Digital Euro: key regulatory and policy aspects

Anti-Money Laundering Europe (AME) attended the DIGITAL EURO High-Level Conference organised by the European Commission on 7 November, to discuss the legislative framework enabling a digital euro for citizens and businesses. The event was timely, since the European Commission has announced a legislative proposal on a digital euro for early 2023.


The panel “A digital Euro at the service of European citizens” discussed how to reconcile data protection and privacy with anti-money laundering (AML) requirements. The main points discussed were the following:


Mairead McGuinness, European Commissioner for Financial Services, emphasised the need to find a balance between users’ privacy and AML considerations, since the European Commission wants to ensure that all transactions are legitimate. Commissioner McGuiness restated the relevance of ensuring data protection while avoiding anonymity which could benefit criminals. She added that these considerations will be key in the design of the digital euro.


Violaine Clerc, Executive Secretary of Financial Action Task Force (FATF), underlined that anonymity, portability and massive adoption of the digital euro are compelling circumstances for criminals and citizens have to be protected from that. She stressed that regulators and stakeholders tend to see data protection and AML as opposing whereas, instead, they should be seen as complementary. Having said that, technology and innovation can facilitate traceability without putting in danger privacy rights and data should only be accessed by customers and investigating authorities. AML/CFT rules should apply to the digital euro in the same manner they apply to cash and privacy does not mean anonymity, she argued. Finally, Mrs Clerc advocated for a risk-based approach according to which data is collected where illicit activities are more likely to occur.


Monique Goyens, Chair of the European Consumer Organization (BEUC) ,pointed out that EU regulators should follow the same approach as with cash, where for small-value transactions there are not AML considerations. For those payments, data minimisation and purpose limitation principles should apply, Mrs Goyens said.


Wojciech Wiewiórowski, European Data Protection Supervisor, agreed on the importance of applying this approach and noted that not all data is useful for AML purposes.


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