Compliance Design Options for Offline CBDCs: Balancing Privacy and AML/CFT

Many central banks are researching and piloting digital versions of fiat money, specifically retail Central Bank Digital Currencies (CBDCs). Core to these systems’ design is the ability to perform transactions even without network connectivity. Due to the lack of direct involvement of third parties in these offline transfers, various regulatory requirements that are key in the financial space need to be accommodated. This paper deploys a compliance-by-design approach to evaluate technologies that can balance privacy with anti-money laundering and counterterrorism financing (AML/CFT) measures. It classifies privacy design options and corresponding technical building blocks for offline CBDCs, along with their impact on AML/CFT measures, and outlines commonalities and differences between offline and online solutions. As such, it provides a conceptual framework for further techno-legal assessments and implementations.