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27 George Mason Law Review (Forthcoming 2019)


Two phenomena dominate reports about blockchain-based transactions—that they will disrupt and displace legacy banking, securities, and trade intermediaries, and that they present new or greater opportunities for hiding proceeds of crimes or corruption. This essay does not deal with the former topic. Rather, the organizers of the symposium at George Mason University’s Antonin Scalia School of Law asks me to consider the latter question. It proved to be a tough assignment.

This essay looks at the separate questions of (1) the degree to which permission-less blockchain transactions will disrupt current anti-money laundering (AML) regimes and enforcement efforts, and (2) what efforts governments that have agreed to pursue goals of deterrence and detection of money laundering may need to initiate as blockchain-based transactions become more common.


This article was originally presented on May 16, 2019 at the Public Policy Conference on The Future of Financial Regulation sponsored by the Program on Financial Regulation & Technology, Law & Economics Center, George Mason University Antonin Scalia Law School.