Global Coins, Global Crime

The crypto ecosystem enables rapid, borderless value transfer but also facilitates money laundering at an unprecedented scale. In response, the Financial Action Task Force (FATF) has extended its anti-money laundering (AML) framework to virtual assets, bringing virtual asset service providers within regulatory scope, adopting a risk-based approach to regulating crypto activities, and implementing the Travel Rule to enhance transparency in crypto transactions. These efforts are significant, but insufficient. FATF’s framework remains anchored in an intermediary-based model, which fails to capture a growing share of crypto activity occurring outside such intermediaries, including peer-to-peer transactions, decentralized finance, and infrastructure-layer processes that govern how transactions are propagated and executed. As illicit actors migrate toward these channels, the effectiveness of the existing framework correspondingly declines. This Essay argues that AML regulation must move beyond intermediaries and toward infrastructure. Specifically, it proposes a framework that combines a normative reorientation toward financial infrastructure, the embedding of compliance through technical tools and system design, and the use of economic incentives to reinforce compliance outcomes. It further calls for institutional adaptations to recalibrate global AML governance for distributed systems.