Digital Currencies Digital Policy
Issue Brief September 28, 2022

Privacy in cross-border digital currency: A transatlantic approach

By Giulia Fanti and Nadia Pocher

As a growing number of countries explore Central Bank Digital Currencies (CBDCs) for the domestic context, multi-country cross-border CBDCs pilots are also proliferating. Cross-border CBDCs could make cross-border payments faster, cheaper, and simpler. However, for any cross-border CBDC to unlock these benefits and be widely adopted, it must address key concerns, chief among them risks around privacy and transparency of data.

This article illustrates how various technical design choices can affect the privacy and transparency of cross-border CBDCs. For instance, architectural choices about the structure of a cross-border CBDC and representational choices about how transactions are encoded in the underlying software can have far-reaching implications for privacy and transparency—both in a domestic context and for cross-border transactions. Many of the cross-border CBDC pilot studies to date have (understandably) adopted the technical designs provided by enterprise distributed ledger platforms. However, some of these designs make tradeoffs regarding privacy, efficiency, and/or security. Whether these tradeoffs are acceptable is a matter of policy, and requires coordination between different regulators and central banks.

In view of these implications—and some of the corresponding tensions that arise—we argue that the US and the EU should work together alongside other partners to create the technological and regulatory environment to enable privacy-preserving cross-border CBDCs. The US and the EU should seize the emergence of CBDCs as an opportunity to finally establish a transatlantic privacy framework, and clarify its interplay with the prevention of money laundering and financing of terrorism (AML/CFT/CPF). More broadly, both should harness the clout of their combined financial systems to develop digital asset regulation and standards with a global reach and democratic values. These regulatory developments would not only streamline regulatory guidelines, but they could also directly impact and ease the technical development of a cross-border CBDC.

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