addressing the challenges and incorporating best practices, governments, central banks, and regulatory bodies can ensure the successful integration of CBDCs into the financial ecosystem while maintaining the integrity of the financial system.

However, AML frameworks are not enough to prevent and detect illicit financial activities involving CBDCs. Individuals and businesses also have a responsibility to conduct due diligence and verify the identity and legitimacy of their customers, partners, and suppliers. This is where Youverify can help. 

Youverify is a platform that provides digital identity verification and background checks for individuals and businesses in Nigeria and across Africa. Youverify can help you to comply with AML regulations and frameworks, reduce the risk of fraud and money laundering, and enhance your reputation and trustworthiness.

If you want to learn more about how Youverify can help you with your AML needs, please visit our website or contact us. We would love to hear from you and offer you a free demo and consultation.