The Open Legal Challenges of Pursuing AML/CFT Accountability within Privacy-Enhanced IoM Ecosystems

This research paper focuses on the interconnections between traditional and cutting edge technological features of virtual currencies and the EU legal framework to prevent the misuse of the financial system for money laundering and terrorist financing purposes. It highlights a set of Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) challenges brought about in the Internet of Money (IoM) landscape by the double-edged nature of Distributed Ledger Technologies (DLTs) as both transparency and privacy oriented. Special attention is paid to inferences from concepts such as pseudonymity and traceability; this contribution explores these notions by relating them to privacy enhancing mechanisms and blockchain intelligence strategies, while heeding both core elements of the present AML/CFT obliged entities' framework and possible new conceptualizations. Finally, it identifies key controversies and open questions as to the actual feasibility of effectively applying the "active cooperation" AML/CFT approach to the crypto ecosystems.