Regulating cryptocurrencies in a post-pandemic global economy: A comparative legal analysis of the EU, the US, and Russia

Abstract

This article examines how the design features of retail central bank digital currencies (CBDCs) influence the detection and prevention of crypto-enabled money laundering. Drawing on a comparative analysis of Russia, the European Union, the United States, and Malta, it evaluates the effectiveness of CBDC-integrated anti-money laundering (AML) mechanisms in addressing the three key stages of illicit finance: placement, layering, and integration. Using primary sources, including pilot program data, legislative texts, and policy consultations, alongside secondary academic literature, the Study explores how design elements such as ledger visibility, programmable transaction limits, sanctions screening, and tiered privacy structures can be embedded into CBDC infrastructure. The findings reveal significant variation in enforcement capacity, privacy protection, and governance transparency across jurisdictions, shaped by political economy, legal traditions, and technological architectures. The article argues that while CBDCs offer unprecedented opportunities to embed compliance at the core of payment systems, their legitimacy and adoption depend on the careful balancing of enforcement effectiveness with constitutional safeguards, civil liberties, and public trust. Policy recommendations emphasize jurisdiction-specific typology mapping, programmable safeguards, stakeholder engagement, tiered anonymity, cross-border interoperability, and independent oversight. The analysis concludes that CBDCs, if responsibly designed, can modernize AML frameworks and strengthen financial integrity without undermining democratic principles.