As crypto-assets continue to reshape global finance, they present both opportunities and challenges for financial regulation, particularly in anti-money laundering (AML) and countering the financing of terrorism (CFT) enforcement. While pseudonymity and decentralization have fueled concerns over illicit financial activities, blockchain technology itself offers unprecedented transparency and traceability, challenging the misconception that crypto-assets are inherently unregulated and untraceable.
The Financial Action Task Force (FATF) and international regulators have sought to extend AML/CFT frameworks to virtual asset service providers (VASPs) and even decentralized finance (DeFi) protocols. However, applying traditional compliance measures to DeFi raises critical concerns about privacy, innovation, and feasibility. While FATF and the International Organization of Securities Commissions (IOSCO) advocate for identifying “responsible persons” within DeFi arrangements, the enforcement of AML/CFT regulations in fully decentralized ecosystems remains highly problematic, costly, and potentially detrimental to innovation.
This Article argues that a globally coordinated AML/CFT approach is essential to mitigate illicit risks while preserving the transformative potential of blockchain technology. The most practical and effective approach is to focus regulatory oversight on VASPs, which serve as the primary fiat on/off ramps for crypto-assets, instead of expanding regulatory oversight on DeFi participants. Additionally, regulatory technology (RegTech) advancements—such as blockchain analytics, zero-knowledge proofs (ZKPs), and self-sovereign Identity (SSI)—offer privacy-preserving compliance solutions that could balance financial security and decentralization.
Achieving global harmonization in AML/CFT regulation for crypto-assets requires international cooperation, technological innovation, and regulatory adaptability. By fostering dialogue between policymakers, industry participants, and RegTech firms, a unified regulatory framework can emerge—one that effectively prevents financial crime without stifling technological progress in the evolving crypto-asset ecosystem.

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