Digital Currency Legislation: AML Gaps

The European Union's proposed digital euro involves key challenges, particularly in Anti-Money Laundering (AML) and cybersecurity. The Institute of International Finance (IIF) highlights gaps in these areas that affect commercial banks, the European Central Bank, and FinTechs.

Digital Currency Legislation: AML Gaps
EU Digital Currency Legislation

Concerns in Digital Euro Legislative Package, Says International Financial Group

Cointelegraph Keywords anti-money laundering (AML) Digital Euro

In an insightful analysis, the Institute of International Finance (IIF), a global financial advocacy group based in Washington D.C., has found gaps in the European Commission's proposed legislation on the digital euro. The IIF, representing members from 60 countries, scrutinised seven areas and found six of them only partly addressed. The report indicated that the legislation does not sufficiently cover cost-benefit analysis, financial stability, bank intermediation mechanisms, and economic and liability model challenges. Furthermore, privacy controls, anti-money laundering (AML) and cybersecurity measures are not clearly defined. Interestingly, the IIF also voiced concerns about the potential conflicts of interest for the European Central Bank (ECB) acting as both the regulator and operator of the digital euro. Lastly, the IIF reiterated its stance on interoperability, suggesting it's crucial for the digital euro to operate on platforms where other digital currencies are active, thereby avoiding the creation of parallel systems.





In the rapidly evolving landscape of digital currencies, the European Union (EU) has put forth its proposed digital euro legislation. While this initiative aims to modernize Europe's financial infrastructure, it leaves several questions unanswered, particularly in the areas of Anti-Money Laundering (AML) and cybersecurity. The Institute of International Finance (IIF) recently released an analysis of the proposal, identifying significant gaps that have far-reaching implications for various stakeholders in the financial sector. This article delves into these challenges, providing insights and mitigation strategies for financial institutions.


The digital euro impacts a broad spectrum of financial organizations:


  • Commercial Banks: Could face destabilizing fund flows and must adapt to new AML requirements.

  • European Central Bank (ECB): The potential dual role as both regulator and operator raises questions about conflicts of interest.

  • Payment Service Providers and FinTechs: Need to align their platforms with new AML and cybersecurity guidelines.



AML and Cybersecurity in Digital Currency Legislation


The EU is the primary governing body overseeing this digital currency legislation. However, ambiguities around AML and cybersecurity provisions are a growing concern:


  • The current AML guidelines are not sufficiently detailed, risking non-compliance.

  • Cybersecurity measures, crucial for the safety and credibility of digital currencies, are not adequately outlined.

Mitigation Strategies: AML and Cybersecurity Focus


To navigate the uncertainties of AML and cybersecurity in digital currency legislation, financial institutions should consider the following:


  • Active Participation: Engage in public consultations to clarify AML and cybersecurity guidelines.

  • Internal Audits: Conduct risk assessments focusing on AML compliance and cybersecurity resilience.

  • Operational Reorganisation: For the ECB, consider segregating regulatory and operational roles to minimize conflicts of interest.

Expect a minimum of 6-12 months for legislative revisions if the IIF's recommendations are considered, followed by a grace period for AML and cybersecurity compliance.


The IIF stresses the need for interoperability between the digital euro and other digital currencies. A lack of interoperability could lead to fragmented financial systems, undermining the benefits that digital currencies aim to bring.


In summary, as financial institutions navigate the evolving landscape of digital currency legislation, paying special attention to AML and cybersecurity is vital. The proposed digital euro offers both challenges and opportunities, but a proactive approach to compliance can turn potential pitfalls into avenues for growth.




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International financial group finds gaps in digital euro legislative package
The Institute of International Finance has published a note on the development of legislation to regulate a potential digital euro, which is being developed simultaneously.




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